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AI HR assistants and Quebec Law 25: protecting candidate experience and employees

A deployment checklist for Quebec: HR documents, personal information, privacy impact assessments, vendors and human review.

An AI HR assistant can make company policies easier to find. When it processes employee or candidate personal information, privacy must be part of deployment. Law 25 is not a software certification: obligations depend on the use, data and vendors. These checks distinguish informative answers from recruitment decisions.

Start with documents and defined purposes

Separate general policies and the employee handbook from individual payroll, health, disciplinary and application records. Section 5 of Quebec’s private-sector privacy act limits collection to information necessary for purposes determined before collection. Explaining vacation rules does not necessarily require an employee’s personal leave balance. Document the required data, authorized users, purposes and applicable legal basis for each use. Do not assume general consent covers every analysis or model-training activity. Start with general policies rather than personal files.

Assess privacy and your vendors

Section 3.3 requires a privacy impact assessment for projects acquiring, developing or redesigning an information system or electronic service involving personal information. Consult the person in charge of privacy from the start. The assessment must be proportionate to the sensitivity, purposes, quantity and medium of the information. Section 17 addresses transfers outside Quebec: assess the legal framework and safeguards, and establish a written agreement reflecting the assessment. Hosting in Canada alone does not prove all processing stays in Quebec. Check AI generation providers, logs, backups and subcontractors as well.

Explain the limits and keep human review available

Answering a policy question is different from automatically rejecting a candidate. Section 12.1 concerns decisions based exclusively on automated processing of personal information. The person must be informed of this by the time they are informed of the decision. On request, they can obtain the information used and the reasons, main factors and parameters leading to the decision. They must also be able to submit observations to a staff member able to review it. An informative assistant should set clear limits: no legal advice, no hiring decisions and referral of sensitive matters to a person. Explain what is recorded and who can access it.

Plan a controlled pilot with Talia

Check five items before a pilot: validated current policies; access limited to necessary data; documented data flows and vendor agreements; retention and deletion rules; a clear human contact. Section 23 provides for destruction or anonymization once purposes are fulfilled, subject to legally required retention periods. Talia, Talentfeel’s product, answers from your HR documents, cites sources and routes sensitive topics to a person. Candidate experience is coming soon. The demo uses fictional company ABC inc., so you can test answers without uploading employee data. The 30-day free trial applies to Essential. Validate privacy and integration terms for your project. This guide is information, not legal advice. Consult your privacy officer and a legal adviser as needed.

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→ LégisQuébec — protection des renseignements personnels, articles 3.3, 5, 12.1, 17 et 23