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How long do you have to keep employee training records in Canada?

By Embay Consulting Inc.

No Canadian statute sets one retention period for employee training records. Law 25 requires a record used for a decision to be kept at least one year after it, then destroyed once its purposes are achieved. Quebec's OHS Act, PIPEDA and Ontario's accessibility standards require training or records but set no number.

Key facts

Law 25, decision records
At least one year after the decision (s. 11); destroyed or anonymized once the purposes are achieved (s. 23).
PIPEDA
No fixed period. Kept no longer than necessary, and long enough for access after a decision (Schedule 1, cl. 4.5 and 4.5.2).
Quebec OHS Act
No retention period and no training register in the Act or the RSST, as read on 2026-09-02.
Ontario IASR
A record of training dates and headcount is required (s. 7(5)); that section sets no retention period.

Which statutes set a retention period for training records?

Of the instruments surveyed here, only Law 25 states a period, in two provisions that work together. Each applies to a narrow set of records. The table lists them with the section the figure comes from, read in the primary source on the date given in the sources list.

Retention periods for employee training records, by statute or regulation, as read on the access date of each source
ObligationWho it coversWhat is keptHow longSource
Law 25, decision recordsQuebec private-sector enterprisesPersonal information used to make a decision about a personAt least one year after the decisionCQLR c. P-39.1, s. 11
Law 25, end of lifeQuebec private-sector enterprisesAny personal informationDestroyed or anonymized once the purposes are achieved, subject to a preservation period in another ActCQLR c. P-39.1, s. 23

Both rows come from the same Act. Law 25 sets a floor for records that fed a decision, then a ceiling for everything else. A completion record that supported a certification, a promotion or a dismissal sits under the floor. The rest of the training history sits under the ceiling, and the ceiling defers to any other Act that sets a longer period.

Which statutes set no retention period at all?

Three instruments create a training or record-keeping duty without a number attached. That absence is a finding, not a gap in this page.

Training duties with no retention period in the text, as read on the access date of each source
ObligationWho it coversWhat the text says about recordsRetention periodSource
Quebec OHS training dutyEvery Quebec employerThe employer must ensure appropriate training, instruction and supervision (s. 51(9)). No training register is prescribed.Not publishedCQLR c. S-2.1 and the RSST
PIPEDA, employee informationFederal works, undertakings and businessesKept no longer than necessary for the purposes; a record used for a decision is kept long enough for the person to access it (cl. 4.5, 4.5.2).No fixed number of yearsS.C. 2000, c. 5, Schedule 1
Ontario accessibility training recordDesignated public sector organizations and organizations with 50 or more employees in OntarioA record of the training, including the dates and the number of people trained (s. 7(5)).Not set in s. 7(5)O. Reg. 191/11

Vendor pages routinely quote a figure for occupational health and safety records. The Act and the Regulation respecting occupational health and safety, as read on the access date, contain none. Section 52 of the Act does require a register, but it is a register of contaminants and dangerous materials, not of training. Conflating the two is the error this table exists to prevent.

How do you set a retention period when the law does not?

Start from the obligation that required the training, not from the platform that recorded it. That is the rule the audit-ready records page states, and this table is what it looks like applied.

  1. List every training program and the obligation behind it. Some programs answer to two.
  2. For each obligation, take the period from the table above, or write "not published" beside it.
  3. Where nothing is published, keep the record for as long as you would need to defend the decision it supported. Under Law 25 that is at least one year. Under an OHS duty of result, it is for as long as the worker could be asked to show they were trained.
  4. Set the longest applicable period as the floor for the whole program, and write the reasoning next to the number.

That reasoning is the document a regulator or a privacy officer asks for. A number without it is a guess with a decimal point.

Where do the figures in this table come from?

Every figure was read in the consolidated text of the statute or regulation. Each row names its section. The sources list gives the access date for each text, and the pages linked below explain each instrument in more detail.

Figures change. Statutes and regulations are amended, and the consolidated text follows each amendment. Treat the access date as the date this table was true.

How does EmbayLMS handle this?

EmbayLMS keeps a completion record with its original date after the learner's account is deactivated, so a retention period can run its full course without keeping a seat active. The history exports by person, by course or by date range, which is the form a regulator's request or an access request takes. The platform does not set or enforce a retention period; that number comes from the table above and from your own counsel.

This page summarizes statutory provisions in general terms as they read on the access date given for each source. It is not legal advice, and it does not state what the law requires of your organization. Consult a lawyer about your own obligations before you rely on it.

Related questions

Which statutes set a retention period for training records?
Of the instruments surveyed here, only Law 25 states a period, in two provisions that work together. Each applies to a narrow set of records. The table lists them with the section the figure comes from, read in the primary source on the date given in the sources list.
Which statutes set no retention period at all?
Three instruments create a training or record-keeping duty without a number attached. That absence is a finding, not a gap in this page.
How do you set a retention period when the law does not?
Start from the obligation that required the training, not from the platform that recorded it. That is the rule the audit-ready records page states, and this table is what it looks like applied.
Where do the figures in this table come from?
Every figure was read in the consolidated text of the statute or regulation. Each row names its section. The sources list gives the access date for each text, and the pages linked below explain each instrument in more detail.

Sources

  1. Act respecting the protection of personal information in the private sector, consolidated to April 7, 2026, LégisQuébec, Éditeur officiel du Québec, accessed August 28, 2026
  2. Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, Justice Laws Website, Government of Canada, accessed September 2, 2026
  3. Loi sur la santé et la sécurité du travail, RLRQ c. S-2.1, Légis Québec, accessed September 2, 2026
  4. O. Reg. 191/11, Integrated Accessibility Standards, Government of Ontario, e-Laws, accessed September 2, 2026