Law 25 and personal information protection · 8 min · October 30, 2026
Phishing and personal information protection
Phishing and AI at work: verify requests before you act
By Exact HR
An urgent request for payment, access or a banking change deserves independent verification, even when the message or voice seems familiar.
The new risk is a request that seems normal
The most dangerous reflex is: “The message looks real, so I’ll take care of it quickly.” Fraudsters deliberately try to reduce thinking time. They may invoke payroll that must go out before noon, an executive’s emergency, a file update, a security problem or a new employee’s imminent arrival.
Treat any unusual request involving payment, access or personal information as something to confirm. Use known contact details, a verified internal portal or an in-person conversation. An email account can be compromised and a voice can be imitated; do not rely solely on the message’s appearance. In its October 8, 2026 update - French resource, the Commission d’accès à l’information (CAI) notes that emails, voices, videos and QR codes can appear legitimate without being so.
Scroll horizontally to view all columns.
| Request received | Risk to recognize | Verification to perform |
|---|---|---|
| Change to banking details | Financial loss and disclosure of sensitive information | Confirm by phone or through a known internal channel, following a two-person verification procedure. |
| Transfer of a candidate’s file or résumé | Disclosure of personal information to an unauthorized recipient | Verify the actual need, recipient and approved secure transfer method. |
| Urgent request on behalf of an executive | Impersonation and bypassing approval processes | Contact the person using known contact details; never use the link in the message. |
| QR code or “reactivation” link | Credential theft or installation of a malicious tool | Open the usual website or app directly instead of using the code or link. |
| Request for information about an absence or health record | Confidentiality breach and excessive disclosure | Limit the information shared, confirm the need and follow the internal procedure. |
Four simple rules to make visible
1. Pause before you act
Urgency is a reason to verify, not a reason to bypass controls. A short pause can prevent an exceptional request from becoming a costly mistake.
2. Verify through another channel
Replying within the same email thread is not independent verification. For a sensitive transaction, use known contact details and apply the established controls. Never share a password or authentication code in response to an unexpected request.
3. Limit what you share
Personnel files, banking details, medical information, insurance documents, applications and performance management records must be handled carefully. Before sending a document, ask whether all the information is necessary and whether the recipient is authorized to receive it.
4. Report it even when no harm is apparent
An attempt should be reported to the designated people. It is not automatically a confidentiality incident. If there are grounds to believe that a confidentiality incident involving personal information has occurred, have the facts assessed, preserve relevant evidence and apply the established process.
Do your procedures clearly identify who verifies requests and receives reports
Who confirms a banking change? Which channel should people use if the usual email seems suspicious? Who receives reports of unusual requests? Exact HR can help clarify roles, procedures and personal information protection tools, in coordination with the people responsible for your operations and IT, within the agreed engagement.
The initial conversation helps clarify the practices to structure. It is not a complete free audit.
Useful training includes practice with realistic situations
Awareness activities should reflect the risks and people’s roles. Short scenarios can complement training: a payment request by text, a banking change, a suspicious link or a QR code. This frequency and format are operational recommendations, not a universal annual requirement imposed by Law 25.
Does your team need Law 25 training
Do your HR staff, administrative team and managers handle the same information? Do they know what to do when a request appears credible but unusual? We can train your team in personal information protection practices and tailor examples to their roles. Objectives, content and format are clarified with you. Technical controls are addressed in coordination with your IT or cybersecurity resource.
Training covers personal information protection practices and appropriate responses by role. It does not include penetration testing, simulated phishing campaigns or emergency technical response services.
For broader support, explore our Law 25 and personal information protection services.

The manager’s role is to make caution acceptable
A team will not follow a verification procedure if people fear being seen as slow, rigid or distrustful. Managers should repeat a clear message: it is always acceptable to take time to verify a request involving money, access or personal information.
Avoid discouraging reports through an automatic blame response. Examine the procedure, access permissions, imposed deadline and training. Under Quebec’s private-sector framework, a confidentiality incident requires reasonable measures and an entry in the incident register. Where there is a risk of serious injury, the required notices must be given promptly, subject to applicable exceptions. An attempt or a click, considered alone, does not establish the conclusion. Private-sector privacy legislation, sections 3.5 to 3.8 - linked French text.
We will clarify your context and the initial steps to consider within the agreed engagement.
A related video from Exact HR
To explore access permissions and digital tools further. This French-language video covers AI agents; it does not replace a phishing response procedure.
Related French-language video
French-language video
French-language video: AI agents and confidential information
This French-language video covers AI agents and access to confidential information. It complements this article but does not replace a phishing response procedure.
Frequently asked questions
Does a familiar voice guarantee someone’s identity
No. A voice can be imitated and an account can be compromised. Contact the person using known contact details and apply the established verification procedure.
Is a suspicious email automatically a confidentiality incident
No. An attempt should be reported, but its classification depends on the facts. Unauthorized access, use or disclosure, loss or another breach of the protection of personal information may constitute a confidentiality incident.
Must we notify the CAI after every click
A click calls for assessment, not an automatic conclusion. Under Quebec’s private-sector framework, notices must be given promptly when an incident presents a risk of serious injury, subject to applicable exceptions.
Training staff, clarifying verification steps and preparing incident management: Exact HR can support your organization in these personal information protection practices. The initial conversation clarifies your need and the scope of support. Do not submit sensitive personal information or incident evidence in the initial form.
Related resources
- Law 25 and personal information protection services
Explore Exact HR’s approaches, tools and support services.
- Confidentiality incident management
Prepare a process to report, assess, document and follow up on an incident.
- IT security and personal information policies
Set clear expectations for access, devices, email, platforms and technology practices.
Sources and references
- CAI - Cybersecurity Awareness Month, October 8, 2026 - French resource
Awareness guidance about emails, voices, videos and QR codes that can appear legitimate.
- Canadian Centre for Cyber Security - What is voice phishing (vishing)?
Official guidance on voice phishing and impersonation by phone.
- Act respecting the protection of personal information in the private sector - sections 3.1, 3.5 to 3.8, 5 and 10 - linked French text
Official text to review in light of the context and facts of a matter.
- CAI - Confidentiality incidents and security measures in the private sector - French resource
Official information about incidents and security measures for the private sector.