The information life cycle

Every piece of information goes through five stages. At each one, a compliance question arises.

Stage Question to ask Example
Collection Is it necessary? Is the person informed? Free-trial sign-up form
Use Is it consistent with the announced purposes? Using support emails for marketing: no, without new consent
Disclosure To whom, why, under what contract? Sending data to a transactional email service
Retention For how long? Where? Who has access? 24-month retention rule for logs
Destruction / anonymization When purposes are fulfilled, destroy or anonymize Automatic purge after a customer leaves

Golden rule

When the purposes for which information was collected are fulfilled, the organization must destroy it or anonymize it for serious and legitimate purposes (s. 23 and Anonymization Regulation). Keeping it "just in case" is not a sufficient reason.

Example (school). Records of students who have left are not kept forever: a retention schedule approved by the principal sets what to keep, for how long, and when to destroy.

Outside Québec

Disclosing information outside Québec (e.g. cloud hosting in the United States) requires a prior assessment (PIA): more on this in the role-based modules.