Quebec privacy regulator releases final consent guidance
On October 31, 2023, the Commission d’accès à l’information du Québec (the CAI) released its final guidelines for organizations on what constitutes valid consent under Quebec’s new privacy law, Law 25. The guidelines articulate specific requirements for the collection of consent for various activities including secondary uses of data, disclosures to third parties and consent in the context of identification, location and profiling technologies.
The CMA was one of only five business-oriented associations invited by the CAI to provide feedback on a draft version of the document this summer. Our response can be found here.
Marketers should take note that the CAI has maintained its interpretation that express consent should be required when organizations collect personal information through technologies that identify, locate or profile individuals. Given the significant technical implications for organizations and additional consent fatigue risk for consumers that this interpretation implies, organizations are encouraged to consult with their compliance teams to ensure the best path forward for their organization.
Stay tuned for additional blogs and resources from the CMA to help marketers navigate Law 25 compliance.
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