Settled case summary #28 — A DVD-rental store
An individual complained that a DVD-rental store required him to provide his driver's license details for entry into their database to become a member, which he believed was unnecessary. The store initially argued this was a business necessity for identity verification and recovering overdue rentals. However, the investigation revealed the store did not use driver's license data for tracing members, but rather publicly available information. Recognizing it was collecting unnecessary information, the store revised its membership process. Under the new process, customers must present two pieces of identification, one with a photo, but driver's license details are no longer entered into the database. The store committed to updating its procedures and training staff on the new process.
- 1Whether collecting and recording driver's license details was necessary for the DVD-rental store's operations
- 2Whether the store's collection practices aligned with the principle of limiting collection to necessary information
- Collection of personal information: Collection deemed unnecessary
- Business practices: Store revised membership process
- Future compliance: Store committed to updating procedures and training
Complaint settled — store revised its membership application process
The complaint was settled after the investigation revealed the store was collecting personal information (driver's license details) that it did not actually use for its stated purposes, leading the store to revise its practices.
The DVD-rental store revised its membership application process to no longer require the entry of driver's license details into its database, instead requiring two pieces of identification, one with a photo, and only recording that photo identification was verified. The company also committed to reviewing the new process with staff and updating its procedures manual.
- Principle 4.4 PIPEDA
This summary is informational only and not legal advice
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