← Back to catalogue/Federal (Canada)Early resolved case summary #10
Federal (Canada)Personal Information Protection and Electronic Documents ActResolved

Early resolved case summary #10: Bank improves its credit card account verification practices after challenge from customer - February 20, 2014

Organization: A financial institutionComplainant: Anonymous applicant
Plain-language brief

An individual complained that her bank required the last six digits of her Social Insurance Number (SIN) to set up a "verified credit account" for online purchases. She believed this practice was inappropriate and that an alternative method not requiring SIN information should be available. The bank initially stated an alternative existed through commercial websites, but the complainant noted this was not clearly communicated. The OPC highlighted a comparable case where a lack of transparency regarding authentication alternatives was found. Following this, the bank decided to discontinue the SIN-based authentication method entirely and update its website. The complainant was satisfied with this resolution, and the OPC confirmed the website changes.

Key issues
  1. 1Whether collecting a partial SIN for credit card account verification was appropriate under PIPEDA
  2. 2Whether the bank provided adequate transparency regarding alternative verification methods
Outcome breakdownFavours: Applicant / complainant
  • Collection of SIN: Practice discontinued
  • Transparency of alternatives: Website updated
  • Complaint resolution: Satisfactorily resolved
Outcome

Complaint early resolved — bank discontinued SIN-based authentication

Reasoning

The bank reconsidered its position after the OPC brought a comparable finding regarding transparency to its attention, leading to the discontinuation of the problematic authentication method.

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Decision notes
Recommended action / remedy

The bank discontinued the practice of requiring a partial SIN for credit card account verification and modified its website accordingly.

This summary is informational only and not legal advice.

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