Canadian privacy & access decisions

An individual complained to the OPC after a retailer's delivery person inappropriately texted her using her phone number, which he had transferred from his faulty work phone to his personal device. The complainant also felt the retailer's management initially showed a lack of concern. The OPC's inquiries revealed the delivery person obtained the customer's number from his work phone. The retailer, disapproving of employees transferring customer information to personal devices, subsequently implemented a new policy requiring delivery employees with faulty work phones to return to the warehouse immediately. The retailer also took disciplinary action against the delivery person, provided mandatory privacy retraining to employees, and the company president met personally with the affected customer. The customer was satisfied with the actions taken by the retailer.

• Whether the delivery person's use of customer information for personal communication was appropriate
• Whether the retailer adequately protected customer personal information when work devices were faulty
• Whether the retailer responded appropriately to the customer's complaint