Law 25 Employee Training: The Awareness Obligation
Make sure your employees know their obligations regarding the protection of personal information.
The essentials
The law has no section titled "training", but section 3.2 of Act P-39.1 requires your governance policies to define the roles and responsibilities of your staff with respect to personal information. Employees who do not know these rules cannot apply them: awareness is the concrete means of meeting this obligation.
A large share of confidentiality incidents comes from human error: an email to the wrong recipient, the wrong attachment, a weak password, a document left accessible.
For a small business: short training at hiring, an annual refresher, and a written record (signed acknowledgment) that demonstrates your diligence.
What the law says
Law 25 requires employees who have access to personal information to know their obligations. Note: the law does not prescribe a formal training program or a specific frequency. What matters is that your employees are informed.
Employees must understand:
- What personal information is
- Their legal and internal confidentiality obligations
- The company's procedures (governance policy, incident management, consent, etc.)
- The possible internal sanctions for non-compliance
The goal is to ensure that every staff member handles data in a secure and compliant way.
For a small business
Good news: for a small business, no elaborate training program is needed! The essentials are:
- A brief team meeting to explain the obligations (15-30 min)
- The Confidentiality Agreement signed at hiring
- A reminder after major changes or after an incident
What matters is having proof that the employee was informed. That is why the signed Confidentiality Agreement is so important.
Good to know
In the event of an incident caused by an employee, the company's liability could be aggravated if it cannot prove the employee had been trained. The signed acknowledgment is your protection.
Concrete examples
Example 1: A clothing store holds a 30-minute meeting where the manager explains to employees what personal information is, the procedures in the event of an incident, and best practices for securing customer data.
Employees then sign an acknowledgment to confirm they have been informed.
Example 2: A professional services firm sends out a PDF document every year summarizing each employee's data protection obligations.
Each employee must reply to the email confirming they have read and understood the document. The confirmations are archived in an HR folder.
What to cover in the training
The essentials come down to five points: what personal information is, the internal rules of your governance policy (access, retention, destruction), how to recognize an incident and report it immediately, what to do if a client makes an access request, and who the privacy officer to contact is when in doubt.
The written record matters as much as the training itself: an acknowledgment signed by each employee, kept on file, is the proof that your business did its part if an incident happens anyway.
A small business's minimal awareness program
| When | Action | Record to keep |
|---|---|---|
| At hiring | Basic training and reading of the governance policy | Signed acknowledgment in the employee's file |
| Every year | Short refresher: incidents, access requests, good reflexes | Dated attendance list |
| At every change | Targeted update: new tool, new type of collection | Information email kept on file |
| Ongoing | Visible quick-reference sheet: who the privacy officer is, what to do when in doubt | Document accessible to the team |
Mistakes to avoid
- Not informing employees of their obligations at all
- Not keeping proof that the information was delivered (signature)
- Simply emailing a document with no confirmation of reading
- Forgetting to inform new employees
Step-by-step instructions
Checklist: Step 9 complete?
- I have identified which employees have access to personal information
- My employees know their confidentiality obligations
- Each employee has signed a Confidentiality Agreement
- The signed copies are kept on file
- New employees are informed as soon as they are hired
Templates included in the Law 25 Kit
- Confidentiality Agreement for the Protection of Personal Information template
Frequently asked questions
Is employee training a legal obligation?
Not as a dedicated section of the law. It flows from section 3.2: your policies must define staff roles and responsibilities, and you must be able to demonstrate they are applied. Training and a signed acknowledgment are the concrete proof.
How often should the team be trained?
At hiring for each new employee, then an annual refresher. Add a one-off update whenever your practices change: a new tool, a new type of data collected.
What form should the training take?
The law imposes no format. For a small business, a 30 to 60 minute presentation, a one-page quick-reference sheet and a signed acknowledgment are more than enough. What matters is consistency, not volume.
Official sources
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