Bill 25: Adopt a Concrete Action Plan That Goes Beyond Your Policies

Published on May 16, 2025

In order to comply with current legislation, your organization must have a mapping system, which is the basis for protecting personal information.

Indeed, mapping processing activities is essential, even for organizations that already have privacy, confidentiality, and security policies in place.

It applies to all organizations that need to demonstrate compliance with Canadian provincial and federal laws, as well as European and U.S. regulations.

A robust data mapping tool will enable your organization to understand, document, and manage the facts underpinning its legal obligations. Without mapping, legal analysis relies on assumptions, and compliance becomes illusory.

Summary

Comply with Bill 25 and other legislation
Meet your partners’ requirements
Carry out mapping and gap analysis
Put vision into action
Realize that policies are no substitute for mapping
Use mapping as the foundation of information security
Understand the economic consequences of a lack of mapping
Turn to your strategic partner for defensible mapping

Not just for Act 25

Numerous laws govern the protection of personal information. In Québec, Act 25 recently came into force, but several other laws can apply to your organization.

Mapping is the first step in meeting your transparency and accountability obligations. It is a prerequisite for carrying out a Privacy Impact Assessment (PIA). The General Data Protection Regulation (GDPR) requires, in certain circumstances, a register of processing activities, the foundation of the principle of accountability, and a prerequisite for any impact assessment.

However, mapping processing activities is not just an exclusive obligation of the RGPD or Act 25. It is also justified under other laws. Here are just a few of them.

Personal Information Protection and Electronic Documents Act (PIPEDA)

This Canadian federal law imposes the principle of accountability, transparency, and right of access. Without mapping, an organization cannot demonstrate how it collects, uses, shares, secures, and communicates personal information.

Alberta and British Columbia Privacy Acts

Alberta’s Personal Information Protection Act (PIPA) and British Columbia’s Personal Information Protection Act (PIPA-BC) impose obligations of reasonableness and accountability. The organization must document the purposes, means, and safeguards associated with each processing activity. Mapping is necessary to meet this obligation of effective transparency.

Health Information Protection Acts in Ontario and Québec

In Ontario and Québec, health information protection laws impose strict requirements for retention, access, security, and consent. Health information custodians must map their processes to comply with rules applicable to medical records, cross-border flows, and information provided to patients.

In short, in all provinces, public sector access to information and privacy legislation imposes similar documentation, minimization, and security obligations.

Protection of sensitive data, a requirement of your partners

Any organization handling sensitive data (health, justice, children) must carry out a complete mapping of its processing activities to comply with the requirements of diligence, consent, and retention. Without mapping, an organization risks not being able to meet its obligation of effective transparency.

But make no mistake. This obligation is not only imposed by regulatory control authorities (such as the Commission d’accès à l’information or the Office of the Privacy Commissioner of Canada).

These obligations may also be contractually required by the organizations with whom you do business, who insure your business risks, who lend you money, and who may eventually become the buyer of your business.

Mapping and Gap Analysis

Gap analysis involves measuring the gaps between your organization’s current data processing practices and legal and organizational requirements. Such an analysis cannot be carried out without a precise inventory of processing activities.

Without mapping:

With mapping:

From vision to action plan: mapping and remediation plan

The remediation plan organizes and prioritizes actions to identify vulnerabilities and limit risks.

It is based on the results of the gap analysis. Mapping enables this plan to be structured according to an operational logic:

Mapping transforms an abstract vision into a concrete, measurable, and legally defensible action plan.

Why can’t policies replace the mapping of your processing activities

Policies define intentions. Mapping documents facts and your reality.

A well-written policy with no underlying mapping is no proof of effective data processing compliance. Without mapping, policies risk being deemed inapplicable, decorative, or even misleading.

Mapping is the only way to link formal commitments to concrete operations. It is the only reliable means of auditing, verifying, and demonstrating actual compliance. In the event of an investigation or incident, the absence of mapping is often perceived as an aggravating factor.

Mapping isn’t just a compliance tool: it’s your first line of defense against data loss, cyber-attacks, and privacy-related litigation. By a ccurately identifying the data you process, its location, sensitivity, and who has access to it, you can deploy targeted, proportionate and cost-effective security measures.It’s intelligent, knowledge-based protection. Without mapping, you risk spending a lot to protect poorly or protecting nothing at all… until the incident.

Mapping as the foundation of information security

You can’t protect what you don’t know.

Mapping is foundational to any data security posture because it enables you to:

This approach aligns with the Data Security Posture Management (DSPM) model:

The economic consequences of a lack of mapping

Security incidents are frequent and expensive. Without data visibility through mapping, organizations apply misaligned and ineffective security controls.

Mapping helps to reduce the attack surface, limit the data to be protected, and therefore reduce risks and associated costs.

Mapping processing activities is not an optional step: it is the foundation of any credible legal compliance, serious information governance, and sustainable security strategy

Mapping processing activities is much more than a bureaucratic exercise. It is:

It transforms abstract principles into concrete, measurable, and prioritized actions.

Your strategic partner for defensible mapping

That’s why we make it the starting point for every compliance privacy program. Only an approach based on evidence, rigor, and interdisciplinarity can build sustainable, strategic compliance.

Our team operates at the intersection of law and cybersecurity. Our methodology enables you to map data processing rigorously, produce defensible risk analyses and transform this knowledge into a legal, operational and strategic action plan.

As a manager, you’ll have the tools to manage data, protect rights and meet regulatory requirements with efficiency and credibility.