Canadian privacy & access decisions

This joint investigation by federal, Alberta, and British Columbia privacy commissioners examined Cadillac Fairview's (CFCL) use of Anonymous Video Analytics (AVA) in mall directories and mobile device geolocation tracking. CFCL collected and used personal biometric information via AVA without valid consent, and improperly retained this data. While CFCL stated it had ceased using AVA, it disagreed with findings and refused to commit to express opt-in consent for future use. Regarding geolocation, CFCL's "Anonymous Shopper Journey" did not collect personal information, and while its "Logged In Shopper Journey" collected personal information, it did not combine it with geolocation data as initially suspected. Therefore, the geolocation aspect was found not well-founded.

• Collection, use, and disclosure of personal information via AVA technology
• Adequacy of consent and notice for AVA technology
• Appropriate retention of personal information collected via AVA
• Collection, use, and disclosure of personal information via geolocation tracking