
Commissioner’s Findings - PIPEDA Report of Findings #2013-002: Bank misinformed client of purpose of requesting personal information for picking up credit card
A bank customer complained after being asked to provide his driver's license to pick up a replacement credit card, despite having other identification on file and being known to staff. The bank initially cited anti-money laundering regulations (PCMLTFA) but later admitted this rationale was incorrect. The OPC investigated two issues: whether the bank improperly demanded to record information (collection) and whether it could explain the purpose of collection. Since the customer refused to provide his driver's license, no actual collection occurred, so that aspect of the complaint was not well-founded. However, the bank's inaccurate explanation for requesting the information contravened Principle 4.2.5. The bank revised its procedures and circulated new guidelines to staff, leading to a well-founded and resolved outcome for the latter issue.
- 1Whether the bank limited its collection of personal information to that which was necessary for the purposes identified by the organization (Principle 4.4 PIPEDA)
- 2Whether the bank ensured its employees were able to explain the purposes for which personal information was being collected (Principle 4.2.5 PIPEDA)
- Collection of information: Not well-founded (no collection occurred)
- Purpose of collection: Well-founded and resolved (bank revised procedures)
Collection complaint not well-founded; identifying purposes complaint well-founded and resolved
The collection complaint was not well-founded because the bank did not actually collect the driver's license information. The identifying purposes complaint was well-founded because the bank's employee provided an inaccurate explanation for the collection, but it was resolved as the bank revised its procedures and trained staff.
The bank revised its procedure for credit card pickup to limit recorded information when identification on file meets anti-money laundering requirements and committed to circulating this information to staff.
- Principle 4.4 PIPEDA
- Principle 4.2.5 PIPEDA
This summary is informational only and not legal advice.
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