Federal (Canada)Personal Information Protection and Electronic Documents ActResolved

Incident Summary #10: Cable provider removes personal information posted online of customers with overdue accounts

Organization: A cable provider
Plain-language brief

The OPC was alerted to a cable provider posting a list of customers with overdue accounts and the amounts owed on a municipal Facebook page. The cable provider believed this practice was permissible, citing municipal tax arrears publications as an example. The OPC informed the provider that publicly disseminating personal information for debt collection without consent is not permitted under PIPEDA, even though disclosure to a third-party debt collector may be. The cable provider subsequently removed the posting. The OPC also clarified with the NWT Commissioner that municipal tax arrears publications are mandated by territorial law, unlike the cable provider's actions. The OPC explained that PIPEDA's debt collection exemption does not authorize public disclosure.

Key issues
  1. 1Whether publicly posting customer debt information on social media is permissible under PIPEDA
  2. 2Whether the debt collection exemption under paragraph 7(3)(b) of PIPEDA authorizes public dissemination of personal information
  3. 3Whether municipal practices of publishing tax arrears are comparable to private organizations publishing customer debt under PIPEDA
Outcome breakdownFavours: Applicant / complainant
  • Public disclosure of debt: Practice found impermissible under PIPEDA
  • PIPEDA debt collection exemption: Does not authorize public disclosure
  • Comparison to municipal tax arrears: Distinguished as legally mandated
  • Removal of posting: Provider removed the posting
Outcome

The cable provider removed the posting after OPC intervention.

Reasoning

The OPC intervened early in the incident, and the cable provider voluntarily removed the offending post, resolving the issue before a formal investigation or finding was necessary.

AI-generated summary for reference only. Always verify against the official decision ↗
Decision notes
Recommended action / remedy

The cable provider removed the posting of customers' personal information from the Facebook page.

Statutes considered
  • paragraph 7(3)(b) PIPEDA

This summary is informational only and not legal advice.

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