Executive Summary: Privacy Commissioner of Canada v. SWIFT

This investigation concerned allegations that SWIFT inappropriately disclosed personal information from Canadian financial institutions to the US Department of the Treasury (UST) via administrative subpoenas. The Privacy Commissioner of Canada determined that SWIFT was subject to PIPEDA due to its operations in Canada and its commercial activities involving Canadian banks. While SWIFT disclosed data held in the US to the UST in response to a subpoena, the Commissioner found this disclosure was permissible under the Act's exceptions to consent.

• Whether SWIFT is subject to PIPEDA
• Whether SWIFT inappropriately disclosed personal information to the UST
• Applicability of PIPEDA exceptions to disclosure in response to a subpoena