Case Study Law 25 March 2026

Athena Collective: Law 25 compliance without replacing a single tool

Athena Collective × Upper Harbour

By Joshua van Es, Founder of Upper Harbour

A Canadian startup mapped its entire SaaS stack to parent jurisdictions, identified its CLOUD Act exposure, and produced defensible Law 25 documentation — in weeks, not months.

At a glance
11
SaaS tools
assessed
9
TIAs
produced
~$20K
Saved vs.
consultants
0
Tools
replaced

The situation

Athena Collective is a platform for women founders, offering personalized business assessments, a searchable member directory, and community tools. Hundreds of members across Canada share personal information through the platform — skills assessments across 212 areas, profiles searchable by stage, industry, and location, and direct community interactions.

That's a lot of personal data flowing through a SaaS stack. Co-founder Mikayla Stewart had already made a smart infrastructure choice: hosting on DigitalOcean's Toronto region, keeping core application data in Canada. But with Law 25 in effect since September 2023, she needed to document the full jurisdictional picture — not just where data is stored, but who can be legally compelled to produce it.

The alternative was expensive. Privacy consultants typically charge $15,000–$40,000 for a full Law 25 compliance engagement. Individual TIAs from law firms run $2,000–$5,000 per tool — for 9 cross-border tools, that's $18,000–$45,000 in legal fees alone. Doing it internally means 20–30+ hours of research before any documentation gets written.

What the scan revealed

Athena Collective ran a HarbourScan, mapping all 11 tools against Upper Harbour's 715-tool sovereignty database.

Athena Collective — jurisdictional map
DigitalOceanCloud infrastructureUS
Auth0AuthenticationUS
StripePaymentsUS
ResendEmail APIUS
MixpanelAnalyticsUS
GitHubCode repositoryUS
Google WorkspaceProductivityUS
ClickUpProject managementUS
SlackCommunicationUS
SageAccountingUK
HubSpotCRMUS
10 of 11 tools are operated by companies incorporated outside Canada. This is typical — in our database, 63% of commonly used tools are US-parented.
11
tools scanned
4
jurisdictions
9
TIAs produced
1
compliance record

Why DigitalOcean Toronto wasn't enough

Mikayla's choice to host in Toronto keeps core data — databases, file storage, compute — physically in Canada. That's a meaningful starting point.

But DigitalOcean is US-incorporated. Under the CLOUD Act, US law enforcement can compel data production regardless of server location. Canadian residency creates friction, but it doesn't close the legal question. This is exactly the nuance Law 25 documentation captures: here's the residency configuration, here's the jurisdictional reality, and here's the assessed risk.

Mikayla Stewart, Co-Founder of Athena Collective
We were quoted $20,000+ from a privacy consultant. I looked into doing it myself and realized I'd spend weeks just understanding what a Transfer Impact Assessment needs to include. The sovereignty audit gave us everything — the jurisdictional map, the TIAs, the full compliance record — for a fraction of the cost.
Mikayla Stewart, Co-Founder · Athena Collective

What was delivered

📋
Jurisdictional mapEvery tool traced to parent company, incorporation country, and legal frameworks.
📑
Transfer Impact AssessmentsTIAs for each cross-border tool, as required by Law 25.
🔍
DPA gap analysisData Processing Agreement review with remediation plan.
📊
Board-ready compliance recordSingle document for regulators, clients, or procurement.

The takeaway

Law 25 doesn't require you to replace your SaaS tools. It requires you to document them.

Athena Collective kept every tool in its stack. What changed was the paper trail — a structured record showing that jurisdictional exposure has been identified, assessed, and documented. That's what compliance looks like in practice.

Looking ahead

The proposed federal Consumer Privacy Protection Act (CPPA) would extend similar documentation requirements nationally. Organizations that document now are building on solid ground.

Common questions

Does Law 25 require me to stop using US SaaS tools?
No. It requires Transfer Impact Assessments and evidence that you've assessed the jurisdictional implications. You can continue using US-parented tools with proper documentation.
Is Canadian data residency enough?
Strong starting point, not a finish line. Residency determines where data is stored. Jurisdiction determines who can legally compel its production. Law 25 requires you to document both.
How long does this take?
HarbourScan takes about 10 minutes. The full sovereignty audit — TIAs, DPA analysis, compliance record — is typically delivered within weeks.

Map your jurisdictional exposure.

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