Canadian privacy & access decisions

Three individuals complained that their dating profiles, containing sensitive medical information, posted on PositiveSingles.com appeared on numerous other affiliated dating websites without their knowledge or consent. The complainants were assured of privacy but found their profiles on sites targeting different demographics, causing distress. The OPC's investigation found that PositiveSingles.com, operated by SuccessfulMatch Inc., used a single database across a network of affiliated sites, making profiles automatically available. The OPC concluded that the organization failed to obtain meaningful consent for this use, lacked openness about its network structure, and had inadequate safeguards, as some personal information was accessible via search engines. Following the OPC's recommendations, SuccessfulMatch revamped its website to provide explicit information about the network, ensure informed consent at registration, and improve safeguards. The complaint was found well-founded and resolved due to these corrective measures.

• Whether PositiveSingles.com obtained meaningful consent for the use of personal information across its network of affiliated sites (Principle 4.3, 4.3.2, 4.3.5 PIPEDA)
• Whether PositiveSingles.com was sufficiently open about its personal information management policies and practices, particularly regarding its network structure (Principle 4.8, 4.8.1 PIPEDA)
• Whether PositiveSingles.com implemented adequate security safeguards to protect sensitive personal information from unauthorized access (Principle 4.7, 4.7.1 PIPEDA)
• Whether PositiveSingles.com's use of cookies, potentially for online behavioral advertising, required express consent given the sensitive nature of the information