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Federal (Canada)Personal Information Protection and Electronic Documents ActEarly-resolved

Early resolved case summary #9: Equipment store ends practice of photocopying driver’s licences as a condition of renting equipment - October 30, 2014

Organization: An equipment storeComplainant: Anonymous applicant
Plain-language brief

An individual complained that an equipment store required a scanned copy of his driver's license and a photograph as a condition for renting equipment. The store justified this practice by citing past losses of expensive rental equipment. The OPC informed the store that collecting driver's license information in this manner was generally inappropriate due to the excessive personal information contained on the license and its limited value in theft investigations. The OPC provided guidance on appropriate collection practices. As a result of the OPC's intervention, the store implemented a less privacy-invasive solution and trained its staff. The complainant was satisfied with the outcome.

Key issues
  1. 1Whether requiring a scanned copy of a driver's license and a photograph for equipment rental constitutes appropriate collection of personal information under PIPEDA
  2. 2Whether the collection of driver's license information is justified for addressing customer theft
Outcome breakdownFavours: Applicant / complainant
  • Collection of personal information: Practice found inappropriate
  • Guidance on collection practices: OPC provided guidance
  • Remedial action by institution: Less privacy-invasive solution implemented
  • Staff training: Staff trained on new practices
  • Complaint resolution: Complainant satisfied
Outcome

Complaint early resolved — store changed practices

Reasoning

The complaint was resolved early in the investigation after the OPC provided guidance to the organization, leading to a change in its practices that satisfied the complainant.

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Decision notes
Recommended action / remedy

The equipment store implemented a new, less privacy-invasive solution for customer identification during equipment rental and provided staff training.

This summary is informational only and not legal advice.

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