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TalentInitiator

Quebec’s Law 25 in hiring

Quebec’s private-sector privacy act, as amended by Law 25, and the Charter of the French Language shape how an employer may screen people who live or work in Quebec. Here is how TalentInitiator applies them.

This page was written in French first, then translated. Read it in French

How to read this page

This page explains how TalentInitiator applies these rules. It is not legal advice for your organization. Our team checks every source again by November 30, 2026, and sources marked “Pending legal review” have not been confirmed by counsel yet.

Decisions made by people

What the rule asks

A business that makes a decision based exclusively on automated processing of personal information must tell the person, and on request explain the information and the reasons used and let a person review the decision.

What TalentInitiator does

No decision in TalentInitiator is based only on automated processing. Advancing, holding or rejecting a candidate takes a person, a reason code and a written reason, and the system refuses a decision that only points to the AI recommendation. Section 12.1 is therefore not triggered, by design. The notice it would require exists as a template, held in reserve in case a customer ever enables an automated step, which the product does not allow.

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Explanations on request

What the rule asks

The law asks for explanations only when a decision is fully automated. The Commission d’accès à l’information still expects employers to tell candidates what they collect during recruitment, and why.

What TalentInitiator does

Every candidate can open “Why this decision” in their portal: the factors, the information used and how to correct it. A “Request a review by a person” button sends the request to the employer’s administrators. We offer both to every candidate, in every province.

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Before information leaves Quebec

What the rule asks

Before communicating personal information outside Quebec, a business must assess the privacy impacts, including how sensitive the information is, the purpose, the protection measures and the legal framework where it goes, and set the protection out in a written agreement.

What TalentInitiator does

Records and recordings are stored in Canada, and recorded interviews will be transcribed in Canada once that service is connected. Résumés are read as submitted, contact details included, and written answers and transcripts are evaluated, by AI services in the United States; names and contact details are removed before anything is scored. An organization in Quebec mode must complete the transfer-assessment template before the live AI service is turned on for it.

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Privacy impact assessment

What the rule asks

A business must assess the privacy impacts of any project to acquire, develop or overhaul an information system that handles personal information.

What TalentInitiator does

The compliance centre includes a privacy impact assessment template for each deployment and shows a warning until the customer completes it.

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Profiling off by default

What the rule asks

Functions that identify, locate or profile a person must be turned off by default, and people must be told about them. Products and services must offer the highest level of confidentiality by default.

What TalentInitiator does

In Quebec mode, three functions are off by default: reusing a profile for other jobs, authenticity signals that compare applicants with one another, and matching against a talent pool. An administrator can turn one on only after reading a notice that explains it. Scoring an application for the job it was sent to is the purpose of the application, and the notice candidates read before applying says so.

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French first

What the rule asks

Job offers for work in Quebec must be published in French, at the same time as any other language version. An employer may require knowledge of another language only when the duties need it, and must first take reasonable means to avoid it.

What TalentInitiator does

Quebec postings publish in French and English together, and publishing one alone is refused. Requiring a language other than French needs a written justification, and the composer warns when the two versions differ on pay, shifts or location. In Quebec mode, notices, consent texts and exports put French first, and the interface opens in French.

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