Many organizations have adopted a privacy policy, updated their consent forms, and designated a person responsible for personal information protection. But they have overlooked a central piece of the puzzle: training the employees who handle that information every day.
Training is not optional. It is an obligation that flows directly from Law 25.
The Legal Basis: Article 3.2
Article 3.2 of the Act respecting the protection of personal information in the private sector (P-39.1) requires organizations to establish and publish governance rules. These rules must include training and awareness measures for staff who handle personal information.
In other words, having rules without training people to apply them does not meet the intent of the law. The Commission d'accès à l'information (CAI) expects organizations to be able to demonstrate that their employees understand their obligations.
What Training Should Cover
Effective training is not a group reading of a privacy policy. It must be tailored to the organization's context and address, at a minimum:
The basics of the law: what personal information is, why it is protected, and what rights individuals have regarding it.
Internal policy: what your organization's rules are for collecting, using, retaining, and communicating personal information. Not the full policy word for word, but the rules that directly affect the employee's role.
Incident reporting: how to recognize a privacy incident (unauthorized access, sending to the wrong recipient, losing a device), who to report it to, and within what timeframe. The 72-hour notification deadline to the CAI applies to the organization, not to the individual employee, but if an employee waits a week before reporting an incident internally, you will never be able to meet your legal deadline.
Information handling in their specific role: an HR employee handles very different records than a sales representative. Training benefits from including concrete examples tied to the specific position.
Frequency
Training should occur:
- At onboarding, for every new employee before they begin handling personal information
- Annually, to keep knowledge current and cover changes in practices or regulations
These frequencies are not prescribed word for word in the law, but they represent the reasonable standard expected by regulatory authorities.
Documentation
Training without documentation is training without proof. In the event of a complaint or a CAI investigation, you will need to demonstrate that training actually took place.
What you should keep:
- The date of each training session
- Topics covered (a course outline or summary is sufficient)
- Names of participants (attendance sheet or digital confirmation)
- Materials used (presentation, handout)
These records can be simple. A spreadsheet in a shared file or an entry in your HR system works. What matters is consistency and traceability.
The Difference Between Awareness and Real Competency
Showing a 10-minute privacy video and then checking "training completed" in an HR system is not sufficient. Awareness creates recognition. Competency develops when employees know how to apply the rules in their context.
The distinction matters. An employee may know that "personal information must be protected" without knowing what to do concretely when they receive an access request, when a laptop containing client data is stolen, or when a customer asks them to delete their information.
The most effective training combines:
- Clear content on obligations
- Examples or scenarios drawn from the organization's real context
- Time for questions
An Investment, Not a Constraint
A trained team will make fewer human errors, which are behind the majority of privacy incidents. An employee who knows how to recognize an incident and report it quickly allows you to meet your legal deadlines. An employee who understands why these rules exist will respect them more than one who simply endures them.
Observantia includes a built-in training module that lets you deliver training to your team, track completions, and automatically generate the attendance records you will need to demonstrate your compliance.
This content is provided for informational purposes only and does not constitute legal advice. For questions specific to your situation, consult a qualified legal professional.