PIA under Law 25: when and how

You are deploying a new CRM that centralizes customers and employees, or adding a chatbot that collects health information on the site? Before clicking "publish", ask: do we need a PIA (EFVP) (privacy impact assessment)? It is the tool to document risks before a sensitive project goes to production.

What is a PIA (EFVP)?

It is a structured process to describe a project, identify the personal information involved, analyze risks for individuals, propose mitigation measures, and decide whether residual risks are acceptable. The CAI publishes guides and expects a documented approach, not a simple checkbox.

In practice: a PIA is not another legal document to file away: it is proof that we thought about impacts before exposing people to a new processing activity.

When to conduct one

• New SaaS tool (CRM, HR, customer support) centralizing personal information.
• Website redesign with new forms, chat, analytics, or sharing with partners.
• Surveillance, geolocation, or biometrics: new or expanded.
• Profiling or automated decision with significant impact on the individual.
• Disclosure of sensitive information to third parties or outside Quebec.
• Large-scale collection or merging previously separate databases.
• High-risk web projects: invasive trackers, chatbots on health/financial data, etc.

When in doubt, consult official CAI criteria and your legal advisor. A PIA complements, but does not replace, technical controls on the public website.

Typical PIA steps

1. Scoping: project description, stakeholders, data flows.
2. Necessity and proportionality: minimize collection; keep only what is useful.
3. Risk analysis: severity, likelihood, vulnerable individuals.
4. Measures: security, contracts, policy, training.
5. Validation: management / privacy officer approval, monitoring, and planned review.

Documenting the PIA for verification

Keep a dated version of the document (PDF or secure repository): project description, risk analysis, measures adopted, privacy officer or management decision, and review schedule. In case of a complaint or investigation, the CAI expects a structured approach, not just a vague internal note.

Key point: date it, name an owner, and plan a review. A frozen 2022 PIA that no longer reflects the current site protects no one.

Link to the website and visible compliance

A PIA often leads to concrete changes: new cookie banner, update to the privacy policy or web privacy policy, hardened TLS or headers. After deployment, verify the site reflects documented decisions. Otherwise, you create a gap that is easy to exploit in a complaint.

In brief

• A PIA documents risks before launching sensitive or large-scale processing.
• CRM, web redesign, profiling, sensitive data, or transfers outside Quebec: frequent SMB triggers.
• Five steps: scoping, proportionality, risks, measures, validation.
• Keep a dated version; link decisions to the public site and vendor contracts.

Useful references

• CAI, PIA (EFVP) tools and guides: templates and criteria to structure your assessment.
• Act P-39.1 (private sector): obligations related to privacy impact assessments.
• Privacy officer: role in validating and monitoring PIAs.

This text is informational and does not constitute legal advice. For a decision binding your organization, consult the CAI and a legal professional.

Check your website

After a PIA, the public site must reflect your decisions (cookies, policy, forms). Our free technical scan helps confirm deployment matches documentation. It complements, but does not replace, your compliance program.