Client Registries in Bars: What You Need to Know

Legal News

The Quebec government recently invited bar owners to establish registries of their clients. The objective is to make it easier to reach people who may have contracted COVID-19 if there is an outbreak of cases linked to a bar.

A purely voluntary basis

This is being done on a purely voluntary basis. Bar owners are not required to set up a registry, and clients are not required to provide their personal information.

What information can be requested?

The creation of a client registry must comply with the Act respecting the protection of personal information in the private sector. This means that a bar owner can only ask for the information necessary for public health authorities to reach you:

  • your complete name
  • contact information to reach you (phone number or email)
  • the date and time of your visit to the bar

The employee collecting this information must provide an explanation of:

  • the reason the information is being collected
  • the voluntary nature of the registry
  • the period of time the information will be kept on file
  • the measures taken to protect the confidentiality of your information
  • your right to have access to this information and to correct it, if necessary

How will this information be used?

The information collected in the registry can only be used by public health authorities. Your information may therefore be communicated to these authorities if there is an outbreak of COVID-19 cases linked to the bar and to the time you visited it. Public health authorities might contact you and ask you to do a test to detect the virus.

The bar owner cannot use the information for any other purpose. For example, they could not use your email to send you a newsletter.

The information must be destroyed after a reasonable period of time. In the case of COVID-19, this means the time it usually takes for symptoms to appear, after an infection. Thus, a period of 21 to 30 days would be reasonable. Beyond that time, the information is no longer of use to public health authorities and should be destroyed by the bar owner.