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ARTICLE · 20 MARCH 2024

Data Anonymization Under Law 25: Québec Interpretation — European Facsimile

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The aim of this bulletin is to analyze the draft regulation respecting the anonymization of personal information using a comparative law approach. It is divided into four main themes...

CanadaPrivacy
Julie Uzan-Naulin
Julie Uzan-Naulin
William Deneault-Rouillard
William Deneault-Rouillard
Jade Paquin-Robidoux
Jade Paquin-Robidoux
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The aim of this bulletin is to analyze the draft regulation respecting the anonymization of personal information using a comparative law approach. It is divided into four main themes: the concept of anonymization, the anonymization procedure under the draft regulation, European law, and the associated sanctions.

Background

On December 20, 2023, the draft Regulation respecting the anonymization of personal information was officially published.1 This regulation will apply to all private enterprises, 2 public bodies and professional orders in Québec.3 It aligns with the concept of "anonymization" introduced into Québec law through Law 25.4 Note that, according to the Commission d'accès à l'information du Québec (the "Commission"), Québec organizations may only anonymize data in accordance with the criteria and terms set out in the draft regulation.5 In other words, the Commission contends that it is impossible to anonymize personal information until such time as

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