Recording Condo Meetings in Quebec: Bill 25

In a divided co-ownership, several syndicates wonder whether they are permitted to record an annual general meeting or special meeting to facilitate the preparation of the minutes or resolve a dispute. Bill 25, which modernizes Quebec’s rules on the protection of personal information, governs this practice. Here is what you need to know to remain compliant while improving your processes.

Updated as of 2026-06-12.

What Bill 25 covers for a co-ownership meeting

Bill 25 notably amends the Act respecting the protection of personal information in the private sector. In this context, an audio or video recording of a co-ownership meeting captures personal information (voice, image and opinions). The syndicate’s “person responsible for the protection of personal information” (often designated by the board of directors) must ensure compliance with governance, security and transparency obligations.

• The syndicate is the custodian of the recording. It must justify the collection (a legitimate and defined purpose) and limit the recording to what is necessary.
• Co-owners must be clearly informed before the meeting begins that the annual general meeting will be recorded, along with the intended purpose (e.g., helping prepare the minutes).
• Reasonable security measures must protect the file against unauthorized access.

For the applicable legislation, consult the Act respecting the protection of personal information in the private sector on LégisQuébec (CQLR, c. P-39.1) and the provisions of the Civil Code of Quebec concerning respect for privacy (e.g., ss. 35-36 C.C.Q.).

• Act respecting the protection of personal information in the private sector: LégisQuébec – P-39.1
• Respect for privacy: LégisQuébec – C.C.Q., ss. 35-36

Need a procedural framework and standardized documents (notice of meeting, agenda and minutes)? See our administrative management services.

Recording an annual general meeting: validity requirements and consent

In practice, a meeting may be recorded if the collection is necessary and proportionate to the stated purpose. The most common purpose is taking notes to prepare accurate and neutral minutes. The following are the recommended conditions.

Notice in the meeting notice and at the beginning of the meeting

• Specify in the notice of meeting that the annual general meeting may be recorded for the purpose of preparing the minutes and ensuring a record of the discussions.
• Verbally remind participants, when opening the meeting, that recording is underway, its purpose, the person responsible (designated by the board of directors) and the intended retention period.
• Indicate whether the recording is audio-only or audio/video, and the recording area (e.g., the chair’s table and speakers’ microphones).

Managing objections and solutions

• If a co-owner objects for reasonable privacy-related reasons, the meeting chair may use audio only, move the camera farther away or offer the person the option of speaking into a microphone outside the camera’s view.
• Avoid recording private conversations taking place outside the meeting. The declaration of co-ownership and the by-laws of the immovable may specify the procedures for reducing conflicts.
• A secret vote (by paper or electronic ballot) must never be filmed or recorded in a way that identifies a voter.

The legal framework requires minimizing the collection of information and obtaining informed consent where required. In a divided co-ownership, clear notice in the notice of meeting and at the beginning of the annual general meeting, combined with concrete protective measures, is the most robust practice.

Best practices: from recording to minutes

For the recording to genuinely improve the quality of the minutes while complying with Bill 25, apply these principles.

• Limited purpose: use the file only to prepare and validate the minutes. Avoid any public distribution or posting on social media.
• Minimization: favour audio. If video is necessary (for a hybrid meeting or to manage speaking turns), frame only the chair’s table and the active microphone.
• Security: store the file in a secure directory with restricted access (the meeting secretary, a designated board member or the condominium manager). Encrypt it if possible.
• Retention: destroy the recording after the minutes are approved at the next annual general meeting, unless a serious dispute has been formally raised and documented.
• Traceability: record in the minutes that the meeting was recorded, the purpose and the intended retention period. Keep an internal access log.

The RGCQ recommends adopting written procedures and training meeting officers. You can also publish an information sheet for co-owners in your shared space.

If you hold virtual or hybrid meetings, structure the logistics (microphone controls, waiting room and identification of proxy holders) and keep an event log from the platform. MultiRent can help you harmonize these practices through its operations management services.

What is prohibited or risky

• Secret recording by a co-owner on a phone without informing the meeting: high risk of violating privacy and improper use.
• Sharing the recording with unauthorized third parties or on public platforms: contrary to the principles of proportionality and security.
• Recording private conversations held away from the microphone in spaces adjacent to the room (often common portions): prohibited.
• Recording or tracking that makes it possible to link each secret vote to a co-owner: must be avoided at all costs.
• Using a co-owner’s image for other purposes (promotion or social media): requires separate, specific and informed consent.

For a reminder of the general principles, also consult ss. 35 and 36 C.C.Q. on respect for privacy on LégisQuébec, as well as professional resources on the protection of personal information, such as those of the OACIQ (applicable by analogy with respect to consent and confidentiality).

Recommended procedure for your syndicate

Here is a simple process for remaining efficient and compliant, from the perspective of the board of directors and the meeting secretary.

1. Board decision and purpose
   • Adopt a resolution specifying why the recording is required (e.g., accuracy of the minutes) and appointing the person responsible.
2. Notice in the notice of meeting
   • Add an “Information and privacy – Bill 25” box explaining the recording, the legal basis, the retention period and the responsible person’s contact information.
3. Opening of the meeting
   • Announce the recording, its scope (audio/video), how objections will be handled and the reminder about the secret vote.
4. Technical recording
   • Test the audio, position a single microphone and display an “Recording in progress” banner. Avoid multiple cameras.
5. Preparing and approving the minutes
   • Prepare concise and neutral minutes. Mention that the recording exists and state the retention plan.
6. Retention and destruction
   • Restrict access to the file. Destroy it after the minutes are approved, unless a demonstrable need related to a dispute exists.

Summary table

Remember that sound by-laws of the immovable can specify these procedures. Several syndicates we support include a “meeting recording policy” consistent with the declaration of co-ownership and Bill 25.

To equip your board of directors, visit our blog and discover our templates and procedures for administrative management.

FAQ about recording meetings

• Can a co-owner record with a phone? Yes, if the meeting is informed and the same rules apply (purpose, no distribution and respect for private discussions). Secret recording remains risky and may contravene the C.C.Q.
• Is a vote required to authorize recording? Not necessarily. A board resolution and clear notice to participants are often sufficient, provided the purpose is legitimate and proportionate. Also check your declaration of co-ownership and the by-laws of the immovable.
• How long should the file be kept? As a general rule, until the minutes are approved at the next annual general meeting. Beyond that, retain it only in the event of a justified dispute, with increased security measures.

For more information, see the Act respecting the protection of personal information in the private sector (P-39.1) on LégisQuébec and the RGCQ guides.

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

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