Privacy Officer Under Quebec Law 25: When & How to Delegate (SMB Guide)
The default is the boss — change it
By default the role falls to the person with the highest authority (the owner or CEO). You can delegate it in writing to a manager, an employee, or an external service, and you must publish the title and contact on your website.
What the privacy officer actually does
They oversee the privacy program: approving the policy, handling access and deletion requests, leading breach response, and being the named contact for the Commission d'accès à l'information. For a small business this is a few hours a month, not a full-time job.
How to delegate safely
Put the delegation in writing, give the person real authority and a small budget, and back them with documented processes so the role survives staff turnover. IT Cares can supply the breach-response and access-request workflows the officer relies on.
Action checklist
- ✅ Confirm who holds the role by default (highest authority)
- ✅ Delegate in writing to a named person if desired
- ✅ Publish the officer's title and contact on your site
- ✅ Give them authority over privacy decisions
- ✅ Document access-request and breach workflows
- ✅ Review the delegation when staff change
FAQ
Does a small business need a data protection officer under Law 25?
Yes — Law 25 requires every business to have a person in charge of protecting personal information. By default it is the highest-authority person, but the role can be delegated in writing to staff or an external provider.
Can I outsource the Law 25 privacy officer role?
You can delegate the function and lean on external help for the workflows, but accountability stays with your business. Many small firms name an internal owner and use an IT/compliance partner for the technical processes.
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