Quebec private sector Act, section 12: de-identified information is still personal information (Act respecting the protection of personal information in the private sector, CQLR c. P-39.1, s. 12, as amended by S.Q. 2021, c. 25 (in force 22 September 2023))
In Quebec, removing direct identifiers makes information de-identified, not anonymous: the Act still treats it as personal information and requires measures against re-identification. Only anonymized information (section 23) leaves the Act.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“(1) de-identified if it no longer allows the person concerned to be directly identified; ... Every person carrying on an enterprise who uses de-identified information must take reasonable measures to limit the risk of someone identifying a natural person using de-identified information.”
Where it was read
Also read from the same source
- For customers or staff in Canada, has each person consented to this new use, or will the data be anonymised to the Canadian standard before it leaves? For Quebec, is the privacy impact assessment done and the written agreement ready?
- Quebec private sector Act, section 12: use for another purpose needs consent or an exception (Act respecting the protection of personal information in the private sector, CQLR c. P-39.1, s. 12, as amended by S.Q. 2021, c. 25 (in force 22 September 2023))
- Quebec private sector Act, section 13: communicating personal information to a third person needs consent (Act respecting the protection of personal information in the private sector, CQLR c. P-39.1, s. 13, as amended by S.Q. 2021, c. 25 (in force 22 September 2023))
- Quebec private sector Act, section 14: consent must be clear, free, informed and specific (Act respecting the protection of personal information in the private sector, CQLR c. P-39.1, s. 14, as amended by S.Q. 2021, c. 25 (in force 22 September 2023))
- Quebec private sector Act, section 17: privacy impact assessment before communicating information outside Quebec (Act respecting the protection of personal information in the private sector, CQLR c. P-39.1, s. 17, as amended by S.Q. 2021, c. 25 (in force 22 September 2023))
- Quebec private sector Act, section 18.4: the commercial transaction exception (Act respecting the protection of personal information in the private sector, CQLR c. P-39.1, s. 18.4, as amended by S.Q. 2021, c. 25 (in force 22 September 2023))
Figures it counts in
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