Settled case summary #21 — A loyalty program

An individual complained that a loyalty program had provided his children's names and addresses to its partner credit card companies, resulting in the children receiving unsolicited marketing materials. The issue arose because the loyalty program did not record the dates of birth for its minor members, meaning they were not identified as minors in its system. Although the program updated the children's profiles and removed their information from the system, ongoing marketing mailings persisted for a period due to advance list generation.

• Disclosure of children's personal information to third parties for marketing purposes.
• Failure to identify and protect the personal information of minors.
• Unreasonable delay in resolving the issue and stopping marketing mailings.