PIPEDA Case Summary #2002-82: Alleged disclosure of personal information without consent for secondary marketing purposes by a bank

An individual complained that a bank failed to obtain adequate consent for using and sharing customer data with affiliates for secondary marketing purposes, arguing the bank did not clearly inform customers or provide an easy opt-out mechanism. The Office of the Privacy Commissioner of Canada (OPC) investigated and found the bank's practices and materials, including informing customers of privacy policies and providing an opt-out process, constituted a reasonable effort to ensure customer knowledge and consent. The OPC concluded the bank was in compliance with PIPEDA principles regarding secondary marketing.

• Adequacy of consent for secondary marketing purposes
• Clarity of information provided to customers about data use and sharing
• Availability and ease of the opt-out process
• Bank's compliance with PIPEDA principles on knowledge and consent