Federal (Canada)Personal Information Protection and Electronic Documents ActResolved

Incident Summary #5: Life insurance company employs best practices in responding to mass mailing error that risked exposing personal information - March 21, 2014

Organization: A life insurance company
Plain-language brief

A life insurance company discovered that a mass mailing error risked exposing the personal information of 53 pension plan members. The new window envelopes used were larger, potentially revealing certificate numbers, SINs, dates of birth, spouse's names, and beneficiaries if statements shifted. Upon discovering the incident, the company promptly notified affected individuals, apologized, explained the incident, and offered a free one-year credit monitoring service. They also advised members to take harm-reducing steps and ceased using the problematic envelopes. The company informed the OPC about the incident and its response. The OPC concluded that the company demonstrated best practices in its incident response.

Key issues
  1. 1Whether a mass mailing error led to the potential exposure of personal information
  2. 2Whether the life insurance company's response to the incident constituted best practices
Outcome breakdownFavours: Institution
  • Personal information exposure: Risk of exposure identified
  • Incident notification: Affected individuals notified
  • Remedial actions: Credit monitoring offered
  • Preventative measures: Problematic envelopes ceased
  • OPC assessment: Best practices demonstrated
Outcome

Best practices implemented in response to incident

Reasoning

The OPC did not conduct a formal investigation or make a finding of contravention. Instead, it noted the company's proactive and comprehensive response to the incident, which included notifying affected individuals, offering credit monitoring, and implementing preventative measures.

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