The new Bill 25, which modernizes personal data protection rules in Quebec, requires businesses to make concrete changes. When properly implemented, it can become a powerful driver of trust and performance. However, in the race toward compliance, many organizations make major Bill 25 related mistakes that hinder their progress or expose them to serious penalties. In this article, we explore the 5 most common Bill 25 mistakes observed in businesses and provide practical advice to help you avoid them effectively.

Mistake #1: Think that Bill 25 only concerns large companies

Common mistake: Numerous SMEs wrongly think that only large companies are affected by Bill 25.

Why it is a problem: The law applies to any organization that collects, holds, or uses personal information, regardless of its size. A small medical clinic, an accounting firm, or an online store are all equally affected. Ignoring this responsibility can lead to fines of up to $25 million or 4% of global revenue, not to mention the reputational damage.

How to avoid it: Put in place progressive compliance strategy, adapt your internal capacities, and prioritize key actions right away.

Mistake #2: To not formally appoint a Data Protection Officer (DPO)

Common mistake: Some companies forget or still hesitate to appoint an official DPO.

Why it is a problem: Since September 2022, the appointment of the DPO is mandatory. His name and contact details must be accessible on the website and known by stakeholder. Without a DPO, it is difficult to ensure a clear data governance, to answer requests, and to document the processes.

How to avoid it: Identify a competent employee, or get an external partner to structure the role and its responsabilities.

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Mistake #3: Limit the company to an update of the privacy policy

Common mistake: Many companies think that by modifying their online privacy policy, they are now compliant with Bill 25.

Why it is a problem: Bill 25 requires much more: data governance, incidents' logbook, explicit consent, private life factors evaluation, and thorough internal mechanisms. A policy alone does not cover the real practices nor the continuous documentation requirement.

How to avoid it: Adopt a global procedure including technological tools, internal processes, and adapted formations for your teams.

Mistake #4: Neglecting employee training

Common mistake: Many organizations do not inform their employees about new practices and requirements to meet.

Why it is a problem: Employees are often the first to interact with personal data through collection, entry, or processing. Without clear training, they risk making unintentional Bill 25 related mistakes: sending data to the wrong recipient, mishandling an incident, or responding improperly to an access request.

How to avoid it: Offer trainings adapted to specific roles: customer support, IT, HR, marketing. A well-informed team reduces the risks of mistakes and is more efficient.

Mistake #5: Wait until September 2025 to react

Common mistake: Many companies postpone the action, thinking they still have many years to prepare.

Why it is a problem: Some requirements are already active and mandatory since 2022-2023. Furthermore, preparing for total compliance (data mapping, updated tools, processes adaptation, awareness) takes time. Waiting until the last minute may provoke organizational stress and increased costs.

How to avoid it: Start right now with a clear roadmap, including progressive steps and defined priorities related to your reality.

🔗 Consult our Bill 25 action plan

Conclusion: Proactive compliance is your best ally

The implementation of Bill 25 may seem complex, but avoiding these common mistakes, your organization is well-positioned to:

  • Reinforce the trust of customers and partners
  • Reduce the risks of fines and legal disputes
  • Optimize information governance

Privacy Safe provides you with useful tools, adaptable models , and an adapted accompaniment so you succeed in complying to Bill 25, at your own pace and for your own needs.

🔗 Talk to a Privacy Safe specialist