Pipeda Compliance for E-Signature: How to Meet the Requirements in 2026

If you are a Canadian business or an organization serving Canadian customers that is moving documents online, you've likely considered or already adopted electronic signatures. The benefits, such as faster approvals and less paperwork, are obvious.

What is less obvious is that Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) holds you responsible for how personal information, like names and email addresses, in your signed documents, is collected, used, stored, and protected.

Contrary to common assumptions, the law is not a formality. The Office of the Privacy Commissioner of Canada is actively monitoring compliance. In its 2024 to 2025 report, the Office recorded a 32 percent increase in PIPEDA complaints compared to the previous year, along with close to 700 reported data breaches affecting millions of Canadians.

This means if you’re using e-signature tools, you must ensure your solutions meet PIPEDA standards for consent, security, retention, and accountability, or risk regulatory breach and reputational harm.

That is why this article explains how PIPEDA applies to electronic signatures, what compliance looks like in practice, and what to consider when choosing an e-signature solution.

What is PIPEDA compliance and why is it important in e-signature

PIPEDA, the Personal Information Protection and Electronic Documents Act, is Canada’s federal law governing how businesses collect, use, and disclose personal information in commercial activities. 

It also gives legal recognition to electronic documents and signatures, so digital contracts and e-signatures can be as valid as paper ones when the law’s requirements are met.

PIPEDA is similar to the U.S.’ ESIGN law that recognizes electronic signatures as legally valid, however, PIPEDA adds strictier privacy obligations and accountable obligations.

Understanding e-signature under PIPEDA

Section 31(1) of PIPEDA, defined electronic signature as any letters, numbers, or symbols in digital form that are attached to or associated with an electronic document. This can include typed names, scanned signatures, or signatures drawn on a tablet. The law recognizes these signatures as valid if they are linked to the document and the signer in a way that demonstrates intent.

Because the definition of an electronic signature in PIPEDA is very broad, many forms of digital signing, such as typed names, clicks, or scanned marks, are legally recognized in Canada.

However, for documents where identity confirmation and tamper evidence are critical, a secure electronic signature may be required. A secure signature is a regulated type that must be created using technology or processes prescribed by regulations. It is designed to:

• Be unique to the signer
• Remain under the signer’s sole control
• Identify who signed
• Be linked to the document so any changes would be detectable

For this reason, choosing an e-signature tool that supports secure signature requirements is critical. A compliant solution demonstrates accountability, maintains audit trails, and safeguards personal information, giving businesses and their clients confidence in the security and legal validity of digital transactions.

10 PIPEDA principles your e-signature must follow to be valid

PIPEDA sets out its privacy obligations through ten Fair Information Principles, which are listed in Schedule 1 of the Act.

The principles apply to all personal information under the control of an organization, regardless of whether it is collected on paper, through an e-signature or document automation tool. When the Office of the Privacy Commissioner of Canada assesses PIPEDA compliance, it does so by evaluating an organization’s practices against these ten principles.

The sections below explains each of the principles and how they apply specifically to e-signature and document workflows. 

Principle 1: Accountability

When you use an e-signature provider, you remain accountable for the personal information they process on your behalf. If your provider experiences a data breach, has poor security practices, or misuses customer data, PIPEDA holds you responsible.

Before signing a contract with an e-signature vendor, review their privacy and security documentation. Ensure your service agreement includes confirmation that:

• They will only use customer data for providing the signing service
• Commitment to appropriate security safeguards
• Agreement to notify you immediately of security incidents
• Clarity on data storage locations
• Confirmation they will assist with access requests and data deletion when required

PIPEDA also requires organizations to designate an individual responsible for compliance. This is often a privacy officer or compliance lead who oversees how e-signature tools are used and ensures that personal information remains protected throughout the document lifecycle.

Principle 2: Identifying purposes

Before you collect any personal information through an e-signature workflow, identify why you're collecting it. This means your e-signature tool should let you clearly state what information you're collecting (name, email, signature, IP address) and why (to execute this agreement, verify identity, maintain legal records).

In practice, include a simple disclosure statement at the beginning of your signing workflow: "By signing electronically, you consent to us collecting your name, email address, and signature for the purpose of executing this agreement. Your information will be securely stored for [retention period] and will not be used for other purposes without your consent."

Principle 3: Consent

Under PIPEDA, organizations must obtain meaningful consent before collecting or using personal information. In practical terms, that means signers should know what information is being collected during the signing process and why.

With e-signatures, consent is usually tied to the act of signing itself. When someone signs electronically, they are agreeing to the collection and use of information like their name, email address, signature, and related audit data for the purpose of executing the agreement.

The key is visibility. Signers should see this information in clear, plain language before they sign, not buried in unrelated documents. E-signature tools support this principle by enabling clear disclosures and preserving evidence of intent through timestamps and audit records.

Principle 4: Limiting collection

Your document and e-signature tool should only collect personal information necessary for the signing process. There’s no need to request phone numbers, social profiles, or other data unless the agreement or process truly requires it.

Choose tools that let you configure what information is collected. For routine contracts, name and email might be sufficient. For higher-risk transactions, you might add IP addresses, timestamps, and authentication methods. The key is proportionality—match data collection to the actual need.

Principle 5: Limiting use, disclosure, and retention

Once someone signs a document, their personal information should only be used for the purpose you specified. If you collected it to execute a contract, don't add that email address to your marketing list without separate consent.

Your e-signature tool should keep signed documents in segregated storage with role-based access controls. Not everyone in your organization needs to see every signed document. Sales teams shouldn't access HR employment agreements. Customer service shouldn't browse financial contracts.

Additionally, PIPEDA requires you to retain personal information only as long as needed. For contracts, this might be the duration of the agreement plus the limitation period for legal claims. Your e-signature tool should let you set retention policies and automate deletion. Avoid tools that retain signed documents indefinitely with no expiration options.

Principle 6: Accuracy

The personal information you collect during e-signature workflows should be accurate and current. Your tool should allow signers to review and confirm their information before finalizing. If someone notices their email address or name is incorrect, they should be able to correct it before signing.

After signing, if errors are discovered, you need a process to update records. This ties into Principle 9 (Individual Access), but the focus here is ensuring the information you're relying on is actually correct.

Principle 7: Safeguards

This is where most businesses focus their compliance efforts, and rightfully so. Your e-signature tool must protect personal information from unauthorized access, disclosure, loss, or theft.

Choose a tool with encryption at rest and in transit. Documents and signatures should be encrypted when stored and when transmitted. Ensure the tool provides secure authentication options—at minimum email verification, and for higher-risk documents, multi-factor authentication or knowledge-based authentication.

Confirm the provider has documented security practices, regular security audits, and incident response procedures. If they experience a breach, you need to know immediately so you can meet PIPEDA's breach notification requirements.

Principle 8: Openness

PIPEDA requires openness about how you handle personal information. Update your privacy policy to mention that you use electronic signatures and disclose how the signing process works.

Specifically, explain that you use a third-party e-signature provider (name them), what personal information is collected during signing, where that information may be stored (Canada, US, EU, etc.), how long you retain signed documents, and how signers can access or request corrections. 

Most businesses add a brief section titled "Electronic Signatures and Document Execution" to their privacy policies. This doesn't need to be lengthy—two or three paragraphs covering these points is sufficient just like what Lendingloop’s privacy did:

Principle 9: Individual access

Under PIPEDA, individuals have the right to access their personal information and request corrections. Your e-signature tool should make it straightforward to retrieve a copy of a signed document and its associated metadata when someone requests it.

This doesn't require a self-service portal (though some tools offer this). It means when someone emails asking "What did I sign last month?" or "Can you update the email address on file?", you should be able to quickly access their records, provide copies, and make corrections without escalating to your IT team.

Principle 10: Challenging compliance

Individuals must be able to challenge your compliance with PIPEDA principles. In practice, this means having a clear point of contact, usually your designated privacy officer or accountability contact from Principle 1, and a documented process for handling privacy complaints or concerns.

Your privacy policy should state how individuals can contact you with privacy questions or complaints. When someone does raise a concern about how their signing data was handled, you need to investigate and respond promptly.

How Docupilot helps achieve PIPEDA compliance

Now that you understand the 10 principles, which tools make compliance easier? Docupilot, a document automation and e-signature tool, is designed with features and privacy commitments that support PIPEDA compliance:

Let’s see how: 

• Audit trail: Every document you create, send, access, sign, and store generates a detailed, immutable audit log. You can see who did what, when, from where, and with what authentication, giving you the evidence PIPEDA expects 
• Role-based access: Set permissions by document type, department, role, or custom rules to ensure sensitive signed documents are only visible to people who need them
• Automated retention policies: Transaction data is deleted automatically within 24 hours, and you can shorten this to as little as 30 minutes. After a workspace expires, service data is retained for up to six months, giving you time to restore or reactivate if needed
• Transparent data processing: Docupilot stores data on secure servers and clearly discloses where it is held and how it may cross borders. For example, data may be processed in the United States, with safeguards in place to protect it
• Easy access and correction: Docupilot lets you store signed documents in your repository of choice like Google Drive, so that you can quickly access and correct personal data when needed
• Customizable consent and disclosure: You can edit all document templates in Docupilot to include custom consent language or add it to your email message, when configuring your automatic e-signature delivery, to diclose what personal information you're collecting, why, and how it will be used
• Vendor accountability: Docupilot’s Terms and Data Processing Agreement commit to processing personal information only as you instruct, maintaining appropriate safeguards, notifying you of security incidents, and supporting your compliance with access and deletion requests

Ready more about Docupilot’s privacy and terms here: 

https://www.docupilot.com/terms-and-conditions 

https://www.docupilot.com/privacy-policy 

PIPEDA compliance as a business advantage

PIPEDA compliance for e-signatures isn’t just a checkbox—it shows your customers, partners, and regulators that you take privacy seriously and have built workflows to protect the personal information they trust you with. This builds trust that strengthens business relationships.

Choosing the right e-signature tool is key. Platforms designed with compliance as a core principle make meeting PIPEDA automatic, while tools treating it as an afterthought create workarounds and manual processes.

Docupilot was built for the former. Its document automation and e-signature features balance efficiency with accountability, so you can focus on business while staying compliant. 

Ready to start creating secure, compliant documents and signatures? Sign up for a 30-day free trial today!