Commissioner’s Findings - PIPEDA Report of Findings #2014-012: Investment Firm Justified in its Collection of "Know Your Client" Information
A customer complained that his investment firm required an unreasonable amount of personal information on its "Know Your Client" (KYC) form as a condition for maintaining his Tax Free Savings Account (TFSA) and Registered Retirement Savings Plan (RRSP). The firm requested details such as investment experience, annual income, spouse's income, dependents, assets, liabilities, and net worth. The firm argued this information was necessary to comply with the Investment Industry Regulatory Organization of Canada (IIROC) KYC and suitability requirements. The OPC assessed whether the firm contravened PIPEDA Principle 4.3.3 by requiring consent for information beyond explicitly specified and legitimate purposes. The OPC found that the firm had explicitly specified its purposes, which were legitimate given IIROC's regulatory framework. The OPC also concluded that the requested information, including details beyond IIROC's standard Form 2, was necessary for the firm to meet its regulatory obligations. Therefore, the complaint was not well-founded.
- 1Whether the investment firm explicitly specified the purposes for collecting personal information under Principle 4.2 PIPEDA
- 2Whether the purposes for collecting personal information were legitimate under subsection 5(3) PIPEDA
- 3Whether the investment firm required more personal information than necessary to achieve the legitimate purposes as a condition of service under Principle 4.3.3 PIPEDA
- 4Whether the collection of personal information was limited to that which was necessary for the identified purposes under Principle 4.4 PIPEDA
- 5Whether information on investment experience was necessary to validate investment knowledge and assess risk tolerance
- 6Whether spouse's or partner's annual income was necessary to assess overall financial position and suitability
- 7Whether detailed assets and liabilities were necessary to establish net worth and understand financial situation
- Collection of personal information: Information collected was for legitimate purposes
- Necessity of information: Information collected was necessary for regulatory obligations
- PIPEDA Principle 4.3.3: No contravention found
- Complaint outcome: Complaint not well-founded
Complaint not well-founded
The OPC found that the investment firm explicitly specified legitimate purposes for collecting the information, which were rooted in IIROC's regulatory requirements. The OPC also determined that the specific information requested, including details beyond standard forms, was necessary for the firm to fulfill its KYC and suitability obligations.
- Principle 4.2 PIPEDA
- Principle 4.3.3 PIPEDA
- Principle 4.4 PIPEDA
- s.5(3) PIPEDA
This summary is informational only and not legal advice.
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