Federal (Canada)Personal Information Protection and Electronic Documents ActWell-founded & conditionally resolved

Compliance Letter to the Office of the Privacy Commissioner of Canada (“OPC”) By WestJet, an Alberta Partnership (“WestJet”)

Organization: WestJet
Plain-language brief

The Office of the Privacy Commissioner of Canada (OPC) launched a Commissioner-initiated investigation (CII) into a privacy breach at WestJet that occurred on June 12, 2025. An unauthorized third party gained access to an employee's administrative account, bypassed multi-factor authentication, deployed ransomware, and exfiltrated data affecting approximately 5.1 million Canadian employees and customers. The breach exposed names, dates of birth, email addresses, mailing addresses, phone numbers, gender, travel booking information, and passport details, but no credit card numbers or SINs. WestJet took immediate containment measures, reported the breach, and provided direct and indirect notifications, credit monitoring, and identity theft protection services. WestJet has committed to further actions, including an external security assessment and providing a summary report to the OPC by August 7, 2026, to ensure the adequacy of its updated security safeguards and prevent future breaches. The CII will be discontinued upon the Commissioner being satisfied that WestJet has fulfilled all commitments.

Key issues
  1. 1Adequacy of security safeguards under PIPEDA
  2. 2Adequacy of notifications to affected individuals under PIPEDA
  3. 3Whether WestJet's post-breach remediation actions and future commitments provide a fair and reasonable response to the incident
Outcome breakdownFavours: Both, in part
  • Privacy breach finding: Breach confirmed
  • Containment measures: Measures taken immediately
  • Notification adequacy: Direct and indirect notifications provided
  • Mitigation services: Credit monitoring and identity theft protection offered
  • Future security commitments: WestJet committed to external assessment and report
  • Investigation status: CII to be discontinued upon commitment fulfillment
Outcome

Commissioner-initiated investigation conditionally resolved pending fulfillment of commitments

Reasoning

The OPC found that WestJet experienced a significant data breach due to inadequate security safeguards and has committed to a series of corrective actions, including an external security assessment, to address the identified issues and prevent future breaches. The investigation will be discontinued upon satisfactory completion of these commitments.

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Decision notes
Recommended action / remedy

WestJet committed to providing a confidential summary report of an external security assessment by August 7, 2026, outlining safeguard enhancements, effectiveness assessment, identified gaps, and recommended solutions, and to inform the Commissioner by September 7, 2026, on the acceptance and implementation status of these recommendations.

Statutes considered
  • s.11(2) PIPEDA
  • s.12.2(1)(c) PIPEDA
  • s.13 PIPEDA
  • s.20 PIPEDA

This summary is informational only and not legal advice.

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