Employee training and Quebec's Law 25: what the text actually requires (English)
Many vendors state that Quebec's Law 25 requires businesses to train their employees on privacy. For a private-sector enterprise, the statute does not say that. In the Act respecting the protection of personal information in the private sector, the word training appears only once in substance, at section 3.4, which lists measures the person in charge of the protection of personal information may suggest at any stage of a project subject to a privacy impact assessment, such as holding privacy training activities for the participants in that project. It is a permissive, illustrative measure scoped to project participants, not a general duty to train all staff. The contrast with the public sector is instructive: section 63.3 of the Act respecting access to documents held by public bodies requires a public body's published governance rules to include a description of the training and awareness activities it offers its personnel. The private-sector equivalent, section 3.2, uses closely parallel wording about the roles and responsibilities of personnel throughout the life cycle of the information, but does not add that sentence about training. Training nonetheless remains the practical way to satisfy obligations the statute does impose: section 3.2 requires governance policies that set out personnel roles and responsibilities and that are actually implemented; section 10 requires security measures that are reasonable given the sensitivity, purpose, quantity, distribution and medium of the information; and section 3.5 requires reasonable measures when a confidentiality incident occurs, which depends on staff recognizing and reporting one. Failure to take the security measures required by section 10 is among the breaches that may lead to an administrative monetary penalty under section 90.1 and to penal proceedings under section 91. HelionAI offers a nine-part training module in French and English with a scored quiz, a certificate for those who pass, and an exportable register, to help organizations organize and document staff training so the evidence is ready when a review comes.
Not legal advice. HelionAI is a software tool, not a law firm. The information provided is general in nature and does not constitute legal advice. Whether any particular training program satisfies your obligations depends on your circumstances. For a specific situation, consult qualified legal counsel.