Collection from Minors
Plain English Translation
Under Quebec Law 25 section 4.1, an organization cannot collect personal information from a minor under 14 years of age without obtaining explicit consent from their parent or legal tutor. The only exception is if the collection of information is clearly for the minor's benefit. To meet these Quebec privacy law minors under 14 requirements, organizations must establish clear age-verification and parental consent processes.
Technical Implementation
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Required Actions (startup)
- Implement basic age-gating dropdowns or date-of-birth checks on sign-up forms.
- Update the privacy policy to state that the service is not intended for users under 14 without parental consent.
Required Actions (scaleup)
- Develop a parental consent workflow that triggers when a user identifies as under 14.
- Ensure cookie banners do not track minors under 14 without explicit parental authorization.
No, under Loi 25 consentement rules, a minor under 14 cannot independently consent to data collection. Their information may only be collected without parental consent if the collection is clearly for the minor's benefit.
The person having parental authority typically refers to a parent or a legally appointed tutor who possesses the legal right to make decisions on behalf of the minor under Quebec civil law.
The Law 25 exception clearly for the minor's benefit refers to situations where the collection of data is essential and immediately advantageous to the child, such as emergency medical services or acute safety interventions.
Organizations must implement age-gating controls during the onboarding or data collection process to ask for the user's age or date of birth to determine how to verify age and parental consent Law 25. If the user is under 14, the system must pause collection and trigger a parental consent workflow.
Organizations should maintain a parental consent collection record that logs the time, date, identity of the parent or tutor, and the specific mechanism used to verify and obtain their approval under Quebec Law 25 requirements for collecting data from minors. Tools like WatchDog Security's Compliance Center can help structure evidence collection and provide an auditable view of consent records linked to this control.
While the Quebec Law 25 minor 14 years old consent rules state that a minor 14 years of age or over can give consent themselves, organizations should ideally notify the user once they turn 14 to provide them direct control over their data and allow them to refresh their consent independently.
Law 25 consent rules for online services and apps dictate that organizations cannot deploy tracking cookies or profiling technologies on known minors under 14 without obtaining verifiable parental authority consent first.
Yes, an organization can collect a minor's personal information indirectly from the parent or tutor, as they are the ones legally authorized to provide the required Loi 25 article 4.1 consentement autorite parentale on the minor's behalf.
Violating the Quebec Law 25 consent requirements for children can result in severe penalties, including administrative fines up to $10,000,000 or 2% of worldwide turnover, and penal fines up to $25,000,000 or 4% of worldwide turnover.
A key expectation under § 4.1 is being able to prove when and how parental authority consent was obtained before collecting a child’s data. Tools like WatchDog Security's Compliance Center can centralize evidence for this control (e.g., consent logs, workflow approvals) and help track gaps when required records are missing or incomplete.
Operationalizing this control requires defined steps (age-gate, stop collection, obtain verified parental consent, record evidence, and enforce tracking limitations). Tools like WatchDog Security's Policy Management can document and version-control the procedure while tracking staff acknowledgment, and WatchDog Security's Secure File Sharing can be used to exchange consent documentation securely with strong access controls and audit logs.
"The personal information concerning a minor under 14 years of age may not be collected from him without the consent of the person having parental authority or of the tutor, unless collecting the information is clearly for the minor’s benefit."
| Version | Date | Author | Description |
|---|---|---|---|
| 1.0.0 | 2026-02-23 | WatchDog Security GRC Team | Initial publication |