Nov 192021
 November 19, 2021  Posted by  Laws, Non-U.S.

Jérémie Wyatt, Véronique Barry, and Imran Ahmad of Norton Rose Fulbright write:

In recent updates (available here and here), we announced the tabling of Bill 64 (Bill), which purports to implement an ambitious reform of the privacy legislation framework. More than one year after being tabled, the Act to modernize legislative provisions as regard the protection of personal information has now come into force.

Impact of the coming into force

Even though the Bill was assented to last September 22, only a few sections came into force on that date, notably those relating to the reports on the application of privacy legislation that the Commission d’accès à l’information (Quebec’s access to information commission, or CAI) must present to the government. The Bill’s other sections will come into force gradually. The sections on the appointment of persons in charge of protecting personal information and the confidentiality incident notification obligations will come into force on September 22, 2022. September 22, 2023, will mark the coming into force of a vast majority of the sections, including those providing for penal sanctions, assessing privacy-related factors, developing privacy policies and practices, as well as changes in consent. Finally, the right to portability provision will come into force on September 22, 2024. Section 165 offers enterprises and bodies a grace period for aligning their practices with the many new requirements implemented by the Bill’s other 164 sections within the allotted time limit.

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