Federal (Canada) privacy & access decisions

An individual complained that a property management company was over-collecting personal information on rental application forms, specifically requesting Social Insurance Numbers (SINs), driver's licence information, and banking details as a condition of application. The complainant also noted the absence of a privacy policy on the company's website. The OPC contacted the company, which stated its website was under construction and would include a privacy policy. The company used third-party generated forms and believed SINs were necessary for credit checks, a point the OPC disputed. The OPC suggested marking SIN requests as 'optional' and advised against collecting unique driver's licence numbers. The company committed to updating its forms and website, satisfying the complainant. The OPC later confirmed these changes were implemented.

• Whether the collection of Social Insurance Numbers (SINs) was appropriate
• Whether the collection of driver's licence numbers was appropriate
• Whether the collection of banking information was appropriate
• Whether the organization made its privacy policy readily available as required by PIPEDA