BreachOfPrivacy
Decisions/Federal (Canada)/Personal Information Protection and Electronic Documents Act/Early resolved case summary #2017-003: Bank agrees to cease performing credit checks on individuals who are no longer clients
Office of the Privacy Commissioner of CanadaPersonal Information Protection and Electronic Documents ActEarly resolved case summary #2017-003Early-resolved
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Early resolved case summary #2017-003: Bank agrees to cease performing credit checks on individuals who are no longer clients

Organization: A bank
Decision: Jul 5, 2017Published: Jul 5, 2017

An individual complained that a bank performed multiple credit checks on her without her consent, even though she had not been a client for many years. The bank initially stated the inquiries were from its marketing group but later found they originated from an unactivated credit card application. While the bank’s policy suggested it could continue soft credit inquiries after a relationship ended, the OPC expressed concerns about this practice. The bank agreed to end the practice and update its privacy policy, leading to the complaint being early resolved. The OPC confirmed the practice has ceased and the policy has been updated.

  • Consent for credit checks after termination of a business relationship
  • Continued collection of sensitive personal information without a legal requirement
  • Accuracy and completeness of information provided to individuals about data handling practices

Complaint early resolved

The bank agreed to end its practice of performing credit checks on former clients and update its privacy policy, resolving the complainant's concerns and satisfying the OPC's concerns about continued data collection without a clear purpose or legal requirement.

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Recommended action / remedy

The bank agreed to cease performing credit checks on individuals who are no longer clients and to update its privacy policy.

This summary is informational only and not legal advice.