What Is the PIPEDA Compliance Checklist for Canadian Websites?

Table of Contents

• What Is PIPEDA and Why Does Your Website Need to Comply?
• What Personal Information Collection Requirements Does PIPEDA Have?
• What Are PIPEDA Consent Requirements?
• What Are PIPEDA Cookie Consent Requirements?
• What Should Be Included in a PIPEDA Privacy Policy?
• What User Rights Does PIPEDA Require?
• What Security Safeguards Does PIPEDA Require?
• What Are Data Retention Requirements Under PIPEDA?
• What Are Common PIPEDA Violations?
• Conclusion / TL;DR
• Frequently Asked Questions

What Is PIPEDA and Why Does Your Website Need to Comply?

PIPEDA (Personal Information Protection and Electronic Documents Act) is Canada's federal privacy law that applies to private-sector organizations collecting, using, or disclosing personal information during commercial activities.

If you:

• Run a business website in Canada
• Collect user data (emails, analytics, cookies)
• Use tracking tools (Google Analytics, Facebook Pixel)
• Operate an e-commerce store
• Process customer information

Then PIPEDA applies to you.

This comprehensive checklist will help you ensure your website is fully PIPEDA compliant in 2025.

What Personal Information Collection Requirements Does PIPEDA Have?

What Personal Information Does PIPEDA Cover?

Personal information under PIPEDA includes:

• ✅ Names and contact information
• ✅ Email addresses
• ✅ Phone numbers
• ✅ IP addresses
• ✅ Device identifiers
• ✅ Browsing behavior and cookies
• ✅ Purchase history
• ✅ Location data
• ✅ Any data that can identify an individual

Action: Create a data inventory listing all personal information your website collects.

Why Must I Document Why I Collect Each Type of Data?

For every piece of personal information, you must have a legitimate purpose:

Examples:

• Email address: To send order confirmations and newsletters (with consent)
• IP address: For security and fraud prevention
• Cookies: To analyze traffic and improve user experience

Action: Create a data collection justification document.

How Much Data Can I Collect Under PIPEDA?

PIPEDA requires "data minimization" — only collect information necessary for your stated purposes.

✅ Good:

• Collect email for newsletter signup
• Collect shipping address for order delivery

❌ Bad:

• Requiring phone number when email is sufficient
• Collecting birthdates for no clear reason
• Asking for more fields than necessary "just in case"

Action: Review all forms and remove unnecessary fields.

What Are PIPEDA Consent Requirements?

What Is Meaningful Consent Under PIPEDA?

PIPEDA requires consent that is:

• Meaningful: Users understand what they're consenting to
• Informed: You explain how data will be used
• Voluntary: Users have a real choice

For cookies and tracking:

❌ Bad: "By using this site, you consent to cookies."
✅ Good: "We use cookies for analytics and advertising. 
         [Accept All] [Reject Non-Essential] [Customize]"

Action: Review all consent mechanisms on your website.

When Do I Need Opt-In Consent?

For sensitive personal information (health data, financial info, precise location), you need explicit opt-in consent.

✅ Opt-in examples:

• Unchecked checkbox that user must check
• Toggle switch user must turn on
• Button user must click

❌ Not acceptable:

• Pre-checked boxes
• Implied consent
• Consent buried in terms of service

Action: Ensure sensitive data collection uses explicit opt-in.

Can I Bundle Multiple Consents Together?

No. Don't bundle consents together. If you collect data for multiple purposes, get separate consent for each.

Example:

□ Yes, send me promotional emails
□ Yes, use my data for analytics
□ Yes, share my data with partners

Action: Unbundle any combined consent requests.

How Easy Must It Be to Withdraw Consent?

Users must be able to:

• Withdraw consent as easily as they gave it
• Opt-out of emails with one click
• Delete their account without hassle

Action: Add clear opt-out mechanisms (unsubscribe links, account deletion option).

What Are PIPEDA Cookie Consent Requirements?

How Do I Implement a Compliant Cookie Banner?

Your cookie banner must:

• ✅ Appear before non-essential cookies are set
• ✅ Explain what cookies do
• ✅ Offer "Accept," "Reject," and "Customize" options
• ✅ Not use pre-checked boxes
• ✅ Link to your privacy policy

Action: Install a PIPEDA-compliant cookie banner (like Cookie Banner Generator).

How Do I Block Cookies Until Consent?

Your website must NOT set tracking cookies until the user accepts them.

Test:

1. Open your site in incognito mode
2. Open DevTools → Network tab
3. Reload page
4. Check if Google Analytics/Facebook Pixel fires before you click "Accept"

If yes, you're not compliant.

Action: Implement cookie blocking until consent is given.

How Do I Categorize My Cookies?

Organize cookies into categories:

• Strictly Necessary: No consent required (security, sessions)
• Functional: Preferences (consent recommended)
• Analytics: Google Analytics, Hotjar (consent required)
• Marketing: Facebook Pixel, Google Ads (consent required)

Action: List all cookies by category in your privacy policy.

How Do I Provide Granular Cookie Control?

Users must be able to:

• Accept all cookies
• Reject non-essential cookies
• Choose specific categories

Example:

Cookie Preferences:
☑ Strictly Necessary (always active)
□ Functional Cookies
□ Analytics Cookies
□ Marketing Cookies

[Save Preferences]

Action: Ensure your cookie banner offers granular controls.

What Should Be Included in a PIPEDA Privacy Policy?

What Must My Privacy Policy Include?

Your privacy policy must include:

• ✅ What personal information you collect
• ✅ Why you collect it (purposes)
• ✅ How you use it
• ✅ Who you share it with (third parties)
• ✅ How long you keep it
• ✅ How you protect it (security measures)
• ✅ User rights under PIPEDA
• ✅ How to contact you with privacy questions

Action: Write or update your privacy policy.

How Accessible Must My Privacy Policy Be?

PIPEDA requires that privacy policies be:

• Easily accessible
• Written in plain language
• Available at or before the point of collection

Best practices:

• Link in website footer
• Link in signup/checkout forms
• Use clear language (avoid legal jargon)

Action: Add privacy policy links throughout your site.

What Cookie Information Must I Include?

Your privacy policy should include a dedicated "Cookies" section:

Required information:

• List of cookies by name
• Purpose of each cookie
• Duration of each cookie
• Third parties involved (Google, Facebook, etc.)
• How users can manage/delete cookies

Action: Add detailed cookie information to your privacy policy.

What Third-Party Information Must I Disclose?

If you share data with third parties, you must disclose:

• Who they are (company names)
• What data you share
• Why you share it
• Link to their privacy policies

Common third parties:

• Google Analytics
• Facebook
• Payment processors (Stripe, PayPal)
• Email providers (Mailchimp, SendGrid)
• Hosting providers

Action: List all third parties in your privacy policy.

What User Rights Does PIPEDA Require?

How Do I Allow Users to Access Their Data?

Under PIPEDA, individuals have the right to:

• Know what personal information you have about them
• Request access to their data
• Receive a copy of their data

Action: Create a process for users to request their data (email form or account dashboard).

How Do I Allow Users to Correct Their Data?

Users have the right to:

• Correct inaccurate information
• Update outdated information

Action: Provide account settings or a contact method for data corrections.

How Do I Provide a Data Deletion Option?

Users can request deletion of their personal information, subject to legal retention requirements.

Action: Add account deletion functionality or a deletion request process.

How Do I Explain User Rights in My Privacy Policy?

Your privacy policy must explain that users can:

• Access their personal information
• Correct inaccurate data
• Withdraw consent
• Request deletion
• File a complaint with the Privacy Commissioner

Action: Add a "Your Privacy Rights" section to your policy.

What Security Safeguards Does PIPEDA Require?

What Security Measures Must I Implement?

PIPEDA requires you to protect personal information with safeguards appropriate to the sensitivity of the data.

Security checklist:

• ✅ HTTPS encryption (SSL certificate)
• ✅ Secure password storage (hashing, not plain text)
• ✅ Regular software updates
• ✅ Firewall protection
• ✅ Access controls (limit who can access data)
• ✅ Regular backups
• ✅ Secure third-party integrations

Action: Conduct a security audit of your website.

Do I Need a Data Breach Response Plan?

Yes. If personal information is compromised, PIPEDA requires you to:

• Report breaches to the Privacy Commissioner (if real risk of significant harm)
• Notify affected individuals
• Keep records of breaches

Action: Create a data breach response plan.

What Are Payment Processing Security Requirements?

If you process payments:

• ✅ Use PCI-DSS compliant payment processors
• ✅ Never store full credit card numbers
• ✅ Use tokenization
• ✅ Implement fraud detection

Action: Ensure your payment processor is compliant.

What Are Data Retention Requirements Under PIPEDA?

How Long Can I Keep Personal Data?

PIPEDA requires you to keep personal information only as long as necessary for its stated purpose.

Guidelines:

• Active customers: Keep data as long as the relationship exists
• Inactive customers: Delete after 1-3 years (unless legally required to keep)
• Cookies: Typically 1-2 years, then require new consent
• Analytics: Aggregate and anonymize after 6-12 months

Action: Document retention periods for each data type.

How Do I Implement Data Deletion Procedures?

Create processes to:

• Automatically delete outdated data
• Remove inactive accounts
• Purge old analytics data
• Respond to deletion requests

Action: Set up automated data deletion where possible.

What Are Common PIPEDA Violations?

What Happens If I Don't Have Cookie Consent?

The mistake: Using Google Analytics or other tracking without getting consent.

The fix: Implement a compliant cookie banner that blocks tracking until consent.

Tool: Cookie Banner Generator

What Happens If My Privacy Policy Is Unclear?

The mistake: Using generic, confusing, or incomplete privacy policies.

The fix: Write a clear, specific privacy policy for your actual practices.

What Happens If I Don't Provide Easy Opt-Out?

The mistake: Making it difficult for users to unsubscribe or delete their accounts.

The fix: Add one-click unsubscribe links and account deletion options.

What Happens If I Collect Unnecessary Data?

The mistake: Requiring more information than needed.

The fix: Remove unnecessary form fields. Only collect what you truly need.

What Happens If I Have Weak Security?

The mistake: No HTTPS, weak passwords, outdated software.

The fix: Implement basic security (HTTPS, password hashing, regular updates).

PIPEDA Compliance Quick Reference

For Websites with Basic Tracking:

Minimum Requirements:

1. ✅ Cookie banner with accept/reject options
2. ✅ Privacy policy explaining cookie use
3. ✅ Block tracking cookies until consent
4. ✅ HTTPS encryption
5. ✅ Contact method for privacy questions

Time to implement: 1-2 hours

For E-Commerce Sites:

Additional Requirements:

1. ✅ Secure payment processing
2. ✅ Customer account privacy settings
3. ✅ Data retention policy
4. ✅ Account deletion option
5. ✅ Third-party data sharing disclosure

Time to implement: 4-8 hours

For SaaS/Data-Intensive Sites:

Additional Requirements:

1. ✅ Comprehensive data processing records
2. ✅ Privacy impact assessments
3. ✅ Employee privacy training
4. ✅ Data breach response plan
5. ✅ Designated privacy officer

Time to implement: 1-2 weeks

Ready to Get PIPEDA Compliant?

Immediate Actions (Do This Week):

1. Install a cookie banner → Cookie Banner Generator (free)
2. Write/update privacy policy → Include all required sections
3. Enable HTTPS → Get a free SSL certificate
4. Add footer links → Privacy Policy and Cookie Settings
5. Review forms → Remove unnecessary fields

Short-Term Actions (Do This Month):

6. Audit your cookies → List all cookies and categorize them
7. Document data flows → What data goes where?
8. Implement security basics → Password hashing, backups, updates
9. Train your team → Brief staff on privacy requirements
10. Create deletion process → How will users delete their accounts?

Ongoing Actions:

11. Review privacy policy → Update when you add new tools/features
12. Monitor compliance → Regular audits (quarterly or annually)
13. Stay informed → PIPEDA and Law 25 are evolving
14. Respond promptly → Answer privacy requests within 30 days

Conclusion / TL;DR

Key Takeaways:

• PIPEDA applies to any Canadian business collecting personal data, including cookies and analytics
• Essential requirements: Cookie consent banner, privacy policy, user rights, security measures
• Cookie consent is critical — must block tracking until users opt-in
• Privacy policy must be comprehensive — explain all data collection, use, and sharing
• User rights must be easy to exercise — access, correction, deletion
• Security is mandatory — HTTPS, secure storage, breach response plan

Next Steps:

1. Install a PIPEDA-compliant cookie banner
2. Create or update your privacy policy
3. Implement user rights mechanisms
4. Conduct a security audit
5. Document your data practices

Frequently Asked Questions

What is PIPEDA?

PIPEDA (Personal Information Protection and Electronic Documents Act) is Canada's federal privacy law that applies to private-sector organizations collecting, using, or disclosing personal information during commercial activities.

Does PIPEDA apply to my website?

If you run a business website in Canada, collect user data (emails, analytics, cookies), use tracking tools, or process customer information, then PIPEDA applies to you.

What are the most important PIPEDA requirements?

The most critical requirements are: (1) cookie consent banner that blocks tracking until opt-in, (2) comprehensive privacy policy, (3) user rights (access, correction, deletion), and (4) security measures (HTTPS, secure storage).

How long does PIPEDA compliance take?

For basic websites with simple tracking: 1-2 hours. For e-commerce sites: 4-8 hours. For complex SaaS/data-intensive sites: 1-2 weeks.

What happens if I don't comply with PIPEDA?

While PIPEDA doesn't have GDPR-style fines, non-compliance can result in Privacy Commissioner investigations, public findings against your organization, reputational damage, and potential Federal Court actions.

Do I need a cookie banner under PIPEDA?

Yes, if you use tracking tools like Google Analytics or Facebook Pixel. You must get explicit consent before setting non-essential cookies.

What should I include in my privacy policy?

Your privacy policy must include: what data you collect, why you collect it, how you use it, who you share it with, how long you keep it, security measures, user rights, and contact information.

How do I make my website PIPEDA compliant?

Start with: (1) install a cookie consent banner, (2) write/update privacy policy, (3) enable HTTPS, (4) add privacy policy links, and (5) create account deletion process.

Ready to make your website PIPEDA compliant? Get your free cookie banner →