BreachOfPrivacy
Decisions/Federal (Canada)/Personal Information Protection and Electronic Documents Act/Commissioner’s Findings - PIPEDA Case Summary #2014-007 : Apple called upon to be more open about its collection and use of information for downloads
Office of the Privacy Commissioner of CanadaPersonal Information Protection and Electronic Documents ActCommissioner’s Findings - PIPEDA Case Summary #2014-007Well-founded & conditionally resolved
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Commissioner’s Findings - PIPEDA Case Summary #2014-007 : Apple called upon to be more open about its collection and use of information for downloads

Organization: Apple Canada Inc.Complainant: An individual
Decision: Apr 22, 2014Published: Apr 22, 2014

The complainant alleged that Apple Canada Inc. ("Apple") unnecessarily required payment information and date of birth for downloading a free application. The investigation found that while the date of birth collection was acceptable for authentication, Apple's privacy policy did not fully identify the purposes for its collection. The collection of payment information was also found to be an issue, as Apple did not clearly communicate that it was not required for downloading free applications. Apple agreed to revise its privacy policy and implement recommendations to improve clarity and user experience.

  • Identification of purposes for collection of personal information
  • Limiting collection of personal information to what is necessary
  • Openness about information management policies and practices
  • Requirement of payment information for free application downloads

Complaint partly well-founded and conditionally resolved, with Apple agreeing to implement recommendations.

Apple's privacy policy did not fully identify the purposes for collecting the date of birth, and the company did not clearly communicate that payment information was not required for downloading free applications, leading to potential over-collection. Apple committed to making changes to address these issues.

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Recommended action / remedy

Apple agreed to revise its privacy policy to identify purposes for collecting date of birth and to clearly communicate that payment information is not required for downloading free applications, including offering an option to proceed without payment details at registration.

Statutory provisions cited
  • Principle 4.1 PIPEDA
  • Principle 4.2 PIPEDA
  • Principle 4.8 PIPEDA

This summary is informational only and not legal advice.