Canadian Privacy Decisions

This investigation examined a privacy breach experienced by a contractor for the Canada Border Services Agency (CBSA), which was targeted by a ransomware attack. Personal information, specifically licence plate images captured at Canadian border crossings, was accessed and some was posted online. The OPC found that the CBSA had contravened the Privacy Act due to inadequate security safeguards in its contract with the contractor and its inconsistent handling of licence plate data as personal information. The investigation concluded the complaint was well-founded but resolved, as the CBSA agreed to implement recommendations to improve its contracting and data protection practices.

• Whether licence plate image files, including metadata, constitute personal information under the Privacy Act.
• Whether the CBSA contravened the disclosure provisions of the Privacy Act.
• Whether the CBSA had adequate security safeguards in its contract with a third-party contractor.
• Whether the CBSA adequately managed the retention of personal information.