Since the gradual implementation of Bill 25, Quebec SMEs have had to rethink how they manage personal information. This law imposes new obligations on all businesses, regardless of their size or sector of activity. Failure to comply exposes them to significant penalties and a loss of trust from customers and partners.
Codex Consulting supports SMEs in this transition by combining expertise in
data governance, cloud architecture, and business intelligence. Our goal: to transform regulatory requirements into levers for performance and credibility.
Legal obligations to be taken seriously
Act 25 applies to any organization in Quebec that collects, uses, or stores personal information. It provides for fines of up to $25 million or 4% of global revenue in the event of a serious breach. But beyond the numbers, it is your reputation and the trust of your customers that are at stake.
A security breach, poorly documented consent, or an incomplete privacy policy can have very real financial and operational consequences, even for a small business.
Key obligations to be aware of
1. Governance and appointment of a data protection officer
Each organization must appoint a data protection officer. By default, this is the CEO, but the role can be assigned to a member of the team. The data protection officer’s contact details must be made public.
2. Transparency and privacy policy
You must clearly inform the individuals concerned about the data collected, how it will be used, and the third parties with whom it may be shared. This information must be accessible, in particular via an up-to-date privacy policy.
3. Explicit consent
Consent must be freely given, informed, and specific for each purpose. Pre-checked boxes or implied consent are no longer acceptable.
4. Data protection and minimization
It is mandatory to implement adequate security measures: encryption, access management, regular updates, deletion or anonymization of data that is no longer needed.
5. Rights of access, rectification, and deletion
Citizens have the right to access their data, correct it, or request its deletion. You must be able to respond within the legal time frame.
6. Reporting incidents
In the event of a leak or unauthorized access posing a serious risk, the Commission d’accès à l’information (Access to Information Commission) and the persons concerned must be informed.
7. Privacy Impact Assessment (PIA)
Any project involving personal data, particularly if it is processed or hosted outside Quebec, must undergo an impact assessment before implementation.
SMEs: where to start?
For many leaders, compliance may seem complex or costly. However, it is possible to take a gradual and effective approach. Here are a few simple steps you can take right now:
- Make an inventory of the personal data you collect and store
- Identify the tools and providers that process this data (CRM, cloud computing,
marketing solutions, etc.). - Update your collection forms and internal processes
- Write or revise your privacy policy
- Raise awareness among your teams about best practices in data protection
Moving from theory to practice
Understanding Law 25 is one thing; applying it on a daily basis is another. To facilitate this transition, Codex Consulting has developed Privacy Safe, a SaaS platform powered by our expertise.
It enables SMEs to structure and document their compliance procedures: data inventory, centralized consent management, incident response procedures, and action history retention.
The objective is clear: to simplify the implementation of best practices, reduce regulatory complexity, and enable leaders to focus on growing their businesses.
About Codex Consulting
Codex Consulting is a Quebec-based firm specializing in business intelligence, data architecture, and governance. As a certified partner of technologies such as Matillion and Snowflake, we help SMEs fully leverage their data potential while adhering to the highest standards of compliance and security.
Contact : Damien Van Steenberge – damien.van.steenberge@codexconsulting.ca – (514) 589-8483
By Pierre-Louis Bourbon
Codex Consulting
