Canadian privacy & access decisions

An individual complained to the OPC after a collection agency failed to correct inaccurate information in his credit file, despite his lawyer's repeated attempts. The complainant had paid off a debt years prior, but the collection agency had not reported this to credit bureaux, causing him difficulty in securing credit. The collection agency initially had no record of the lawyer's correspondence. However, after the OPC intervened and the lawyer sent another letter, the agency investigated and confirmed the debt was paid. Consequently, the agency updated the credit bureaux, and the complainant's credit files were amended. The complaint was settled during the investigation.

• Whether the collection agency failed to ensure the accuracy of personal information it held
• Whether the collection agency failed to correct inaccurate personal information upon request

Several employees of a federally regulated transportation company complained that a list of employees receiving severance packages, including names, identification and seniority numbers, and Social Insurance Numbers (SINs), was disclosed to their union without their knowledge or consent. The company admitted that the SINs were included on an electronic spreadsheet provided to the union, though in a hidden column. The employer did not obtain employee consent for this disclosure. During the investigation, the company changed its severance application process to no longer require SINs. The company also agreed to amend its application form to include a consent statement for the release of personal information to the union. The complaint was settled during the investigation.

• Whether the disclosure of employee names, identification numbers, seniority numbers, and Social Insurance Numbers to a union without consent contravened PIPEDA

An individual complained that a bank inappropriately required a credit check and other personal information, including length of employment and Social Insurance Number (SIN), to open a no-fee personal deposit account online. The complainant also found the language regarding information exchange with credit bureaus unclear. The bank agreed to modify its online application forms to clarify that credit checks are optional for deposit accounts if applied for in person. It also agreed to only request length of employment for credit applications and make SIN provision optional. The bank committed to reviewing the language concerning credit bureau information exchange. The OPC confirmed the complainant's credit rating was unaffected. Both the complainant and the OPC were satisfied with the bank's actions.

• Whether a credit check was appropriately required for a no-fee personal deposit account
• Whether length of employment was appropriately required for a no-fee personal deposit account
• Whether the Social Insurance Number (SIN) was appropriately required for a no-fee personal deposit account
• Whether the language describing information exchange with credit bureaus was clear