BreachOfPrivacy
Decisions/Federal (Canada)/Personal Information Protection and Electronic Documents Act/PIPEDA Report of Findings #2018-006: Breach of the World Anti-Doping database
Office of the Privacy Commissioner of CanadaPersonal Information Protection and Electronic Documents ActPIPEDA Report of Findings #2018-006Well-founded & conditionally resolved
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PIPEDA Report of Findings #2018-006: Breach of the World Anti-Doping database

Organization: World Anti-Doping Agency (WADA)
Decision: Feb 7, 2018Published: Feb 7, 2018

This investigation examined a breach of WADA's Anti-Doping Administration and Management System (ADAMS) database, which resulted in the public disclosure of athletes' personal information, including health details. The OPC found that WADA's security safeguards were insufficient, contravening PIPEDA principles. While WADA committed to implementing recommendations, including enhanced security measures, the matter was resolved conditionally pending compliance.

  • Sufficiency of security safeguards for sensitive personal information
  • Access controls and authentication mechanisms for the ADAMS database
  • Monitoring, logging, and incident response capabilities
  • Policies, procedures, and training related to information security

Complaint well-founded and conditionally resolved

WADA failed to implement security safeguards appropriate to the sensitivity of the data, including insufficient access controls and a lack of robust authentication, leading to unauthorized access and disclosure of athletes' personal information.

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Recommended action / remedy

WADA agreed to implement recommendations to augment its security safeguards, including developing a comprehensive Information Security framework, implementing mandatory two-factor authentication for non-athlete users, updating contractual arrangements with ADOs, and employing encryption at rest for ADAMS data.

Statutory provisions cited
  • Principles 4.7 PIPEDA
  • Principle 4.7.1 PIPEDA
  • Principle 4.7.2 PIPEDA
  • Principle 4.7.3 PIPEDA
  • Principle 4.1.4 PIPEDA
  • subsection 11(2) PIPEDA
  • subsection 4(1.1) PIPEDA
  • Schedule 4 PIPEDA

This summary is informational only and not legal advice.