License Plate Recognition in Divided Co-Ownership (Bill 25)

Automatic licence plate recognition (LPR) is attracting more and more divided co-ownership syndicates in Montreal and on the South Shore. The goal: better control over parking access and fewer abuses. But is it legal in Quebec under Bill 25? The short answer: yes, provided the syndicate complies with the Act respecting the protection of personal information in the private sector (P‑39.1), the Civil Code of Quebec (C.c.Q.) and applies clear proportionality measures. Content up to date as of 2026-07-28.

In this article, we explain what your board of directors (board) must plan for: legal grounds, policies, signage, data retention and governance. You will also find practical steps for deploying the solution while respecting the privacy of co-owners and visitors.

Is it legal to use license plate recognition in divided co-ownership?

• Yes, if its use serves a legitimate purpose related to the administration of the common portions, such as securing access, enforcing the parking by-laws or preventing encroachment on reserved spaces.
• A licence plate is personal information because it directly or indirectly identifies a person. Its processing is therefore governed by the Act respecting the protection of personal information in the private sector (amended by Bill 25).
• The C.c.Q. recognizes the syndicate’s powers to administer the divided co-ownership and adopt rules for the use of the common portions, while respecting co-owners’ rights and privacy.

In practical terms, legality rests on necessity and proportionality: collect the minimum information necessary, for a specific purpose, for a limited retention period and with appropriate security measures. Use must also be transparent (signage, policy) and provided for in the by-laws of the immovable or in a board resolution recorded in the minutes.

For reference:
– Civil Code of Quebec – divided co-ownership (C.c.Q., art. 1039 et seq.). Link: https://www.legisquebec.gouv.qc.ca/fr/document/ccq-1991
– Act respecting the protection of personal information in the private sector (P‑39.1), as amended by Bill 25. Link: https://www.legisquebec.gouv.qc.ca/fr/document/lc/P-39.1

What Bill 25 requires for an LPR system

Bill 25 modernized the obligations of private-sector organizations, including divided co-ownership syndicates. If you implement a license plate recognition solution, plan for at least the following:

Personal information involved

• Data captured: plate image, number, date/time, access point and, sometimes, an image of the vehicle. This is personal information.
• Categories of people concerned: co-owners, occupants, suppliers and visitors.

Key compliance obligations

• Defined and necessary purpose: precisely define the objective (access control, enforcement of the by-laws) and limit use to that objective.
• Governance and responsible person: appoint the person responsible for the protection of personal information for the syndicate and adopt an accessible internal policy.
• Privacy impact assessment (PIA): conduct a PIA before acquiring or deploying a system involving personal information, especially if there is a transfer outside Quebec or profiling.
• Data minimization: capture only the plate, without retaining unnecessary images of people; avoid audio.
• Retention period: establish a short, justified period (e.g., a few days or weeks depending on investigation needs), followed by automatic deletion.
• Security: encryption, access controls, access logs and role separation (condominium manager, caretaker, IT provider).
• Transparency: clear signage at entry points; notice to co-owners describing the purpose, the people with access to the data and the retention periods.
• Access and rectification rights: establish a process for responding to requests.
• Supplier agreements: a written contract describing security measures, confidentiality, the prohibition on secondary use, subcontracting and the disposition of data at the end of the mandate; PIA if the data leaves Quebec.
• Incident register: document every confidentiality incident and provide notification when necessary.

Official resources:
– Act respecting the protection of personal information in the private sector (P‑39.1) – general obligations: https://www.legisquebec.gouv.qc.ca/fr/document/lc/P-39.1

Proportionality and data protection best practices

The key to compliance is proportionality. Your syndicate must be able to demonstrate that LPR is the least intrusive means of achieving the chosen purpose.

Best practices to consider:

• Avoid facial recognition or broad capture of people; position the camera so that it reads the plate only.
• Enable a “whitelist” mode for reserved spaces and limit retention of compliant entries.
• Pseudonymize or hash the plate number where possible, especially when exporting logs.
• Limit access to logs to what is strictly necessary (e.g., the condominium manager and one board member), with strong authentication.
• Keep an audit trail of every consultation or export.
• Plan regular testing and an annual policy review.

For the divided co-ownership framework, confirm alignment with the declaration of co-ownership and the by-laws of the immovable. Updating the parking by-laws may be appropriate, followed by communication to co-owners and filing in the minutes of the next annual general meeting.

Useful references:
– C.c.Q. – general and divided co-ownership provisions: https://www.legisquebec.gouv.qc.ca/fr/document/ccq-1991
– RGCQ – divided co-ownership resources and best practices: https://rgcq.org/

Implementation: practical steps for the board

Here is a pragmatic process we often recommend to a syndicate we support:

1. Clarify the purpose and issues: parking abuses, security and visitor access.
2. Confirm the legal basis: administration of the common portions and the by-laws of the immovable; record the decision in a board resolution entered in the minutes.
3. Conduct a PIA: risks, mitigation measures, data minimization and data flows (including any transfer outside Quebec).
4. Choose a supplier: require contractual guarantees, verify security and, where necessary, confirm the installer’s compliance with applicable RBQ requirements.
5. Draft or update the documents: privacy policy, internal policy governing access to logs, and procedures for responding to access requests and incidents.
6. Configure the solution: camera positioning, automatic deletion, access list and role-based controls.
7. Install signage and communicate: signs at access points, an information notice to co-owners and an addition to the parking by-laws.
8. Train authorized people: the condominium manager, caretaker and board member; test different scenarios.
9. Operate and audit: record consultations and review the necessity and settings annually.

To speed up the organization of your policies and templates, see our administrative and operational management services:
– multiRent services – administrative management: https://www.multirent.ca/services/#gestion-administrative
– multiRent services – operations management: https://www.multirent.ca/services/#gestion-des-operations
– Discover more practical content on our blog: https://www.multirent.ca/blogue/

Example of how requirements correspond to syndicate actions:

Related external resource:
– RBQ – information on contractor licences: https://www.rbq.gouv.qc.ca/entrepreneurs-et-professionnels/licence/

Risks, complaints and penalties to anticipate

A deployment without a privacy framework exposes the syndicate to:

• Complaints and investigations by the competent authorities.
• Orders to stop collecting or destroy the data.
• Administrative and penal sanctions provided for under the Act respecting the protection of personal information in the private sector (P‑39.1) in cases of serious non-compliance.
• Internal conflicts and challenges if the by-laws of the immovable have not been properly amended or communicated.

To mitigate these risks, keep a complete documentary record: PIA, board resolution, notices, photos of signs, contracts, access logs and proof of deletion. Also make sure the divided co-ownership’s parking rules align with the declaration of co-ownership and inform co-owners at the next annual general meeting.

Frequently asked questions

Q1. Do we need co-owners’ consent to capture plates?
A. Not necessarily if the collection is necessary for administration and clearly disclosed. Transparency, proportionality and the right of access remain mandatory.

Q2. How long can plate logs be retained?
A. For the minimum period justified by the purpose. Prefer rapid automatic deletion, except where longer retention is required for a documented investigation.

Q3. Can the condominium manager access images and logs?
A. Yes, if this is provided for in the mandate, limited to what is necessary, with access controls and logging. The board must govern this access through an internal policy.

Additional official references:
– Act respecting the protection of personal information in the private sector (P‑39.1): https://www.legisquebec.gouv.qc.ca/fr/document/lc/P-39.1
– C.c.Q. – divided co-ownership: https://www.legisquebec.gouv.qc.ca/fr/document/ccq-1991
– RGCQ – resources: https://rgcq.org/
– RBQ – licences: https://www.rbq.gouv.qc.ca/entrepreneurs-et-professionnels/licence/

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

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