Early resolved case summary #2017-001: Privacy obligations under PIPEDA apply to financial technology sector
A complainant sought to open an online financial investment account with a FinTech organization. To access the investment account management agreement, the complainant was required to provide personal information, some of which was sensitive. After reviewing the agreement, the complainant decided not to open an account and requested deletion of their personal information. The organization cited "regulatory requirements" for the collection. The OPC clarified that while regulatory requirements exist, they apply once an individual becomes a client, not before. The OPC advised the organization to revise its website so prospective clients could review the agreement without prior personal information disclosure. The organization agreed to revise its website and Privacy Policy, leading to an early resolution.
- 1Whether a FinTech organization can require personal information before a prospective client reviews terms and conditions
- 2Whether consent under PIPEDA is meaningful if personal information is collected before a user can review service agreements
- 3Whether regulatory requirements justify collecting personal information from prospective clients who do not proceed with opening an account
- Collection of personal information: Collection before client status deemed unnecessary
- Website revision: Organization agreed to revise website
- Privacy Policy revision: Organization agreed to revise Privacy Policy
- Complaint resolution: Early resolution achieved
Complaint early resolved
The organization agreed to revise its website and Privacy Policy to allow prospective clients to review terms without first providing personal information, satisfying the complainant and addressing the OPC's concerns about meaningful consent.
The organization agreed to revise its website and Privacy Policy to ensure prospective clients can review the management agreement without first providing personal information.
This summary is informational only and not legal advice.
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