WikiFrameworksQuebec Law 25Accuracy and Retention for Decision-Making

Accuracy and Retention for Decision-Making

Updated: 2026-02-23

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.

Executive Takeaway

Organizations must ensure personal information used for decision-making is accurate and retain it for a minimum of one year following the decision.

ImpactMedium
ComplexityMedium

Why This Matters

  • Prevents adverse impacts on individuals resulting from decisions based on outdated or incorrect personal data.
  • Ensures individuals have adequate time to exercise their right to access, rectify, or contest decisions made about them, mitigating regulatory compliance risk.

What “Good” Looks Like

  • Implementing data validation rules for inputs to maintain accuracy before a decision is executed.
  • Configuring automated retention policies to preserve decision-making data for exactly one year, balancing compliance with storage limitation principles; tools like WatchDog Security's Posture Management can help detect misconfigurations and provide remediation guidance for retention-related settings where applicable.

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.

LAW25 § 11

"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."

VersionDateAuthorDescription
1.0.02026-02-23WatchDog Security GRC TeamInitial publication