COBALTIUM

Québec Law 25 (Bill 64)

I have been asked about the new compliance requirements that start in September 2023. Most clients have had opinions and recommendations from their attorneys already, I do not intend to replace those recommendations with this. Here is a summary, in my personal opinion, on what you need to have in place right now to be compliant.

Your site should:

  • Provide the name and contact information of your compliance officer (This is NOT myself of Cobaltium. It must an internal person)
  • Proof of consent
  • Records of consent
  • Privacy policy
  • Cookie Policy
  • Retention Policy
  • Imprint
  • General terms
  • Legal notice

You are also responsible for generating a report of all events and keeping that report. All events MUST be submitted to the Quebec government.

FORM (French only): https://www.cai.gouv.qc.ca/documents/CAI_FO_avis_incident_confidentialite.pdf

You should have the means to:

  • allow to opt out
  • see and remove their own data
  • make official requests
  •  automate the retention as per your policy

The great news is that most of you have the above integrated into your web site already!