Does my company need a privacy officer?

The title doesn’t matter much. What the law requires is that a named person is accountable for privacy and that people know how to reach them.

What does PIPEDA require?

Principle 4.1 of PIPEDA’s Schedule 1 says an organization is responsible for personal information under its control and shall designate an individual or individuals accountable for compliance. Their identity must be made known on request. Others in the company can handle day-to-day work, but the accountability sits with the designated person.

How do the rules compare?

Law	Who	Publish?
PIPEDA	One or more designated individuals	Identity available on request; contact details usually go in the privacy policy
Quebec private sector law	The person with the highest authority, by default; the Act lets them delegate the role in writing, in whole or in part, to any person	Title and contact information on your website
PHIPA (Ontario health custodians)	A contact person	Yes, in a written public statement. See privacy for wellness clinics
GDPR	A data protection officer only in some cases	Contact details, if required

Who should it be at a startup?

Usually a founder or the COO at first, with outside help as needed. In Quebec the CEO holds the role unless it’s delegated in writing, so if a founder is the CEO and someone else does the work, document the delegation. The Commission d’accès à l’information recommends choosing someone with the right skills and real decision-making authority, and notes that the person with the highest authority remains accountable for compliance even after delegating.

What does the role involve?

• Keeping a map of personal information, vendors and transfers.
• Owning the privacy policy and making sure it matches the product.
• Answering access requests and complaints on time.
• Running the breach response and the breach record. See when to report a privacy breach.
• Reviewing new features and vendors, including AI tools, before launch. Quebec requires a privacy impact assessment for some projects.
• Training the team, and answering customer security and privacy questionnaires.

What should I publish?

A privacy contact in your privacy policy: a role-based email such as privacy@ rather than a personal address, so it survives staff changes. For Quebec, also publish the title of the person in charge.

What to do next

We prepare privacy policies that name your privacy contact and describe your practices, at fixed fees on our fees page. See also what PIPEDA requires and Quebec’s Law 25 for SaaS.

This guide is general information about Ontario and Canadian law, not legal advice for your situation. To set up your privacy role, book a free 15-minute consult.