Early resolved case summary #2013-01: Property management company alters its rental application form to make clear that Social Insurance Number is optional
An individual complained that a property management company was over-collecting personal information on rental application forms, specifically requesting Social Insurance Numbers (SINs), driver's licence information, and banking details as a condition of application. The complainant also noted the absence of a privacy policy on the company's website. The OPC contacted the company, which stated its website was under construction and would include a privacy policy. The company used third-party generated forms and believed SINs were necessary for credit checks, a point the OPC disputed. The OPC suggested marking SIN requests as 'optional' and advised against collecting unique driver's licence numbers. The company committed to updating its forms and website, satisfying the complainant. The OPC later confirmed these changes were implemented.
- 1Whether the collection of Social Insurance Numbers (SINs) was appropriate
- 2Whether the collection of driver's licence numbers was appropriate
- 3Whether the collection of banking information was appropriate
- 4Whether the organization made its privacy policy readily available as required by PIPEDA
- Collection of SINs: Institution agreed to make SIN collection optional
- Collection of driver's licence: Institution agreed to stop collecting unique driver's licence numbers
- Collection of banking details: No finding on banking details collection
- Privacy policy availability: Institution agreed to publish privacy policy
- Resolution of complaint: Complaint resolved
Complaint early resolved
The complaint was resolved early in the investigation after the property management company committed to making the requested changes to its rental application forms and website, satisfying the complainant.
The property management company committed to contacting the third party to ensure the application form made clear that the request for a SIN, driver's licence, and banking information was optional, and to providing a privacy policy on its website.
- Principle 4.3 PIPEDA
- Principle 4.8 PIPEDA
This summary is informational only and not legal advice.
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