Federal (Canada)Privacy ActNot well-founded

Canada Post collection of online signatures for mail tracking draws complaint

Organization: Canada Post CorporationComplainant: Anonymous applicant
Plain-language brief

A complaint was filed against Canada Post Corporation (CPC) regarding its collection, use, and disclosure of electronic signatures for parcel tracking. The complainant raised concerns about the clarity of information provided to addressees regarding their option to opt-out of having their signature displayed online, and the absence of labels on signature devices at a specific postal outlet. The investigation also examined the privacy and security controls of CPC's online tracking website. CPC argued that disclosure of signatures to senders was authorized under the Privacy Act and that it provided an opt-out option. The OPC found that the collection and disclosure of signatures for parcel tracking were consistent with the Act, but raised concerns about the adequacy of security controls for online signatures. CPC committed to implementing enhanced security measures.

Key issues
  1. 1Whether the collection of electronic signatures by CPC contravenes the Privacy Act
  2. 2Whether the disclosure of electronic signatures to the sender of a parcel contravenes the Privacy Act
  3. 3Whether the disclosure of electronic signatures online contravenes the Privacy Act
  4. 4Whether CPC adequately safeguards digitized signatures displayed online
  5. 5Whether the information provided to addressees about opting out of online signature display is sufficiently clear
Outcome breakdownFavours: Both, in part
  • Collection of signatures: Consistent with Act
  • Disclosure of signatures: Consistent with Act
  • Clarity of opt-out information: Concerns raised
  • Absence of labels on devices: Concerns raised
  • Security of online signatures: Concerns raised
  • Security enhancements: Commitment obtained
Outcome

Complaint not well-founded regarding collection and disclosure; conditionally resolved regarding security safeguards.

Reasoning

The OPC found that the collection and disclosure of signatures for parcel tracking were consistent with the Privacy Act. However, CPC's security controls for online signatures were deemed inadequate, leading to recommendations that CPC committed to implementing.

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Decision notes
Recommended action / remedy

The OPC requested Canada Post Corporation to follow up in 6 months to confirm progress in implementing enhanced privacy and security controls for online signatures. The OPC also reminded CPC to ensure consistency in affixing labels to signature devices and to ensure staff are knowledgeable about signature procedures.

Statutes considered
  • s.3 Privacy Act
  • s.4 Privacy Act
  • s.7(a) Privacy Act
  • s.8(1) Privacy Act
  • s.8(2)(a) Privacy Act

This summary is informational only and not legal advice.

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