# Dash Cams, Driver-Facing Cameras and Quebec Law 25: What Fleets Must Do

Driver-facing cameras and Quebec Law 25: a fleet must justify the camera, tell drivers, limit who sees footage and how long it is kept. With a checklist.

Source: https://www.highpointgps.com/resources/driver-facing-cameras-quebec-law-25
By Max Karnaukh, VP of Sales, published 2026-10-14, updated 2026-10-14

## Does Quebec Law 25 Apply to Dash Cams and Driver-Facing Cameras?

Yes. Quebec's privacy regulator, the Commission d'accès à l'information (CAI), treats the image of an identifiable person as personal information, so a Quebec business that records its drivers with dash cams, and above all with a driver-facing camera, must follow the Act respecting the protection of personal information in the private sector as updated by Law 25. In practice, the fleet has to decide why it records, collect only what it needs, tell drivers, limit who sees the footage and destroy it when it is no longer needed.

Law 25's changes came into force in stages, from September 22, 2022 to September 22, 2024. This guide covers businesses under Quebec jurisdiction. An interprovincial or international transportation company is federally regulated, and the federal law (PIPEDA) then applies to its employees' personal information. This page is general information, not legal advice, and it cannot make a camera program compliant on its own. Have your policy reviewed by a lawyer.

## When Is a Driver-Facing Camera Necessary Under Law 25?

The law requires a business to decide the purposes of a collection before collecting anything (section 4) and to collect only the information necessary for those purposes (section 5). The CAI applies a specific test: a collection is necessary if the objective is legitimate, important, urgent and real, and if the intrusion on privacy is proportional to it. It adds that mere apprehension, speculation or the fact that other businesses use cameras is generally not enough.

For a fleet, that means documenting the problem with figures from your own files: collisions, disputed claims, complaints, cargo theft. Then ask whether a less intrusive option would do. A road-facing camera records little of the driver, while a cab camera records the driver for the whole shift. Geotab offers both the GO Focus Plus and the GO Focus Pro in Road Only versions with no cabin lens, and the GO Focus Plus has privacy options that include blurring.

## What Did the CAI Order for Cameras in Truck Cabs?

In May 2025, the CAI ruled on dashboard cameras inside the cabs of a company's delivery trucks (Crane Supply). It found the purposes of the collection legitimate, real and important, and found that the benefit of the collection outweighed the harm. The company had not shown, however, that it had minimized the intrusion on privacy enough.

The CAI ordered it to limit recording inside the cabs to a limited number of seconds before and after a defined incident, or else stop recording inside the cabs; to stop recording inside the cab once the engine is off; and to destroy any cab recording beyond the sequence tied to an accident or significant incident. The lesson for fleets: a cab camera can be justified, but its settings must keep the collection to a minimum.

## What Must You Tell Drivers?

Section 8 requires the business to tell each driver, when the information is collected and in clear and simple language, the purposes, the means used, the rights of access and rectification, and the right to withdraw consent. On request, it must also say which people in the business can see the footage, how long it is kept and how to reach the person in charge of the protection of personal information.

Dash cams tied to telematics add one more duty. Section 8.1 covers any technology that can identify, locate or profile a person, and the law defines profiling as assessing a person's characteristics, in particular work performance or behaviour. A camera with GPS and driver scoring fits that description, so the business must first tell the driver that it uses the technology and how those functions are activated. The CAI also recommends posting clearly visible notices of the cameras.

## Do You Need a Privacy Impact Assessment?

Often, yes. Section 3.3 requires a privacy impact assessment for any project to acquire, develop or overhaul an information system involving the collection, use, communication, keeping or destruction of personal information, and a new program of cameras connected to a cloud platform fits that description. The person in charge of the protection of personal information must be consulted from the outset, and the assessment must be proportionate to the sensitivity of the information.

Two points deserve attention. If the video is hosted or processed outside Quebec, section 17 requires an assessment before that communication and a written agreement with the provider, so ask your provider where the footage is stored. And if a feature verifies a driver's identity from their face, Quebec's Act to establish a legal framework for information technology (section 44) requires the driver's express consent and prior disclosure to the CAI.

## How Long Can You Keep Footage, and Who Can See It?

Section 23 requires a business to destroy information once its purposes are achieved, or to anonymize it under the prescribed rules. The law sets no specific period for dash cam video. In its fact sheet on video surveillance, currently under revision, the CAI says that keeping images for 30 days is generally sufficient and recommended. Platforms have their own defaults: Geotab keeps event video for 365 days by default, so set your period in your policy and adjust the platform to match. Video used to make a decision about a driver must be kept for at least one year after that decision (section 11).

Only employees who need the footage for their duties may access it (section 20). A driver can ask to see footage about them, and the person in charge must reply in writing within 30 days of receiving the request (section 32). Unauthorized access to or loss of footage is a confidentiality incident: it goes in a register and, if it presents a risk of serious injury, must be reported to the CAI and to the people concerned. The administrative penalty for a business can reach $10,000,000 or 2% of worldwide turnover.

## Law 25 Checklist for Fleet Dash Cams

This checklist sums up the steps above. Use it to prepare the conversation with your lawyer; it does not replace legal advice.

| Step | What to do | Source |
| --- | --- | --- |
| 1. Person in charge | Confirm who is in charge of the protection of personal information and publish their title and contact details on your website | Section 3.1 |
| 2. Purpose and necessity | Write down why you record, with figures, and why a less intrusive option is not enough | Sections 4 and 5; CAI fact sheet |
| 3. Privacy impact assessment | Complete it before rolling out cameras, and check where the video is hosted | Sections 3.3 and 17 |
| 4. Settings | Choose Road Only or a cab camera, record the cab only around events, and nothing after the engine is off | CAI decision, May 2025 |
| 5. Notice to drivers | Tell drivers in writing the purposes, means, rights, location and profiling functions; post notices of the cameras | Sections 8 and 8.1 |
| 6. Policy | Adopt a camera policy covering access, permitted uses, retention and complaints | Section 3.2; CAI fact sheet |
| 7. Retention | Set a period, configure the platform to match and destroy footage once its purpose is achieved | Sections 11 and 23 |
| 8. Access and incidents | Limit access, answer requests within 30 days and keep an incident register | Sections 3.5, 3.8, 20 and 32 |

## Setting Up Dash Cams With High Point GPS

Settings do much of the work. The GO Focus Plus dual dash cam and the GO Focus Pro truck camera system both come in Road Only versions. On the GO Focus Plus you can also turn on blurring and choose what each event records: snapshot and video, snapshot only, video only or nothing. For the general rules on windshield mounting and in-cab audio, read our guide Are Dash Cams Legal in Canada and the US? Laws by State.

High Point GPS is a Montreal fleet telematics company and Geotab partner, founded in 2013 and serving over 500 fleets in Canada and the United States, in English and French. We install AI dash cams with professional installers and configure the settings with you to match the policy your lawyer has reviewed. We do not give legal advice. Use the free quote form on this page to tell us about your fleet.

## FAQ

### Can a business record its drivers in Quebec?

Yes, if it can show the collection is necessary: a legitimate, important, urgent and real objective, and an intrusion on privacy that is proportional and kept to a minimum. In 2025, the CAI accepted cameras in delivery truck cabs but required the company to limit cab recording to a few seconds around an incident and to stop recording once the engine is off.

### Do drivers have to consent to a dash cam in Quebec?

The law mainly requires informing drivers when the information is collected: the purposes, the means, their access and rectification rights, and any location or profiling functions. Express consent is required in some cases, for example when a feature verifies a driver's identity from their face. Have your approach reviewed by a lawyer before you roll cameras out.

### How long should a fleet keep dash cam footage in Quebec?

The law sets no fixed period: footage must be destroyed once its purpose is achieved. The CAI recommends 30 days for video surveillance in general. Footage used for a decision about a driver must be kept for at least one year after that decision. Set the retention period in your policy and configure your camera platform to match it.

### Does a road-facing camera avoid Law 25?

No, but it greatly reduces the intrusion on drivers' privacy. Road footage can still show identifiable people, and the GPS tied to the camera locates the driver, so you still need a clear notice and a policy. A Road Only camera is often the least intrusive option when you do not need to see inside the cab.

## Sources

- [Légis Québec, Act respecting the protection of personal information in the private sector (P-39.1)](https://www.legisquebec.gouv.qc.ca/en/document/cs/P-39.1)
- [Légis Québec, Act to establish a legal framework for information technology (C-1.1)](https://www.legisquebec.gouv.qc.ca/en/document/cs/C-1.1)
- [CAI, La vidéosurveillance: practical advice (PDF, in French)](https://www.cai.gouv.qc.ca/uploads/pdfs/CAI_FIC_Videosurv.pdf)
- [CAI, Commission decision on video surveillance (May 2025, in French)](https://www.cai.gouv.qc.ca/actualites/decision-de-la-commission-en-matiere-de-videosurveillance)
- [CAI, Main changes made by Law 25 (in French)](https://www.cai.gouv.qc.ca/protection-renseignements-personnels/sujets-et-domaines-dinteret/principaux-changements-loi-25)
- [CAI, Vers la conformité à la Loi sur le privé (PDF, in French)](https://www.cai.gouv.qc.ca/uploads/pdfs/CAI_GU_Responsabilites_Entreprises.pdf)
- [CAI, Privacy impact assessment guide (PDF, in French)](https://www.cai.gouv.qc.ca/uploads/pdfs/CAI_GU_EFVP.pdf)
- [CAI, Biometrics (in French)](https://www.cai.gouv.qc.ca/protection-renseignements-personnels/sujets-et-domaines-dinteret/biometrie)
- [Québec.ca, Law 25 provisions in force (in French)](https://www.quebec.ca/nouvelles/actualites/details/entree-en-vigueur-des-nouvelles-dispositions-de-la-loi-25-50723)
- [Office of the Privacy Commissioner of Canada, PIPEDA requirements in brief](https://www.priv.gc.ca/en/privacy-topics/privacy-laws-in-canada/the-personal-information-protection-and-electronic-documents-act-pipeda/pipeda_brief/)
- [Geotab, GO Focus Plus](https://www.geotab.com/products/go-focus-plus/)
- [Geotab, GO Focus Pro](https://www.geotab.com/products/go-focus-pro/)