Use Of Biometric Data: Québec's Privacy Commissioner Keeps The Bar High

The use of biometrics is growing in both the private and public sectors. In its latest progress report (2023-2024), Quebec's privacy commissioner, the Commission d'accès à l'information ("CAI"), stated that it received 124 declarations (including 118 from businesses), which represents an increase of 59% over the previous year. While this increase can be partly attributed to the fact that the Act to modernize legislative provisions as regards the protection of personal information ("Law 25") includes a requirement to notify the CAI before using biometric data (an obligation that was previously limited to the creation of a biometric database), we can certainly expect this trend to continue over the next few years.