Diagnostic Framework

Mutually Exclusive.
Collectively Exhaustive.

Every Verimont audit applies a rigorous four-vector structure across four vectors of North American data sovereignty. No overlap between categories. No gaps in coverage. The result is a liability map that holds under regulatory scrutiny.

I
Consent

Ingestion & Consent Architecture

The front door. Every commercial website is a data collection machine. The question Law 25 asks is simple: did you ask first? This vector audits the precise sequence of events between a user's first request and the organisation's first data collection action.

Cookie Timing
Do tracking scripts execute before or after documented user consent?
Consent Mechanism
Is consent explicit and opt-in, or implied through continued use?
Payload Identification
Which third-party scripts are present and what data do they collect?
Consent Withdrawal
Can users withdraw consent as easily as they granted it?

Law 25, s.8.1: "Any person who collects personal information must, before doing so, take reasonable steps to inform the person concerned of the purpose for which the information is collected and obtain their consent."

II
Governance

Governance & Personnel Accountability

The paperwork. Regulatory frameworks do not just mandate behaviour — they mandate accountability structures. If your organisation processes personal data and cannot name the person responsible for it, you are already in violation, regardless of how good your consent management is.

Privacy Officer
Is a named DPO/CPO publicly disclosed with a contact route?
Policy Currency
Does the privacy policy reference Law 25 and Bill C-27 explicitly?
Language Compliance
Is the policy available in French for Quebec-located subjects?
Retention Schedules
Are data retention periods defined and published?

PIPEDA, s.4.1: "An organisation is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organisation's compliance."

III
Sovereignty

Sovereign Infrastructure & Cross-Border Transits

The back end. Where data physically lives determines which government can compel its disclosure. Canadian subject data routed through US infrastructure is subject to the US CLOUD Act — a federal law that allows US authorities to demand access to data held by US-domiciled corporations, regardless of where that data resides.

Server Geolocation
In which jurisdiction do the primary servers reside?
CDN Jurisdiction
Does the CDN provider create US-jurisdiction exposure?
PIA Publication
Are cross-border transfer PIAs documented and published?
Transfer Agreements
Are contractual protections in place for cross-border data flows?

Law 25, s.17: "Before communicating personal information outside Québec, a person carrying on an enterprise must conduct a privacy impact assessment and ensure that the information will receive adequate protection."

IV
Rights

Subject Rights & Remediation Mechanics

The exit. Knowing what data you hold is the minimum. Having operational infrastructure to delete it, export it, and respond to requests within mandated timelines is the requirement. Most organisations that pass vectors I–III fail here.

Access Requests
Is there a documented pathway to request access to held data?
Deletion Mechanism
Can subjects request deletion with a documented 30-day response?
Data Portability
Can data be exported in a structured, machine-readable format?
Response Infrastructure
Does the SAR workflow exist in code, not just policy documents?

Law 25, s.28: "A person carrying on an enterprise must, at the request of the person concerned, communicate to the person, in a structured, commonly used technological format, the personal information collected from the person."

Jurisdictions Covered

Quebec Law 25

Bill 64, now in full force. The most demanding provincial privacy legislation in Canada. Applies to any organisation processing personal information of Quebec residents, regardless of where the organisation is based.

PIPEDA / Bill C-27

Federal Canadian privacy law governing commercial organisations. Bill C-27 (CPPA) proposes significant reforms including a statutory tort of privacy violation and fines up to $10M or 3% of global turnover.

US CLOUD Act

Not Canadian law — but profoundly relevant to Canadian data sovereignty. The CLOUD Act allows US federal agencies to compel US-domiciled cloud providers to disclose data stored anywhere in the world.