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Federal (Canada) Privacy Decisions

Browse privacy decisions from Federal (Canada) — with AI-generated plain-language summaries for every ruling.

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Federal (Canada)Personal Information Protection and Electronic Documents ActWell-founded & resolved
Jan 26, 2023PIPEDA Findings #2023-001· Indexed Apr 12, 2026

PIPEDA Findings #2023-001: Investigation into Home Depot of Canada Inc.’s compliance with PIPEDA

Home Depot of Canada Inc.

The Office of the Privacy Commissioner of Canada investigated Home Depot for disclosing customer email addresses and purchase details to Meta (Facebook) through Meta's "Offline Conversions" tool without valid consent. Home Depot used this tool to measure the effectiveness of its Facebook ads. The OPC found that Home Depot's privacy statement and Meta's policy were insufficient to obtain implied consent for this disclosure, as customers were not reasonably expected to understand that their data would be shared for these secondary purposes. Home Depot has since discontinued the use of the tool and agreed to implement recommendations for obtaining express consent should they restart the practice.

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Personal Information Protection and Electronic Documents ActWell-founded & resolved

PIPEDA Findings #2023-001: Investigation into Home Depot of Canada Inc.’s compliance with PIPEDA

Jan 26, 2023PIPEDA Findings #2023-001
Adjudicator: Philippe Dufresne
Plain-Language Summary

The Office of the Privacy Commissioner of Canada investigated Home Depot for disclosing customer email addresses and purchase details to Meta (Facebook) through Meta's "Offline Conversions" tool without valid consent. Home Depot used this tool to measure the effectiveness of its Facebook ads. The OPC found that Home Depot's privacy statement and Meta's policy were insufficient to obtain implied consent for this disclosure, as customers were not reasonably expected to understand that their data would be shared for these secondary purposes. Home Depot has since discontinued the use of the tool and agreed to implement recommendations for obtaining express consent should they restart the practice.

Key Issues
  • Whether Home Depot obtained valid consent for disclosing customer purchase data to Meta.
  • Whether the information disclosed was sensitive.
  • Whether Home Depot's privacy statement and Meta's policies provided sufficient notice and clarity.
  • Whether express opt-in consent should have been obtained.