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Canadian Privacy Decisions

The comprehensive archive of Canadian privacy decisions from federal, provincial, and territorial commissioners — with AI-summarized plain-language summaries for every decision.

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Federal (Canada)Personal Information Protection and Electronic Documents ActWell-founded & resolved

Oct 16, 2019PIPEDA Findings #2019-003· Indexed Apr 12, 2026

PIPEDA Findings #2019-003: Investigation into authentication and transfer practices used during Loblaw gift card offering

Loblaw Companies Ltd.

This investigation examined Loblaw's practices in its gift card program, which was established to compensate customers affected by a bread price-fixing scandal. The complainant argued Loblaw collected more personal information than necessary and was concerned about data transfers to the United States. The OPC found that while Loblaw initially collected more information than needed by requesting full identification documents, they subsequently clarified their requirements, resolving this issue. The OPC also found Loblaw's measures to protect personal information transferred to a third-party administrator in the US were sufficient and that Loblaw was transparent about cross-border data transfers.

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Outcome Notes

Federal rulings come from two regulators with different statutory authority — outcome filters cover both.

OIC Order (ATIA s.36.1, binding) — Since June 2019 (Bill C-58) the Information Commissioner can issue binding orders requiring disclosure or reconsideration. Enforceable after 31/41 business days unless reviewed by the Federal Court (s.41).

Well-Founded — finding that the complaint is well-founded. For OIC: ATIA s.37(1)(a) finding (may be paired with a s.36.1 order). For OPC: Privacy Act s.35(1) / PIPEDA s.13(1) advisory finding — recommendations only, no binding order-making power. Includes well-founded, well-founded & resolved, well-founded & conditionally resolved, well-founded & unresolved.

Not Well-Founded — no contravention found.

s.6.1 Application— the OIC's response to a head's application for authorization to refuse a frivolous, vexatious, or bad-faith access request. Granted = institution may refuse; Denied = institution must respond.

Settled / Resolved / Early-resolved — OPC matter resolved during or before formal findings without a contravention finding.

Declined to investigate / No jurisdiction — Procedural close (Privacy Act s.34, PIPEDA discretion, or scope outside the Acts).

References: ATIA s.36.1 · OPC disposition definitions

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Breach of Privacy is the one-stop archive for Canadian privacy decisions from federal, provincial, and territorial commissioners. Each decision includes an AI-generated plain-language summary. Always verify against the official source document.

Canadian Privacy Decisions

PIPEDA Findings #2019-003: Investigation into authentication and transfer practices used during Loblaw gift card offering

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PIPEDA Findings #2019-003: Investigation into authentication and transfer practices used during Loblaw gift card offering

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