Bill 25 in Co-ownership: Access and Correction Requests

Updated as of 2026-07-30. Bill 25 applies to divided co-ownership syndicates in Quebec. It governs the collection, use and disclosure of personal information belonging to co-owners, tenants and employees. In practice, your board of directors must know how to handle a request for access to or correction of information without disclosing information about third parties or unduly delaying its response.

This article guides you step by step through managing these requests, from the first email received to sending a reasoned response. We also connect these requirements with the Civil Code of Quebec (C.C.Q.) obligations concerning access to co-ownership documents (AGM minutes, register, declaration of co-ownership), to avoid common confusion. The goal: protect individual rights, comply with Bill 25 and reduce risks for your syndicate.

1) Who can request what? Distinguishing between a “condo document” and “personal information”

• Personal information: any information about an identifiable person (e.g., a co-owner’s contact information, complaints concerning that person, camera recordings in which they appear, or the payment status associated with their unit). The Act respecting the protection of personal information in the private sector (as amended by Bill 25) applies. See LégisQuébec (P-39.1).
• Co-ownership documents: for example, the declaration of co-ownership, the by-laws of the immovable, AGM minutes, the maintenance logbook (EUC), certain financial statements and the co-owners’ register. Access to these documents is governed by the C.C.Q. and does not automatically involve disclosing sensitive personal information about third parties.

In plain terms:

• A person may request access to personal information concerning them in the syndicate’s records and request its correction if it is inaccurate, incomplete or ambiguous (see P-39.1, the provisions on access and correction).
• They cannot obtain another person’s personal information (e.g., another co-owner’s outstanding balance), unless there is a clear legal basis. The board of directors must redact third-party information.

Common situations in co-ownerships in Montreal and on the South Shore:

• A co-owner requests copies of correspondence concerning them in a file about noise, animals or short-term rentals (Airbnb).
• A tenant requests access to segments of camera footage in which they appear, on a specific date.
• A former board member requests the correction of references to them in minutes.

2) Receiving and processing an access request: the eight-step method

1. Centralize the request: ask the person to write to the syndicate’s official email address for the “Person Responsible for the Protection of Personal Information” (often the board president, unless delegated by resolution). Keep a request log.
2. Verify identity: request the necessary documents, especially where sensitive information is involved. However, avoid requiring more than the reasonable minimum.
3. Clarify the scope: confirm the period, the systems involved (emails, cameras, intercom, common expense files, maintenance records) and the requested format.
4. Locate the information: contact administrative management and service providers as needed (e.g., the camera company) to extract the data.
5. Assess exceptions: determine whether certain passages must be withheld to protect third parties, confidential security information or material covered by solicitor-client privilege.
6. Redact and document: black out non-disclosable sections. Keep a working copy explaining your redactions.
7. Respond within the deadline: send the reasoned decision and a copy of the information disclosed.
8. Record and improve: update your log and adjust your templates and internal policy.

Deadlines and extensions

– Basic deadline: 30 calendar days to respond to an access request (P-39.1). If you need an extension, notify the person in writing before the deadline expires, give reasons for the extension and indicate the new reasonable deadline.

– No response within the deadline: this may amount to a refusal. The person may then exercise a remedy before the appropriate authorities. This is why a prompt, dated acknowledgment of receipt is important.

Prudent exceptions and redactions

• Protect the confidentiality of third parties mentioned in emails, internal board minutes or investigation reports. Redact names, contact information or details that could identify anyone other than the requester.
• Security: do not disclose information that could compromise the security of the common portions (e.g., precise camera layouts or access codes) where the law permits this.
• Ongoing litigation: if a lawyer or notary is involved and documents are covered by privilege, clearly explain why they cannot be disclosed.

3) Correction requests: correct, track and notify third parties

When a person demonstrates that personal information concerning them is inaccurate, incomplete or ambiguous, they may require it to be corrected. Recommended process:

1. Validate the evidence of inaccuracy: for example, an invoice assigned to the wrong account, an incorrect date in minutes or a comment that confuses two units.
2. Correct at the source: update the main system (register, financial file or ticketing tool) and preserve the history.
3. Notify third parties: if the syndicate disclosed the incorrect information to a supplier, an insurer in connection with a claim or another organization, notify them of the correction where applicable.
4. Confirm in writing: respond within the deadline with a summary of the corrections made and the notifications sent.
5. Annotation in the event of disagreement: if you refuse the requested correction, you must allow the person to add a comment or note to their file and inform them of their remedies.

Good to know: a correction does not require you to amend adopted AGM minutes if the information accurately reflects what was said at the time. However, you can add a note to the requester’s file and, if necessary, record a correction in subsequent minutes if a factual error has been established.

4) Bill 25 governance for a syndicate: roles, policies and logs

• Person Responsible for the Protection of Personal Information: by default, a board member (often the president). The board of directors may delegate this role by resolution and publish the official contact information.
• Privacy policy: clear, accessible and adapted to the co-ownership (e.g., management of cameras, intercoms, electronic keys, AGM forms and rental requests). Display it and apply it.
• Confidentiality incident register: keep a register and assess the “risk of serious injury” in the event of an incident. If the risk is high, you must notify the affected individuals and the appropriate authorities in accordance with P-39.1.
• Privacy impact assessments (PIAs): required in certain situations (e.g., implementing a new video surveillance system or a cloud-based tool hosting co-owners’ information).
• Supplier contracts: include confidentiality and deletion clauses for the end of the mandate. Verify where the data is hosted.
• Training: brief directors and volunteers. A misdirected email can be enough to create an incident.

General framework reminder: corporate documents accessible under the C.C.Q. (the co-ownership register, declaration of co-ownership, by-laws of the immovable, financial statements, budget and contingency fund) are not automatically “personal information” belonging to others that can be disclosed in full. Rely on both regimes: the C.C.Q. for access to co-ownership documents, and P-39.1 for access to and correction of personal information.

5) Practical table: common requests, deadlines and precautions

Tip: publicly announce, in the by-laws of the immovable or on your website, the official email address for Bill 25 requests. This reduces wasted time and the risk of missed deadlines.

6) Common mistakes to avoid

• Confusing “access to syndicate documents” with “access to personal information.” The legal tests are not identical.
• Responding verbally without keeping a record. Always issue an acknowledgment of receipt and a written decision.
• Disclosing too much: sending an entire email thread containing information about unrelated third parties. Redact or extract the relevant content.
• Ignoring identity verification: providing information to an unauthenticated person.
• Forgetting to notify third parties when a significant correction has already been disclosed externally.

Frequently asked questions (FAQ)

Q1. Can a co-owner obtain a list of the outstanding balances for other units?

No. A person may access their own information. Other people’s balances are third-party personal information. Instead, provide aggregated data where appropriate (e.g., total arrears in a financial report), in accordance with the C.C.Q.

Q2. How much does a copy of the information cost?

The Act sometimes allows reasonable reproduction or mailing fees to be charged. Inform the person before incurring the costs. However, avoid creating an unreasonable financial barrier.

Q3. What should we do if the request concerns footage showing several people?

Extract the segments in which the requester appears and redact the other faces. If this is not technically feasible, offer an on-site consultation under supervision, while respecting the security of the common portions.

Useful resources

• Consolidated text of the Act respecting the protection of personal information in the private sector (P-39.1), as amended by Bill 25: LégisQuébec.
• General provisions of the Civil Code of Quebec, including the section on divided co-ownership: LégisQuébec.
• Best practices and information for syndicates and co-owners: RGCQ.
• Sector-specific references on the protection of personal information in real estate: OACIQ.

To learn more about internal organization and delegating tasks related to access requests, see our administrative management and operations management services. You can also consult our blog for practical guides intended for boards of directors.

This article provides general information and does not constitute legal advice. Consult a lawyer or notary for advice about your situation.

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