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Quebec Law 25 vs EU GDPR
Act respecting the protection of personal information in the private sector (CQLR c P-39.1), as amended by Law 25 (Bill 64) (Quebec, Canada) compared with Regulation (EU) 2016/679 (General Data Protection Regulation) (European Union (EEA)) on the same topics. Every value comes from the law pages, which link to the official sources.
| Topic | Quebec Law 25 Quebec, Canada 10/14 facts confirmed by two sources | EU GDPR European Union (EEA) ✓ Confirmed by two sources |
|---|---|---|
| Status | In force; amendments phased in Sep 2022, Sep 2023 (main wave) and Sep 2024 (data portability).✓ | In force since 25 May 2018. Digital Omnibus amendments proposed Nov 2025, not adopted as of Oct 2026.✓ |
| Who it applies to | Enterprises that collect, hold, use or communicate personal info in the course of carrying on business in Quebec. | Any organisation processing personal data in the context of an EU establishment, plus non-EU organisations that offer goods/services to people in the EU or monitor their behaviour there.✓ |
| Size thresholds | No size or revenue thresholds; applies to any enterprise handling personal info.✓ | None — applies regardless of size. Limited record-keeping relief for organisations under 250 staff (Art 30(5)), lost if processing is risky, not occasional, or includes special-category or criminal data.✓ |
| Regulator | Commission d'accès à l'information du Québec (CAI)✓ | National data protection authorities (DPAs), coordinated by the European Data Protection Board (EDPB)✓ |
| Breach or incident reporting | Notify the CAI and affected persons promptly of any confidentiality incident that presents a risk of serious injury; keep an incident register and give it to the CAI on request. The Act sets no fixed number of days.✓ | Notify the competent supervisory authority without undue delay and within 72 hours of becoming aware, unless the breach is unlikely to result in a risk to individuals (Art 33). If you have an EU main establishment, that is your lead authority; if you have no EU establishment (even with an EU representative), notify the authority of every member state where affected people live (EDPB Guidelines 9/2022, para 73). Tell affected individuals without undue delay if the risk is high (Art 34).✓ |
| Deadline to answer personal data requests | Respond to access or rectification requests within 30 days of receipt; no answer in time counts as a refusal. Data portability in a structured, commonly used format available since 22 Sep 2024.✓ | 1 month from receipt; extendable by 2 further months for complex requests if the person is told within the first month. Free of charge unless manifestly unfounded or excessive.✓ |
| Data protection officer | The person with the highest authority (e.g., CEO) is by default the person in charge of protecting personal information; may delegate in writing. Title and contact details must be published on the website.✓ | DPO mandatory for public bodies, and where core activities involve large-scale regular and systematic monitoring, or large-scale processing of special-category or criminal-offence data.✓ |
| Local representative | Being verified | Non-EU controllers/processors caught by Art 3(2) must appoint an EU representative in writing, unless processing is occasional, low-risk and excludes large-scale sensitive data, or they are a public body.✓ |
| Sending data abroad | Before communicating personal info outside Quebec (including to other provinces), complete a privacy impact assessment; transfer only if it shows adequate protection, and put a written agreement in place (since Sep 2023).✓ | Transfers outside the EEA need an adequacy decision (e.g. UK, Switzerland, EU-US Data Privacy Framework), or safeguards such as Standard Contractual Clauses or Binding Corporate Rules, or a narrow Art 49 derogation.✓ |
| Cookies and consent | Before collecting, tell people about any technology that identifies, locates or profiles them (e.g., ad cookies) and how to activate it; these functions must be off by default. Public tech products must use the highest privacy settings by default, except cookie settings.✓ | Cookie/tracker consent is governed by the ePrivacy Directive Art 5(3); where consent is the GDPR legal basis it must be freely given, specific, informed, unambiguous and as easy to withdraw as to give.✓ |
| Maximum penalty | Administrative monetary penalties up to C$10M or 2% of worldwide turnover (whichever is greater); penal fines up to C$25M or 4% of worldwide turnover for enterprises (C$5,000-C$100,000 for individuals). | Up to EUR 20 million or 4% of total worldwide annual turnover, whichever is higher (lower tier: EUR 10 million or 2%).✓ |
= confirmed by two independent sources, at least one official.
Facts marked “Being verified” are still being confirmed and are not given as answers.
Who each law applies to
- Quebec Law 25
- Enterprises that collect, hold, use or communicate personal info in the course of carrying on business in Quebec.
- EU GDPR
- Any organisation processing personal data in the context of an EU establishment, plus non-EU organisations that offer goods/services to people in the EU or monitor their behaviour there.
What you must do under Quebec Law 25
- Designate and publish the person in charge of personal information (default: the CEO).
- Adopt and publish governance policies and a plain-language privacy policy.
- Do a privacy impact assessment before sending personal info outside Quebec and sign a written agreement.
- Report confidentiality incidents with risk of serious injury to the CAI and affected people; keep an incident register.
- Disclose use of identification, location or profiling technologies and how to turn them on.
- Tell people when a decision is made solely by automated processing and explain it on request.
What you must do under EU GDPR
- Identify a lawful basis for every processing purpose and record it.
- Publish a clear privacy notice covering purposes, recipients, retention and rights.
- Keep a record of processing activities and sign Art 28 contracts with processors.
- Run a DPIA before high-risk processing such as large-scale profiling or sensitive data.
- Report qualifying breaches within 72 hours (lead authority, or every relevant DPA if you have no EU establishment) and log all breaches.
- Answer access, erasure and other rights requests within one month.
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Information only, not legal advice. Laws change; confirm with the regulator or a qualified lawyer before relying on this page. Spotted an error? Email contact@