Bill 64 – Chief Privacy Officer Will Be Mandatory In Private Organizations

Bill 64 seems bold given its numerous provisions that indicate a clear intention to focus on the principle of accountability. While the current Act respecting the protection of personal information in the private sector ("Quebec Private Sector Act")¹ never addresses the principle of accountability or transparency (note that the terms "accountable," "accountability" and "transparency" do not appear in any provision in the current Act), Bill 64 provides a major upgrade by instantly adding a whole section based on the accountability principle.²

This section on accountability provides numerous new obligations such as the obligation to: implement governance policies and practices for the protection of personal information, establish a framework for the keeping and destruction of the information, establish a process for dealing with complaints, assess privacy-related factors, report security incidents in certain circumstances and keep a register of confidentiality