PIPEDA Case Summary #2015-015: Roofing company takes measures to ensure sub-contractors follow its privacy policy
An individual complained that an estimator, subcontracted by a roofing company, disclosed his personal information to another roofing company without consent. The investigation found that the second roofing company was responsible for its estimator's actions and that there was a disclosure of personal information in contravention of PIPEDA. The second roofing company implemented a recommendation to establish agreements with subcontractors regarding privacy policies and training.
- Whether the subcontractor's actions were attributable to the organization.
- Whether personal information was disclosed without consent.
- Whether the disclosure exceeded the purposes for which the information was collected.
Complaint well-founded and resolved
The roofing company was responsible for the actions of its subcontractor, and a disclosure of the complainant's personal information occurred without knowledge or consent, contravening PIPEDA. The company resolved the matter by implementing measures to ensure subcontractors adhere to its privacy policy.
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The second roofer was required to establish an agreement under which subcontractors commit to adhere to the company's privacy policy and receive training.
- Principle 4.3 PIPEDA
- subsection 7(3) PIPEDA
This summary is informational only and not legal advice.