Bill 194 Comes into Force: A Turning Point for Privacy in Ontario’s Public Sector
On July 1, 2025, a landmark change in Ontario’s public sector privacy landscape will take effect. Bill 194, Strengthening Cyber Security and Building Trust in the Public Sector Act, 2024, will formally come into force, placing new legislative requirements on provincial institutions, including a mandate to conduct Privacy Impact Assessments (PIAs). This move aligns Ontario with other Canadian jurisdictions that already require PIAs and signals a more proactive and transparent approach to handling personal information in the digital age.
Why PIAs Matter
A Privacy Impact Assessment is more than a checkbox, it’s a foundational practice in responsible data governance. PIAs help institutions identify, assess, and mitigate privacy risks before launching a new program, policy, or system that involves personal information. They are typically completed during early planning stages and guide the implementation of safeguards throughout the project lifecycle.
The Information and Privacy Commissioner of Ontario (IPC) and other privacy authorities across Canada have long advocated for PIAs as best practice. They promote transparency, embed privacy-by-design principles, and ensure public bodies are meeting their obligations under access and privacy legislation. In a time where digital services are growing rapidly and data breaches are increasingly costly – financially, operationally, and reputationally – PIAs offer a critical layer of foresight and accountability.
PIAs in Other Jurisdictions: A National Trend
Ontario’s new mandate brings it in line with a growing number of jurisdictions across Canada that already require PIAs under law.
At the federal level, the Government of Canada mandates PIAs through the Treasury Board Directive on Privacy Impact Assessment, which requires all departments and agencies to assess privacy implications of programs that involve personal information. Federal institutions must submit completed PIAs to the Office of the Privacy Commissioner before implementation.
In British Columbia, section 69 of the Freedom of Information and Protection of Privacy Act (FOIPPA) requires that a PIA be completed whenever a public body is designing or implementing a project that involves personal information. This ensures that privacy considerations are built into all phases of the initiative.
Alberta requires public bodies to complete PIAs before launching new programs that use or disclose personal information in a way that is significantly different from existing processes. These assessments must be submitted to the Office of the Information and Privacy Commissioner (OIPC) for review and approval.
Quebec’s Law 25 goes even further, imposing strict requirements on both public and private organizations to conduct PIAs when acquiring, developing, or overhauling any system that processes personal data.
Taken together, these laws reflect a national shift toward embedded privacy accountability. Ontario’s Bill 194 is the latest signal that governments are recognizing the need to anticipate privacy risks, not simply react to them.
What Bill 194 Requires
With Bill 194 now in effect, Ontario provincial institutions are required to complete PIAs in advance of any new collection of personal information. This applies across ministries, agencies, boards, commissions, and other provincial entities covered under Ontario’s Freedom of Information and Protection of Privacy Act (FIPPA).
At its core, Bill 194 is about strengthening public confidence in how government handles personal information. PIAs are a key tool in that mission, not just to comply with the law, but to demonstrate that privacy is considered at every stage of service design and delivery.
While many institutions may have already been completing PIAs as a best practice, the transition to a legal requirement will likely demand more consistency, documentation, and process rigour. Notably, the IPC now has explicit oversight of this PIA process. Institutions must submit their assessments to the IPC, which can provide guidance, request additional information, or recommend changes to strengthen privacy protections.
This shift positions PIAs not only as an internal planning tool, but also as a formal mechanism for external accountability.
How Vayle PIA Can Help
For institutions adapting to these new requirements, Vayle PIA offers an integrated, user-friendly platform purpose-built to streamline the assessment process while supporting compliance.
Vayle PIA guides users through each step of the PIA journey with tailored forms, specifically designed for FIPPA and other applicable Canadian legislation. Features include:
- Dynamic workflows that reflect the complexity of each initiative
- Built-in logic to record personal information types and associated risks
- Tagging and commenting tools for collaborative input from legal, privacy, and IT teams
- Track and manage privacy risk follow-up items across all monitored PIAs at the individual program level, with real-time visibility into ownership, status, and resolution timelines
- Risk scoring and flagging of issues requiring mitigation
- Generation of audit-ready reports and summaries for submission to the IPC
- Personal Information Bank (PIB) tracking and records for future reference and reviews
By embedding automation and structure into the process, Vayle PIA helps institutions reduce manual effort, minimize compliance gaps, and build a privacy-first culture. It supports both day-to-day users and privacy professionals, ensuring assessments are not only completed, but also completed with quality and consistency.
