Condo Surveillance Cameras and Bill 25

Installing or operating surveillance cameras in divided co-ownership raises legal and governance issues. Bill 25 now imposes stricter rules on the collection of images considered personal information. Updated as of 2026-05-12, here is what your board of directors and syndicate need to know in the Greater Montreal area.

Security is a legitimate concern, especially in parking areas, lobbies and access points. However, it must be balanced with respect for the privacy of co-owners and occupants. A clear, documented and proportionate approach reduces the risk of complaints and non-compliance.

How Bill 25 changes surveillance cameras in condos

Images of an identifiable person constitute personal information. Under the Act respecting the protection of personal information in the private sector (Bill 25), the syndicate becomes the “person responsible” for processing this data. The board of directors must therefore establish a specific purpose (e.g., preventing and investigating incidents), limit collection, secure access and set a reasonable retention period.

• Legal basis and proportionality: film only what is necessary for security. Avoid intrusive angles and audio recording, which is more sensitive and rarely justifiable.
• Designated person responsible: the board of directors appoints a person responsible for the protection of personal information and documents their roles (receiving access requests, managing incidents and following up with service providers).
• Privacy impact assessment (PIA): required for any project presenting a high risk (e.g., cloud storage outside Quebec or facial recognition). The PIA assesses the risks and mitigation measures.
• Retention and deletion: define a short, justified period (e.g., a few days to a few weeks depending on investigative needs), with automatic, logged deletion.

Useful references:
– LégisQuébec – Act respecting the protection of personal information in the private sector (chapter P-39.1) (Bill 25): https://www.legisquebec.gouv.qc.ca/
– LégisQuébec – Personality rights and respect for privacy under the Civil Code of Quebec (see sections 35-37, including section 36 on invasions of privacy): https://www.legisquebec.gouv.qc.ca/

Where to film and what to avoid: common portions vs. private portions

Cameras should be aimed at common portions where incidents occur most often: entrances, exits, access ramps, elevators and mechanical rooms. Exercise areas, swimming pools and terraces require extra vigilance because the expectation of privacy is stronger there.

• Private portions: never point a camera inside a unit or beyond the threshold of a door. Also avoid directly capturing the inside of balconies whenever possible.
• Audio and zoom: audio recording and intrusive zooming increase the risk of invading privacy. Disable audio and limit zoom capabilities to essential needs.
• Access to images: access must be restricted to authorized people (the condominium manager or a board member appointed for this purpose). Do not display live footage on screens accessible to the public or unauthorized personnel.

Best practices and guides:
– RGCQ – Resources and best practices in co-ownership: https://rgcq.org/
– RBQ – Contractors and systems installation work (licences and compliance): https://www.rbq.gouv.qc.ca/

Governance, consent and mandatory signage

Before installation, the board of directors should present the project at the annual general meeting and explain its purpose, locations, retention period and costs to be paid through common expenses. Depending on the scope of the work on the common portions and its impact on enjoyment, different majorities may apply. Refer to your declaration of co-ownership and, where necessary, the Civil Code of Quebec for the applicable voting thresholds. Record the decisions in the minutes.

• By-law and policy: adopt a by-law of the immovable or an internal policy governing the use of cameras. Specify the purpose, areas filmed, authorized access, retention period, process for requesting footage and incident protocol.
• Clear signage: install visible signage indicating the presence of cameras, their purpose and the contact information of the person responsible. The signage meets the information requirement under Bill 25.
• Access requests: provide a form and response deadlines. Share only the footage required, obscuring third parties whenever possible.
• Training: inform the concierge and board members of the access rules, audit-log requirements and steps to follow in the event of an incident.

For structured administrative support, see our administrative management services (policies, minutes and annual general meeting follow-ups), and browse our blog for other practical guidance.

Implementation: contract, data security and maintenance

Choose a qualified contractor, duly licensed by the RBQ where required, and request a proposal covering implementation, wiring, storage and cybersecurity. Document the plans and areas covered, and add them to the co-ownership’s maintenance logbook/EUC.

• Service provider contract: include clauses covering data hosting, encryption, strong authentication, access logs, retention period, reversibility and deletion at the end of the contract.
• Data outside Quebec: if the images are hosted outside Quebec, conduct a PIA and assess the protection provided by the jurisdiction concerned, as required by Bill 25.
• Internal procedures: implement an escalation procedure for a confidentiality incident, an access register and a maintenance schedule. Periodically test image quality and retention.
• Budget and follow-up: plan equipment replacements through common expenses and, where appropriate, coordinate them with the contingency fund forecasts. Ensure consistency with your declaration of co-ownership and the by-laws of the immovable.

For selecting and following up with service providers, as well as preventive maintenance, see our operations management services.

Sources for further information:
– LégisQuébec – Act respecting the protection of personal information in the private sector (Bill 25): text and updates
– LégisQuébec – Civil Code of Quebec, privacy (see sections 35-37): applicable provisions
– RGCQ – Co-ownership governance advice: documentation and training
– RBQ – Specialized contractor licences: compliance verification

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

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