Commissioner’s Findings - PIPEDA Report of Findings #2013-017: Apple called upon to provide greater clarity on its use and disclosure of unique device identifiers for targeted advertising

The OPC investigated a complaint alleging Apple used and shared a user's unique device identifier (UDID) without knowledge or consent for tracking and targeted advertising. While Apple initially argued UDID was not personal information, the OPC found it was, especially given Apple's ability to link it to account details. The OPC determined Apple's privacy policy lacked clarity on UDID use for advertising, though its administrative uses were acceptable. Apple has since ceased using UDID for advertising, replacing it with Ad ID, and enhanced opt-out mechanisms for Ad ID, leading the OPC to find the complaint well-founded and resolved.

• Whether UDID and Ad ID constitute personal information under PIPEDA.
• Whether Apple obtained meaningful consent for the collection, use, and disclosure of UDID and Ad ID for advertising purposes.
• Adequacy of notice provided by Apple regarding its use of UDID and Ad ID.
• Apple's responsibility for disclosures of UDID and Ad ID to third-party app developers.