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16.10.2026Priority 1: CriticalQuebecCanada

Court of Québec upholds CAI order against Clearview AI

What changed

The Court of Québec dismissed Clearview AI’s appeal of the 2021 order issued by the Commission d’accès à l’information (CAI). The order requires the company to stop collecting images of Quebecers and to destroy their images and biometric identifiers. The Court found a real and substantial connection with Quebec even though Clearview has had no office, staff or clients there since 2020. It also held that information collected in breach of the law cannot rest on a serious and legitimate interest.

Source: View the official source

Why it matters

Foreign companies that collect personal information about Quebecers are subject to Quebec privacy law, even without an office, staff or clients in Quebec.
Publishing images online does not remove the consent requirements for collecting them from third parties.
Facial recognition and AI tools trained on scraped images carry legal risk for the organizations that buy and use them.

Our comment

The decision turns the origin of biometric and training data into a procurement question. Organizations that buy facial recognition tools, or AI systems trained on scraped images, can confirm through vendor due diligence how the data was collected and whether Quebec consent requirements were met. The obligations already apply; the ruling confirms they reach foreign providers.

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Sara Derbel

Paralegal

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