Introduction
On May 15, 2024, the Québec government published the final version of the Regulation respecting the anonymization of personal information (the “Anonymization Regulation”). The Anonymization Regulation comes into effect on May 30, 2024, with the exception of Section 9 (which requires organizations to maintain a register), which comes into effect on January 1, 2025. The Anonymization Regulation is significant, as it introduces Canada’s first legal framework on the anonymization of personal information.
The Anonymization Regulation sets out the requirements that organizations (both public and private sector) must meet to anonymize personal information in accordance with the Act respecting the protection of personal information in the private sector (the “Québec Private Sector Privacy Act”) and the Act respecting Access to documents held by public bodies and the Protection of personal information. The focus of this advisory will be on the Québec Private Sector Privacy Act. All organizations that anonymize personal information from residents of Québec will be required to ensure that its policies and practices regarding anonymization processes comply with the Anonymization Regulation.
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