Privacy: Compliance for Clinics in Quebec

Clinics operating in Quebec are subject to strict privacy obligations governing the collection, use, disclosure, and protection of personal information, including personal health information.

This article provides an overview of the privacy framework applicable to clinics in Quebec, explains the key requirements introduced by Loi 25, and outlines how Colib supports clinics in implementing security and governance measures aligned with these obligations. This content is provided for informational purposes only and does not constitute legal advice.

Privacy Laws Applicable to Clinics in Quebec

Loi 25 — Quebec’s Privacy Modernization Framework

Loi 25 (formerly Bill 64) modernizes Quebec’s privacy regime by amending, among other statutes, the Act respecting the protection of personal information in the private sector.

Loi 25 applies to any organization that collects, uses, or discloses personal information in the course of its activities, including private clinics and healthcare professionals operating in Quebec.

Loi 25 introduces enhanced obligations related to:

• governance and accountability for personal information;

• consent, transparency, and purpose limitation;

• data security and confidentiality incident management;

• alignment with leading international privacy standards.

PIPEDA and Quebec Clinics

In addition to Loi 25, PIPEDA (Personal Information Protection and Electronic Documents Act) may apply in certain contexts.

Quebec has been recognized as having privacy legislation that is substantially similar to PIPEDA. As a result, Loi 25 generally governs personal information handled within Quebec, particularly for healthcare and local commercial activities.

However, PIPEDA may still apply in specific situations, including:

• interprovincial or cross-border data flows;

• interactions with federally regulated organizations;

• certain commercial activities involving personal information outside Quebec.

Clinics should therefore ensure their privacy practices meet the expectations of both Loi 25 and PIPEDA, depending on the context.

Core Privacy Principles Under Loi 25

Loi 25 is built around several foundational principles that clinics must respect:

• Accountability: organizations must implement policies and practices demonstrating compliance.

• Consent: consent must be clear, informed, and given for specific purposes.

• Limitation of collection: only information strictly necessary for the stated purposes may be collected.

• Accuracy, retention, and destruction: information must be accurate, retained only as long as necessary, and securely destroyed when no longer required.

• Transparency: organizations must clearly inform individuals about how their information is handled.

• Security safeguards: appropriate administrative, technical, and physical safeguards must be in place to protect personal information.

These principles are consistent with PIPEDA’s fair information principles.

How Colib Supports Compliance with Loi 25 and PIPEDA

Colib is designed to help clinics align their operational practices with the technical and organizational expectations set out in Loi 25 and PIPEDA, particularly in the areas of security, access control, accountability, and transparency.

Access Controls and Security Measures

Colib provides:

• Individual user accounts with unique credentials.

• Granular, role-based access controls defined by the clinic.

• Two-factor authentication (2FA) for practitioners and for clients using the client portal.

• IP address restrictions, when necessary, to limit access to approved networks or locations.

These measures help prevent unauthorized access and support both Loi 25 and PIPEDA security requirements.

Accountability and Auditability

• Detailed activity logs allow clinic owners to review when personal information was accessed or modified, and by whom.

• These logs support internal monitoring, investigations, and accountability obligations.

Data Hosting and Protection

• Data encrypted in transit and at rest.

• Personal and health information hosted on Canadian servers.

• Regular backups to ensure data availability and integrity.

• Logical separation between production, testing, and development environments.

Consent, Forms, and Documentation

• Customizable electronic forms allow clinics to clearly inform patients about the collection and use of their personal information.

• Consent can be documented as part of clinical and administrative workflows.

• Real-time and automatic data saving reduces the risk of accidental data loss.

Organizational Obligations Under Loi 25

Loi 25 introduces governance and accountability obligations that go beyond technical safeguards.

Governance and Responsibility

Clinics are required to:

• establish internal privacy policies and practices;

• designate a person responsible for the protection of personal information;

• assess and manage privacy risks.

While Colib provides tools that support these practices, each clinic remains responsible for its own governance and compliance.

Transparency Toward Individuals

Organizations must provide clear and accessible information regarding:

• the purposes for which personal information is collected;

• how it is used and disclosed;

• individuals’ rights of access and rectification.

Clinics can use Colib’s forms and documentation tools to support these transparency obligations.

Privacy Breach Notification Obligations

In the event of a confidentiality incident involving personal information that presents a risk of serious harm, Loi 25 requires organizations to:

• notify affected individuals;

• notify the Commission d’accès à l’information;

• document the incident and corrective measures taken.

PIPEDA imposes similar breach notification requirements when applicable.

Colib includes preventive safeguards such as encryption, access controls, and activity logging. However, incident assessment and notification obligations remain the clinic’s responsibility.

Clinic Responsibilities and Colib’s Role

Colib acts as a technology service provider supporting clinics in the secure management of personal and health information.

What Colib Provides

• A secure, access-controlled platform.

• Security and privacy features aligned with Loi 25 and PIPEDA expectations.

• Tools supporting consent documentation and transparency.

• Canadian data hosting and encryption.

Colib’s own information-handling practices are described in its Privacy Policy:
https://www.colib.io/privacypolicy

What Clinics Remain Responsible For

• Determining the purposes of collection and use of personal information.

• Maintaining privacy policies and internal procedures.

• Obtaining valid consent in accordance with applicable law.

• Managing and reporting privacy incidents when required.

Colib’s contractual and legal framework, including responsibilities and limitations, is set out in its Terms of Service:
https://www.colib.io/terms

Colib provides the technical foundation, while legal accountability remains with the clinic.

Key Takeaways

• Loi 25 governs privacy obligations for clinics operating in Quebec.

• PIPEDA may also apply in certain interprovincial or federal contexts.

• Colib provides security, access control, auditability, and data protection features aligned with both frameworks.

• Full compliance requires technical safeguards as well as organizational governance and consent management.

Questions?

If you have questions about Loi 25, PIPEDA, or how Colib supports privacy compliance for clinics in Quebec, please contact support@colib.io.