Anonymization Regulation in Quebec: What you need to know

The Act Respecting the Protection of Personal Information in the Private Sector and the Act respecting Access to documents held by public bodies and the Protection of personal information as amended by the Act to modernise legislative provisions as regards the protection of personal information (together the "Quebec Privacy Legislation"), govern the collection, use and communication of personal information in Quebec.

Quebec Privacy Legislation stipulates that organizations must destroy personal information once the purposes for which it was collected have been achieved, unless its retention is required to comply with applicable laws. As an alternative to destruction, Quebec Privacy Legislation allows organizations to anonymize personal information if it is used for serious and legitimate purposes.

On Dec. 20, 2023, the Draft Regulation respecting the anonymization of personal information, Gazette No. 51 of 20-12-2023 ("Anonymization Regulation"), was published. We have prepared our comments on the Anonymization Regulation, presented in the form of a flow chart, in the context of the consultation by the Secrétariat à la réforme des institutions démocratiques, à l'accès à l'information et à laïcité.

Link to flow chart

If you have additional questions regarding the anonymization of personal information or other obligations under Quebec Privacy Legislation, contact our Cyber Security and Data Protection Group.