Canadian privacy & access decisions

An individual complained to the OPC after discovering inaccuracies in his credit file, including two unrecognized credit inquiries and a notation that his account had been automatically combined with others. The credit reporting agency acknowledged that his file had been manually combined with another individual's due to similar names and addresses. The OPC investigated two main issues: unauthorized use/disclosure and accuracy of personal information. The OPC found no unauthorized use or disclosure, as the inquiries occurred before the files were combined and only the other individual's information was used. However, the OPC determined that the agency failed to maintain accurate personal information, as combining files compromised accuracy and led to incorrect information being attributed to the complainant. The agency rectified the error by separating the files, notifying creditors of corrections, and committing to enhanced employee training. Consequently, the accuracy issue was found to be well-founded and resolved.

• Whether the credit reporting agency improperly disclosed the complainant's personal information without consent
• Whether the credit reporting agency failed to maintain accurate personal information as required by PIPEDA Principle 4.6
• Whether the credit reporting agency failed to maintain accurate personal information as required by PIPEDA Principle 4.6.3