Canadian privacy & access decisions

A complainant alleged that a public opinion research firm unnecessarily collected her full date of birth and failed to adequately inform her about the purpose of a profiling survey. The firm collected full birth dates for demographic purposes and to verify identity, arguing that month and year alone were insufficient. The OPC found that collecting the full date of birth was not necessary for the firm's stated purposes and that the consent language for profiling surveys was not sufficiently clear. While the firm agreed to clarify its consent language, it refused to stop collecting or delete the day of birth from its records. Consequently, the OPC found the complaint well-founded but partially unresolved regarding the collection of full birth dates.

• Whether it is necessary for the Respondent to collect all three elements of the date of birth at registration
• Whether it is necessary for the Respondent to confirm all three elements of the date of birth in profiling surveys
• Whether the Respondent adequately informed the complainant of the purpose of the profiling survey
• Whether consent under Principle 4.3 was meaningful
• Whether the collection of personal information was limited to that which is necessary for the identified purposes under Principle 4.4