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ARTICLE · 02 SEPTEMBER 2020

De-identify, Anonymize And De-index: New Verbs And New Obligations!

Bill 64 contributes its share of novelties by giving new rights to individuals and, as a correlation, imposing new obligations on organizations. In this bulletin for private sector companies...

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Bill 641 contributes its share of novelties2 by giving new rights to individuals and, as a correlation, imposing new obligations on organizations. In this bulletin for private sector companies, we will examine the obligations with respect to the length of retention period and the anonymization of personal information on the one hand, and the obligations resulting from de-indexing on the other.

The Retention Period for Personal Information: Issues Still Outstanding

Section 111 of Bill 64 creates a new s. 23 according to which:

"23. Where the purposes for which personal information was collected or used are achieved, the person carrying on an enterprise must destroy or anonymize the information, subject to any preservation period provided for by an Act.

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