PIPEDA, Law 25, and CRM: A No-Drama Compliance Guide

Let’s be honest… When someone says “data privacy regulation,” your brain checks out faster than a sales dashboard with zero leads. But this actually matters, especially if you’re a Canadian SMB handling customer data, trying to stay compliant, and very much not looking to become a cautionary headline.

Today we’re decoding PIPEDA (Canada’s federal privacy law) and Law 25 (Québec’s modernized privacy regime) the Cone way: clear, practical, and maybe even kinda fun.

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PIPEDA, in real words

• What it is: Canada’s federal private-sector privacy law that sets the ground rules for how organizations collect, use, and disclose personal information during commercial activities. It also covers employee information for federally regulated organizations (e.g., banks, telecoms).

• Where it applies: Across Canada unless a province has a“substantially similar” private-sector law (e.g., QC, AB, BC) — but PIPEDA still applies to interprovincial/international transfers of personal information.

• What counts as personal info: Broadly, any information about an identifiable individual (names, contact info, IDs, device data, etc.).

• Core rules: Follow PIPEDA’s 10 Fair Information Principles(accountability, identifying purposes, consent, limiting collection, limiting use/disclosure/retention, accuracy, safeguards, openness, individual access, challenging compliance). These are the practical “how-to” for compliance.

• Individuals’ rights: People can access their personal information, challenge accuracy, and complain to the Office of the PrivacyCommissioner of Canada (OPC) if they think an organization is offside.

• Enforcement & remedies: The OPC can investigate complaints; matters can proceed to Federal Court, which may order organizations to change practices and award damages. (source)

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The two PIPEDA things SMBs miss most

1. Breach rules: Since Nov 1, 2018, you must assess whether a breach poses a real risk of significant harm (RROSH); if yes, report to the OPC, notify affected individuals, and keep a breach record. The OPC even has a quick RROSH tool to help you decide.
2. Fines are real: Knowingly failing to report/notify or to keep breach records can lead to fines up to $100,000 per offence. That’s a lot of maple syrup.

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Enter Law 25 (a.k.a. Bill 64) — Québec turned up the dial

If you’re in Québec or you sell to Québec residents (spoiler: that’s many of us), Law 25 layers on stricter rules. Major chunks came into force Sept 2022 and Sept 2023, with data portability landing Sept 22, 2024.

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What Law 25 expects from businesses

• Appoint & publish a Privacy Officer: The person with the highest authority in the company is thePrivacy Officer by default (can delegate). Publish their title and contact info on your website (or make it accessible another way if no site).

• Do Privacy Impact Assessments (PIAs/EFVPs): Mandatory for any project to acquire, develop, or overhaul an information system or electronic service delivery involving personal data and before communicating personal information outside Québec.

• Consent for minors: If the individual is under 14, consent must come from a parent or tutor(unless collection is clearly for the minor’s benefit). From 14+, the minor can consent (or a parent/tutor may)

• Breach playbook: For any confidentiality incident, assess risk; if there’s a risk of serious injury, you must notify the CAI and the affected individuals, and you must keep a register of incidents(and provide it to the CAI on request).

• Transfers outside Québec: Conduct a PIA first; the info may be sent only if it will receive adequate protection, and the transfer must be covered by a written agreement reflecting the PIA results (applies to outsourcing outside Québec, too).

• Data portability: New systems must allow a person to obtain their computerized personal information in a structured, commonly used technological format (this is how Law 25implements portability). (source)

And yes, the fines can sting

Law 25 allows penal fines up to $25 million or 4% of worldwide turnover (whichever is higher) for the worst offences, plus administrative penalties for others. This is the “we’re serious” part.

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Why should an SMB actually care?

Because your customers care, and they’re voting with their wallets. In Cisco’s 2024 consumer privacy study, 75% of people said they won’t buy from organizations they don’t trust with their data, and 38% identified as “Privacy Actives” who’ve switched providers over data practices. Translation: privacy drives revenue.

Oh, and breaches are expensive: IBM’s 2024 study pegs the average cost of a Canadian breach at $6.32 million (yes, million). You don’t need that kind of “marketing.”

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PIPEDA vs. Law 25

• PIPEDA = federal ground rules (consent, safeguards, access, breach reporting).
• Law 25 = Québec’s turbo version: privacy officer, PIAs, portability, minors’ consent, transfer assessments, and bigger penalties.

If you’re in Ontario but collect Québec leads? Law 25 still applies to that Québec personal data. Your CRM and processes should reflect both layers.

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CRM + privacy: how Cone helps you not panic

Let’s be real — a CRM that ignores privacy is like a car without brakes. It moves… until it doesn’t.

Here’s how to keep it boring (which is what you want in compliance):

• Canadian data residency & bilingual support.
  
  • Cone emphasizes data stored in Canada and service in French and English — great signals for sovereignty and accessibility, especially for Québec operations.
• Consent, lawful basis & preferences.
  
  • Use custom fields and forms to record consent (e.g., purpose, date, channel) and segment audiences accordingly.
• Requests, exports & deletions.
  
  • Be ready for access/correction/erasure requests — your CRM should make it fast to find a contact, export their records, and action a deletion when appropriate.
• Breach-readiness baked into process.
  
  • Store an incident checklist in your CRM workspace and track investigations, notices, and RROSH assessments (the OPC tool helps).
• Québec cross-border logic.
  
  • If any processing happens outside Québec, document your assessment and vendor safeguards right in your CRM notes/tasks (Law 25 loves a paper trail).

Friendly reminder: Law 25 doesn’t ban out-of-province or cloud vendors. It asks you to assess and document risk before personal info leaves Québec. Compliance ≠ “no cloud”, it = “prove you thought it through.”

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TL;DR

• PIPEDA = Canada’s federal rulebook (consent, safeguards, breach reporting with fines up to $100k for willful non-reporting).
• Law 25 = Québec privacy upgrade (privacy officer, PIAs, portability, minors’ consent, cross-border assessments, fines up to $25M or 4%).
• Customers care: 75% won’t buy from brands they don’t trust; 38% have already switched.
• Breaches are pricey: $6.32M average in Canada.
• Cone CRM helps you operationalize privacy with Canadian hosting signals, bilingual support, consent tracking, and tidy workflows for requests and incidents.

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Quick FAQs

• ‍Do I need a lawyer to do a PIA?
  Not required, but legal review helps — especially for higher-risk projects. Québec’s resources explain what to cover.‍

• If my cloud is in Canada but outside Québec, am I fine?
  You still need a transfer assessment under Law 25 because the data leaves Québec. Document it.‍

• Will customers care if I do all this?‍
  Yes. Most won’t buy if they don’t trust you with data — so tell your story on your website and in onboarding.

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Want a CRM that helps you capture consent cleanly, move fast on access/deletion requests, and keeps everything tidy for audits — with a Canadian footprint and bilingual experience? Cone was built for Canadian SMBs that take trust seriously.

_{Disclaimer: This is information, not legal advice. Call your lawyer (or your mom — she definitely has thoughts).}