Quebec’s AI workplace guidelines push employers toward greater transparency and employee rights

Quebec’s AI Workplace Guidelines: What HR Needs to Know

Quebec has introduced workplace guidelines on artificial intelligence that, while not legally binding, provide clear signals on how existing privacy laws will be applied and where legal standards are heading. These guidelines emphasize that AI use in the workplace goes beyond technology—it directly affects employee rights, privacy, and fairness.

Employers should recognize that AI policies, staff training, and transparency must all evolve to keep pace with these changes.

AI’s Growing Role in the Workplace

Earlier this year, Quebec’s privacy regulator, the Commission d’accès à l’information (CAI), submitted a brief to the Ministry of Labour highlighting how AI is already shaping workplace practices. From automating hiring processes to monitoring performance and employee behavior, AI tools are becoming integral. The brief calls for a regulatory framework that prioritizes transparency, fairness, and privacy protection.

Key Employer Responsibilities

• Publish clear AI policies. These should specify which AI systems are in use, how decisions are made, and what employee data is collected.
• Notify employees. Inform staff when AI supports or fully automates decisions affecting their work.
• Start simple. Smaller employers can begin by keeping basic records on AI tool usage—clarity matters more than complexity.

These steps help clarify expectations and reduce risk without overwhelming administrative resources.

Where to Draw the Line with AI

The CAI advises caution around AI applications that may cause harm, such as emotion analysis, biometric data use, or fully automated decisions with significant employee impact. Employers must also verify whether their AI vendors use employee data to train models, as this could breach privacy laws if done without explicit consent.

Asking direct questions about data handling with vendors is essential for compliance.

Conducting Algorithmic Impact Assessments

Alongside privacy reviews, employers are encouraged to perform algorithmic impact assessments. These assessments should:

• Include employee feedback
• Evaluate whether the AI tool is necessary and proportionate
• Check for bias or unfair outcomes

These proactive steps serve as protection against potential legal or reputational issues down the line.

Respecting Legal and Contractual Rights

AI use must align with individual contracts, collective agreements, and Quebec’s Charter of Human Rights and Freedoms. This means respecting privacy, dignity, equality, and fair working conditions. Failure to comply can lead to grievances or legal challenges.

Practical Steps for Employers

• Document AI systems and data usage clearly.
• Notify employees about automation in decision-making.
• Confirm third-party data practices with vendors.
• Train key staff on privacy obligations related to AI.

These measures can be scaled based on the organization's size and resources but should never be skipped to avoid unnecessary risk.

Looking Ahead

While Quebec’s current privacy reforms already raise standards, the CAI acknowledges that clearer regulations on AI in employment are still needed. Until these arrive, the safest approach is a proactive one—prioritizing transparency, employee rights, and responsible data management.

For HR professionals looking to strengthen their understanding and implementation of AI policies, exploring targeted AI training can be valuable. Resources like Complete AI Training’s latest courses offer practical insights tailored to workplace applications.