Commissioner’s Findings - PIPEDA Report of Findings #2013-003: Profiles on PositiveSingles.com dating website turn up on other affiliated dating websites
Three individuals complained that their dating profiles, containing sensitive medical information, posted on PositiveSingles.com appeared on numerous other affiliated dating websites without their knowledge or consent. The complainants were assured of privacy but found their profiles on sites targeting different demographics, causing distress. The OPC's investigation found that PositiveSingles.com, operated by SuccessfulMatch Inc., used a single database across a network of affiliated sites, making profiles automatically available. The OPC concluded that the organization failed to obtain meaningful consent for this use, lacked openness about its network structure, and had inadequate safeguards, as some personal information was accessible via search engines. Following the OPC's recommendations, SuccessfulMatch revamped its website to provide explicit information about the network, ensure informed consent at registration, and improve safeguards. The complaint was found well-founded and resolved due to these corrective measures.
- 1Whether PositiveSingles.com obtained meaningful consent for the use of personal information across its network of affiliated sites (Principle 4.3, 4.3.2, 4.3.5 PIPEDA)
- 2Whether PositiveSingles.com was sufficiently open about its personal information management policies and practices, particularly regarding its network structure (Principle 4.8, 4.8.1 PIPEDA)
- 3Whether PositiveSingles.com implemented adequate security safeguards to protect sensitive personal information from unauthorized access (Principle 4.7, 4.7.1 PIPEDA)
- 4Whether PositiveSingles.com's use of cookies, potentially for online behavioral advertising, required express consent given the sensitive nature of the information
- Consent for disclosure: Organization failed to obtain meaningful consent
- Openness: Organization lacked openness about network structure
- Safeguards: Organization had inadequate safeguards
- Complaint outcome: Complaint found well-founded and resolved
- Corrective measures: Organization implemented corrective measures
Complaint well-founded and resolved
The OPC found that SuccessfulMatch Inc. contravened PIPEDA Principles 4.3 (consent), 4.8 (openness), and 4.7 (safeguards) by failing to obtain meaningful consent for the use of sensitive personal information across its network of sites, not being transparent about its practices, and having insufficient security. The complaint was resolved after the organization implemented significant changes to address these deficiencies.
SuccessfulMatch revamped its website to explicitly inform users of the network relationship, promote informed consent at key decision points, confirm no disclosures to exterior third parties, and implement improved safeguarding measures.
- Principle 4.3 PIPEDA
- Principle 4.3.2 PIPEDA
- Principle 4.3.5 PIPEDA
- Principle 4.3.6 PIPEDA
- Principle 4.7 PIPEDA
- Principle 4.7.1 PIPEDA
- Principle 4.8 PIPEDA
- Principle 4.8.1 PIPEDA
This summary is informational only and not legal advice.
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