Bill 64 Receives Royal Assent And Signals Major Reform For Quebec’s Privacy Landscape

M. Imtiaz Karamat is an IP Osgoode Alumnus and Associate Lawyer at Deeth Williams Wall LLP. This article was originally posted on E-TIPS™ For Deeth Williams Wall LLP on September 28, 2021.

On September 22, 2021, Quebec’s major privacy reform bill, An Act to modernize legislative provisions as regards the protection of personal information (Bill 64), received royal assent after being adopted by the Quebec National Assembly the day before.

Bill 64 is set to dramatically change Quebec’s current framework for the protection of personal information by amending existing legislation to impose new obligations on regulated private and public sector entities, as previously reported by the E-TIPS® Newsletter here. By passing Bill 64, Quebec becomes one of the first Canadian jurisdictions to introduce such a substantial privacy overhaul and likely will lead the trend across Canada, with provinces like Ontario currently considering updating its own privacy regime.

The adopted amendments will not take immediate effect, with most of Bill 64’s provisions set to come into force on September 22, 2023 and a few provisions coming into force a year earlier, on September 22, 2022. Those provisions that will become law on September 22, 2022 include new breach notification requirements that will mandate private sector organizations to notify impacted individuals and the Commission d’accès à l’information of cybersecurity incidents. The gradual implementation of Bill 64 offers regulated entities the opportunity to update their operations and systems to ensure compliance with the province’s new privacy landscape.  

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