Accuracy and Retention for Decision-Making
Plain English Translation
Under Quebec Law 25 section 11 requirements, organizations must ensure that any personal information used to make a decision about an individual is both up to date and accurate. Furthermore, to protect the individual's rights and allow for potential recourse, the Law 25 one year retention following the decision rule mandates that this specific data be securely retained for at least one year after the decision has been made.
Technical Implementation
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Required Actions (startup)
- Identify all systems where personal data is used to make decisions about individuals.
- Implement basic validation to ensure data is up to date before decisions are finalized.
- Establish manual processes or basic calendar reminders to prevent deletion of this data before the one-year mark.
Required Actions (scaleup)
- Implement automated validation rules for inputs across applications handling decision-making data.
- Configure retention period settings in databases to automatically preserve decision records for at least 365 days.
- Maintain audit logs of when decisions are made and what data was used.
Required Actions (enterprise)
- Integrate data quality management tools to continuously monitor and enforce accuracy.
- Utilize automated lifecycle management policies within the data warehouse to strictly enforce the one-year retention hold.
- Conduct routine audits of the consent management record and data subject request log to ensure deletion requests do not prematurely purge required decision-making records.
Quebec Law 25 section 11 requirements state that any personal information used to make a decision about an individual must be up to date and accurate. Additionally, this data must be kept for at least one year following the decision.
To comply with the Law 25 one year retention following the decision mandate, organizations must keep the personal information used to make a decision for at least one year after the decision is rendered.
A decision under Loi 25 article 11 accuracy and retention typically refers to any determination that significantly affects the individual, such as hiring decisions, credit approvals, insurance claims processing, or automated service denials.
What does up to date and accurate mean under Loi 25 depends on the context, but it requires organizations to take reasonable steps to verify the data's correctness and currency immediately prior to using it for a decision, ensuring the outcome is not based on obsolete or flawed records.
Yes, the Loi 25 retention period for automated or profiling decisions applies equally to both human-driven and automated processes. Any personal information feeding into an automated decision engine must be accurate and retained for the one-year period.
To prove how to prove compliance with Loi 25 section 11, organizations should maintain clear Law 25 documentation for decision-making records retention, including data management policies, automated retention configurations, and audit logs linking specific data to specific decisions.
Any system storing Law 25 personal information used for decision-making is in scope. This includes HR Information Systems (HRIS), Customer Relationship Management (CRM) platforms, credit scoring tools, and applicant tracking systems.
Yes, Quebec privacy law accuracy requirements for HR decisions apply to employment contexts. Information used for hiring, promotions, or terminations must be accurate and kept for at least one year after the decision.
IT teams should enforce validation rules for inputs, implement data quality monitoring, and ensure that source systems are synchronized so that any decision relies on the most current and accurate version of the data available.
No. The statutory requirement to keep the information used to make a decision for at least one year overrides an individual's immediate right to erasure, ensuring the data remains available if the individual chooses to contest the decision.
Meeting § 11 requires knowing which systems and workflows generate or rely on decision-making personal information and ensuring records are not removed before the one-year mark. Tools like WatchDog Security's Compliance Center can map this control to required evidence, collect supporting artifacts (policies, logs, configurations), and highlight gaps when retention controls are missing or outdated.
Evidence usually spans multiple owners (privacy, engineering, IT ops) and sources (tickets, logs, retention configs), which can make audits slow and inconsistent. Tools like WatchDog Security's Trust Center can centralize approved evidence and access controls for sharing with stakeholders, while WatchDog Security's Compliance Center helps organize artifacts and automated evidence collection against § 11 expectations.
"Every person carrying on an enterprise must ensure that any personal information held on another person is up to date and accurate when used to make a decision in relation to the person concerned. The information used to make such a decision is kept for at least one year following the decision."
| Version | Date | Author | Description |
|---|---|---|---|
| 1.0.0 | 2026-02-23 | WatchDog Security GRC Team | Initial publication |