HR Compliance — Law 25 Employee Data and IT-HR Policies
Internal policies, PPO mandate, remote work, BYOD — coordinated with your IT reality.
HR compliance is an engagement that covers the employee side of Quebec's Law 25 (privacy legislation), internal policies (remote work, BYOD, confidentiality), and the designation of your Privacy Protection Officer (PPO). Factero coordinates our HR partners and our IT team to ensure your policies account for your actual infrastructure — not just abstract legal requirements.
The result: enforceable policies, a documented PPO mandate, a training plan, and Law 25 compliance that doesn't stop at theory.
Who is it for?
SMEs of 10–150 employees whose IT-HR policies haven't kept up with growth.
HR managers or staff appointed as PPO without IT support or structured HR department.
Organizations coming out of a Factero audit with identified HR-IT gaps.
When does it help?
If you recognize yourself in any of these situations, this service is designed for you.
- You need to designate a PPO, document their mandate and set up Law 25 employee data procedures.
- Your HR policies are missing, outdated or incompatible with your actual IT infrastructure.
- You're coming out of a Factero audit with IT-HR policy gaps identified.
What will you receive?
Law 25 HR: approved internal policies, training plan, PPO mandate charter, incident procedures.
HR policies ready to deploy: remote work, BYOD, confidentiality, digital code of conduct, social media.
Consistency verified: policies validated against your actual IT infrastructure.
One coordination point — HR partners and Factero IT team communicate directly.
Professional deliverables ready to adopt — their implementation and adaptation to your specific context are the responsibility of your organization.
Not a good fit?
- If your need is a pay equity exercise or compensation study, the Pay Equity service will be more appropriate.
- If your need is a complete Law 27 mandate, the Law 27 Compliance service will be more appropriate.
How does the process work?
A rigorous and transparent approach, step by step.
Law 25 — HR Component
Law 25 penalties for missing policies or incident procedures can reach $25M or 4% of global revenue — and they apply to employee data as much as client data. Mandate covers internal policies, staff training, PPO mandate charter and CAI notification procedures. Typical duration: 3 to 6 weeks.
Law 27 — Related Service
If your employment contracts or internal communications aren't compliant with the Charter, your organization faces OQLF requests — which cost more to fix under pressure than to anticipate. For a complete Law 27 mandate, see the Law 27 Compliance service.
HR Policy Package
A missing BYOD policy can turn a lost personal device into a Law 25 incident. A vague remote work policy can generate CNESST claims if an employee is injured at home. Typical duration: 3 to 5 weeks for a complete package — a few thousand dollars for policies that limit a potentially far more costly exposure.
IT and HR Coordination
Two separate mandataries means two scoping meetings, two sets of deliverables to reconcile, and an internal coordinator absorbing the gap — a real management cost that doesn't appear in fees. Each policy drafted by our HR partners is validated by the Factero IT team against your actual infrastructure.
Frequently Asked Questions
Answers to the questions our clients ask before reaching out.
Does Law 25 really apply to employee data?
Yes — Law 25 applies to any information about a natural person, including employees. Payroll data, performance reviews, health records, internal communications, and vehicle geolocation data are all covered. PPO designation, management policies, and incident procedures must cover this track just as much as client data. An incident involving employee data — loss of an unencrypted laptop, unauthorized access to a payroll file, email sent to the wrong recipient — triggers the same CAI notification obligations as a client data incident. Factero coordinates compliance between the HR track (policies, training, PPO charter) and the IT track (systems, access, protective measures) to ensure obligations are covered on both sides — with no gray zone between your departments.
What is the difference with the Law 25 Compliance service?
The Law 25 Compliance service covers the entire organization — this service specifically targets the HR component. Law 25 Compliance addresses organization-wide data governance: IT systems, providers, incident register, personal information mapping, gap analysis, third-party inventory. The HR Compliance service targets the employee track: internal policies (remote work, BYOD, confidentiality, digital code of conduct), PPO designation and mandate charter, staff training plan, Law 25 notification procedures for employee data. Both services can run in parallel or sequentially — Factero coordinates deliverables to be consistent without duplication. Many organizations do both together, especially when an audit revealed gaps on both sides. The free 20-minute discovery call determines the right sequencing based on your situation and priorities.
How long does it take to implement HR policies?
The timeline depends on the number of policies to produce and the state of your existing documentation. Here are the typical durations observed by Factero across its HR mandates:
— Single policy (remote work, BYOD, or confidentiality): 1 to 2 weeks.
— Complete package of 5 to 6 policies: 3 to 5 weeks.
— Full Law 25 HR component (policies + PPO mandate charter + training plan): 3 to 6 weeks depending on organization size.
Each policy follows a scoping, drafting, client review, and final delivery cycle. The initial scoping — a 60 to 90-minute meeting — confirms the scope and exact timeline, which is documented in the proposal. If policies already exist, revision is generally faster than drafting from scratch. The free 20-minute discovery call determines the right format before any commitment.
We already have policies. Can we just have them reviewed?
Yes — reviewing existing policies is a common mandate format and often more efficient than writing from scratch. Factero evaluates each policy on three axes: legal validity (Law 25, Law 27, pay equity compliance), consistency with your actual IT infrastructure (BYOD policies that don't account for your Microsoft 365 environment or MDM are unenforceable), and completeness (what's missing, what's outdated, what contradicts other internal policies). The deliverable is a set of revised policies, annotated with changes and justifications, ready to deploy. The review also includes cross-checking between policies — a remote work policy that contradicts the confidentiality policy creates an exploitable gray zone. Typical duration: 2 to 3 weeks for 3 to 5 existing policies to review, versus 3 to 5 weeks for complete drafting.
Who in our organization needs to be involved?
Two contacts are enough: the person wearing the HR hat and the one managing IT systems. On the HR side, it's typically the general manager, administrative director, or designated HR manager — in SMEs, it's often the same person wearing multiple hats. On the IT side, it's the internal IT manager or your external IT provider. Both don't need to be available simultaneously: Factero structures exchanges to minimize internal workload, with targeted 30 to 60-minute meetings rather than lengthy workshops. For the PPO (privacy protection officer) mandate charter, a single scoping meeting is generally sufficient. If your organization has no IT manager, Factero can interact directly with your IT provider — this is a common scenario in SMEs with fewer than 50 employees. Total client-side workload is typically 4 to 8 hours spread over the entire mandate duration.
Are the policies tailored to our sector?
Yes — every policy is written based on your sector, size, and actual IT tools. Factero doesn't deliver generic templates downloaded from the internet. A remote work policy for a 200-employee municipality with a Microsoft 365 environment has nothing in common with one for a 30-person manufacturing SME using an on-premise ERP. The initial scoping identifies Law 25, Law 27, and pay equity obligations applicable to your specific situation — municipal sector, non-profits, professional services, retail, manufacturing. Policies also incorporate your IT infrastructure specifics: MDM type, BYOD policy, collaboration tools, VPN access. For an exhaustive analysis of all sector-specific legal obligations, a specialized labour lawyer will usefully complement the mandate — Factero covers the IT and governance track, not the legal track.
Who is responsible for implementing the delivered policies?
Factero delivers policies written according to best practices and the legal obligations identified during scoping — their adoption and implementation are your organization's responsibility. These are professional deliverables ready to deploy: each policy includes an executive summary, the legal obligations covered (Law 25, Law 27, pay equity as applicable), and implementation instructions. Formal adoption, employee communication, initial training, and ongoing updates over time are your responsibility. Factero can support deployment on request — team presentations, training sessions, periodic reviews — but this support is a separate mandate with its own terms. If you need legal advice on a policy's compliance or defensibility before an administrative tribunal, a specialized labour lawyer will be more appropriate — Factero covers the IT and governance track.
Need to move forward on this?
Let's discuss your specific situation. No commitment, just expert advice.