AI and client confidentiality in Canada: PIPEDA, CPA Rule 208 and the law societies

Privacy law: PIPEDA and the joint principles

On December 7, 2023 the Office of the Privacy Commissioner of Canada and all provincial and territorial privacy regulators issued the Principles for responsible, trustworthy and privacy-protective generative AI technologies. They apply to organizations that use generative AI, not only to developers, and say organizations should use anonymized, de-identified or non-personal data rather than personal information wherever possible (Torys LLP summary). Information you can re-identify with your own key is still personal information in your hands; what pseudonymization changes is what the AI provider receives.

In Quebec, Law 25 adds its own rules on de-identified information (renseignement dépersonnalisé). See our French-language page for Quebec specifics.

CPAs: Rule 208

Under Rule 208 of the CPA Code of Professional Conduct, you cannot disclose confidential information without proper and specific authority. CPA Ontario's guidance on the responsible use of AI names confidentiality (Rule 208) as paramount (CPA Ontario). CPABC goes further: registrants should ensure no confidential information is included in AI queries, and are encouraged to refrain from it even after checking a tool's privacy compliance (CPABC, July 2025).

Lawyers: rule 3.3-1 and law society guidance

Rule 3.3-1 of the Federation of Law Societies' Model Code imposes a strict duty of confidentiality. The Law Society of Ontario's April 2024 white paper on licensee use of generative AI lists the unanticipated spread of confidential information as a key risk (Osler summary), and the law societies of British Columbia, Alberta, Saskatchewan, Manitoba and Nova Scotia have published similar guidance. Several note that informed client consent may be needed before confidential information goes into a tool that retains inputs.

A practical routine for Canadian firms

1. Document approved tools and the purposes they may be used for.
2. Prefer accounts that don't retain or train on inputs.
3. De-identify before upload: names, SINs, Business Numbers and program accounts, NEQ and QST numbers, addresses and postal codes, account and file numbers.
4. Keep the key on your computer.
5. Review every output; you remain accountable for the work.

What Velado detects in Canadian documents

Social Insurance Numbers (NAS) with context, Business Numbers with program accounts (123456789 RT0001), Quebec NEQ, QST/TVQ and RAMQ numbers, GST/HST numbers, Canadian postal codes, North American phone numbers, street addresses in English and French, names after "Client:", "Tenant:" and similar, plus cards and emails.

Price in CAD

• Individual, 1 user: C$229 per year
• Firm, up to 5 users: C$790 per year
• Firm+, up to 15 users: C$1,750 per year

Prices exclude VAT and sales tax. Free public beta until 31 January 2027, then a 14-day free trial. All plans.

This page summarises public guidance for information only. It is not legal advice; check your professional body's current rules.