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White paper Law 25 Privacy Officer SMEs & municipalities

Synéra rather than a lawyer ? Here's why — and how we cover 100 % of your needs.

Law 25 compliance cannot be improvised, but it does not begin in a law firm either. What you gain by entrusting your process to a specialised technology firm, backed by expert partners.

By Michel Monette, Privacy Officer — Synéra May 4, 2026 · 6 min read

Law 25 compliance is rarely an isolated legal problem. It is first and foremost a project of systems, processes and data governance — one that calls for technological expertise above all. A specialised firm, backed by legal partners, covers what a law firm alone cannot.

1What Law 25 truly requires of your organisation

Since the progressive coming into force of the provisions of Law 25 between September 2022 and September 2024, any organisation that collects, uses, communicates or stores personal information in Quebec is subject to substantial obligations: a designated Privacy Officer (s. 3.1), an incident register, a Privacy Impact Assessment (PIA) before any new project, notification to the CAI, and strengthened individual rights (access, rectification, portability). SME, municipality, non-profit or large enterprise: no one is exempt.

But Law 25 compliance is not only a matter of law. It is first and foremost a matter of processes, systems and data governance. And this is precisely where organisations face a strategic choice: call a lawyer, or turn to a firm specialised in technology compliance?

"Compliance is an organisation-wide project, not merely a legal exercise. It touches your systems, your processes, your employees and your suppliers." — Michel Monette, Privacy Officer — Synéra

2What Synéra does — and what we do not do

Synéra comes from the technology world. We understand information systems, data flows, how software works, cloud architectures and security risks. That is our core business.

But we are not lawyers. And we say so plainly.

✓ What Synéra does

Mapping of processing activities, Privacy Impact Assessments (PIAs), implementation of security measures, compliant registers, data governance, team training, incident response, Privacy Officer on demand.

⚖ What a lawyer does

Legal opinions, drafting and review of contracts, legal interpretation, representation before the CAI, review of confidentiality clauses and processing agreements.

These two areas of expertise are complementary. An organisation that relies solely on a law firm will obtain an analysis of the legislative text, but not necessarily an inventory of its information systems. Conversely, a technology firm with no legal grounding cannot interpret the law or defend your organisation before a tribunal.

The Synéra difference

Synéra partners with law firms — including RB Avocats — to cover 100% of your compliance needs. You benefit from leading-edge technological expertise and rigorous legal support, coordinated by a single team and a single primary point of contact.

3Our approach with Conformaze: mapping, registers and active compliance

To carry your Law 25 compliance project through to completion, Synéra uses Conformaze, a specialised SaaS platform that allows us to establish and document your Law 25 compliance posture. This tool lets us structure your entire process within a centralised, auditable environment aligned with the recommendations of the Commission d'accès à l'information (CAI).

What Conformaze makes possible in concrete terms

Why a dedicated platform makes all the difference

Without a structured tool, compliance remains a one-off exercise on paper. With Conformaze, it becomes a continuous, documented and defensible process. In the event of an incident or a CAI investigation, you have complete traceability and proof of due diligence — which can make all the difference to the nature of the penalties.

4The eight steps to compliance

Law 25 compliance is not a state you reach overnight. It is a structured project, with clearly defined phases. Here is how Synéra supports you, from end to end.

1
Governance and designation of the responsible person

Official designation of the Privacy Officer, establishment of the governance structure and publication of the Privacy Officer's identity on your website.

2
Data inventory and mapping

Identification of all processing activities, the systems involved, the categories of personal information and internal and external data flows.

3
Risk and gap analysis

Assessment of your current level of compliance against the requirements of Law 25 and identification of the priority gaps to close.

4
Update of policies and legal documents

Drafting or review of the privacy policy, information notices and consent forms — in collaboration with our legal partners.

5
Privacy Impact Assessment (PIA)

Conducting PIAs for projects involving sensitive personal information or new technologies, with documentation in Conformaze.

6
Security measures and incident management

Implementation of appropriate security measures, creation of the confidentiality incident register and establishment of a documented response protocol.

7
Employee training

Awareness and training of your teams on Law 25 obligations, data protection best practices and internal procedures.

8
Ongoing monitoring and maintenance of compliance

Active monitoring of your level of compliance, updating of registers as organisational changes occur, and regulatory watch.

5A Privacy Officer on demand for your organisation

Law 25 requires every organisation to designate a person responsible for the protection of personal information (s. 3.1). For many SMEs, non-profits and municipalities, maintaining this expertise in-house on a full-time basis is not realistic from a budgetary standpoint.

That is why Synéra offers a Privacy Officer on demand service: an expert resource, available according to your needs, who assumes the legal responsibilities of the role while integrating into your organisation.

Privacy Officer on demand — the expertise without the full-time hire

During your compliance project and well beyond, Synéra acts as the official Privacy Officer for your organisation: management of access requests, oversight of incidents, regulatory monitoring, liaison with the CAI and ongoing training. Three plans available: Essential ($750/month), Structured ($1,500/month), 360 ($3,000/month).

See the Privacy Officer plans →

To go further: our analysis "Why the Privacy Officer role is becoming essential for Quebec SMEs".

6A complete ecosystem: legal partners, MSSP, training

Law 25 compliance touches several dimensions: legal, technological, human and operational. Synéra has built an ecosystem of specialised partners to cover all of these dimensions — without compromise and without fragmenting the coordination of the project.

Partner law firms

For legal opinions, contract review, confidentiality clauses, processing agreements and representation before the CAI. The law is their business — RB Avocats is one of our key partners.

Training experts

Employee training on Law 25 obligations, data protection best practices and internal procedures. A well-informed team is your first line of defence.

MSSP — cyber defence

Partners specialised in managed cybersecurity (Managed Security Service Providers) for threat monitoring, incident response and active protection of technology environments.

Protection of IT environments

Hardening of infrastructure security, access management, encryption, backup and business continuity — so that your data stays where it belongs.

Centralised coordination for your peace of mind

Rather than managing a multitude of unconnected vendors yourself, Synéra acts as the central coordination point for your compliance process. You have a single primary point of contact — and behind that person, a network of experts working in concert.

7Conclusion: complete compliance, without improvisation

Entrusting your Law 25 process to Synéra does not mean replacing your lawyer. It means giving yourself access to a team that understands your systems, structures your project, integrates the right tools and coordinates the necessary areas of expertise — including the legal component — so that nothing falls through the cracks.

Law 25 penalises organisations that have not taken adequate measures. Fines can reach $25M or 4% of worldwide turnover for the most serious breaches (s. 93). The risk of doing nothing — or of doing things by halves — is very real.

With Synéra, you benefit from an integrated, documented and defensible approach. No improvisation. No gap between the technological and the legal. Complete compliance, right from the start.

Start your Law 25 process — Synéra

Let's talk about your organisation

Contact our team for a free initial assessment of your current level of compliance and a prioritised action plan tailored to your size and your sector.

Request a free assessment See the Privacy Officer on demand

To go further

Synéra plans mentioned in this article

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This article is written for general information and positioning purposes. It does not constitute legal advice. For any question relating to your specific situation, contact Synéra or your legal counsel.

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