Federal (Canada)Personal Information Protection and Electronic Documents ActSettled

Settled Case summary: Credit check to open a personal deposit account - November 2004

Organization: A bankComplainant: Anonymous applicant
Plain-language brief

An individual complained that a bank inappropriately required a credit check and other personal information, including length of employment and Social Insurance Number (SIN), to open a no-fee personal deposit account online. The complainant also found the language regarding information exchange with credit bureaus unclear. The bank agreed to modify its online application forms to clarify that credit checks are optional for deposit accounts if applied for in person. It also agreed to only request length of employment for credit applications and make SIN provision optional. The bank committed to reviewing the language concerning credit bureau information exchange. The OPC confirmed the complainant's credit rating was unaffected. Both the complainant and the OPC were satisfied with the bank's actions.

Key issues
  1. 1Whether a credit check was appropriately required for a no-fee personal deposit account
  2. 2Whether length of employment was appropriately required for a no-fee personal deposit account
  3. 3Whether the Social Insurance Number (SIN) was appropriately required for a no-fee personal deposit account
  4. 4Whether the language describing information exchange with credit bureaus was clear
Outcome breakdownFavours: Applicant / complainant
  • Credit check requirement: Bank agreed to clarify optionality for in-person applications
  • Employment length request: Bank agreed to limit request to credit applications
  • SIN collection: Bank agreed to make SIN provision optional
  • Credit bureau language: Bank committed to reviewing language
  • Credit rating impact: OPC confirmed no impact
Outcome

Complaint settled — bank agreed to modify practices

Reasoning

The complaint was settled because the bank agreed to implement changes to its online application process and information collection practices that addressed the complainant's concerns.

AI-generated summary for reference only. Always verify against the official decision ↗
Decision notes
Recommended action / remedy

The bank agreed to modify its online account application forms to inform applicants that they can apply for a deposit account in person to avoid a credit check, to only require length of employment for credit applications, and to make the provision of the SIN optional. The bank also agreed to review the language on the form describing information exchange with credit bureaus.

This summary is informational only and not legal advice.

Pro · AI

Decisions with similar reasoning and facts — found by AI across statutes and jurisdictions, not just keywords.

Pro
Coverage — 13 of 14 jurisdictions searchable

Fully searchable: Ontario, British Columbia, Alberta, Saskatchewan, Newfoundland and Labrador, Northwest Territories, New Brunswick, Manitoba.

Partial (recent decisions only): Federal (Canada) (651 of 1,631), Nova Scotia (49 of 472), Quebec (6 of 7,090), Prince Edward Island (2 of 279), Yukon (1 of 75).

Coming soon: Nunavut — being re-processed for AI search.

Find decisions like this one — by meaning, not keywords.

Related by meaning is a Pro feature. Upgrade to surface conceptually similar decisions across the corpus, powered by AI.

Upgrade to Pro