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Call recording consent under Quebec's Law 25
Quebec's Law 25 requires consent that is explicit, free and informed, given for each specific purpose. Here is what that means for a phone line that records.
August 19, 2026
Under Quebec's Law 25, consent to record a call must be explicit, free, informed, given for a specific purpose, and requested separately for each purpose. A recorded greeting that says "this call may be recorded" satisfies the announcement, but it is not automatically valid consent.
That gap — between announcing and obtaining — is where most phone systems sit, and it is worth understanding before you configure one.
What the law actually asks
Law 25 amended Quebec's private-sector privacy act, and the consent provisions took effect in stages from September 2022. The Commission d'accès à l'information is the regulator.
Consent has to meet several conditions at once. It must be:
- manifest — an actual, positive indication, not an absence of objection
- free — not bundled with something the person cannot decline
- informed — the person knows what is collected, by whom, and for how long
- specific — tied to a named purpose
- granular — requested separately for each purpose, not as one block
The last two matter most for a phone line, because "quality assurance" and "training" and "dispute evidence" are three purposes, not one. Consent obtained for the first does not carry the other two.
Where a recording announcement fits
An announcement is a disclosure, not a consent mechanism. It tells the caller what is happening. Whether staying on the line then constitutes consent depends on the situation:
| Situation | Announcement alone |
|---|---|
| Inbound call, caller chose to phone you | Often defensible — the caller can hang up |
| Outbound call you initiated | Weaker — the person did not choose the channel |
| Recording used for a new purpose later | Not sufficient. New purpose, new consent |
| Sensitive information discussed | Weaker. Higher expectations attach |
The practical reading is that an announcement plus a genuine option to continue or hang up covers ordinary inbound service calls, and does not cover repurposing a recording months later.
What this means when you configure a phone system
Three things are worth deciding before anyone answers a call.
Decide the purpose, then write it down. "This call may be recorded" names no purpose. "This call is recorded so we can check the quality of our service" names one. The second is what the law is asking for, and it is barely longer.
Decide who can play the recording back. Consent is bounded by purpose, and the purpose was not "anyone in the company can listen at any time". Permission to replay is part of the consent question, not separate from it.
Decide what happens to the recording. Retention is a purpose limitation too. A recording kept indefinitely has outlived any quality-assurance purpose it was collected under.
Where Ringfully is, honestly
Ringfully stores a per-organisation recording announcement and lets you edit it. It does not yet play it on the call — the stored text reaches no part of the call flow. That is a real gap and it is stated on our recording policy page rather than left for you to discover. When it does play, what it should say has to satisfy Law 25 and the Charter at once.
We also do not decide your purpose for you, and no phone system can. Recording is off by default, and an organisation that has not configured it does not record.
This is a description of what the statute asks, not legal advice. Law 25 obligations depend on what you collect and why, and a Quebec-qualified adviser is the right person to confirm your position. If you want the mechanics of how a call is actually put together before recording enters the picture, how it works walks the path a call takes.