Canadian privacy & access decisions

A bank customer complained after being asked to provide his driver's license to pick up a replacement credit card, despite having other identification on file and being known to staff. The bank initially cited anti-money laundering regulations (PCMLTFA) but later admitted this rationale was incorrect. The OPC investigated two issues: whether the bank improperly demanded to record information (collection) and whether it could explain the purpose of collection. Since the customer refused to provide his driver's license, no actual collection occurred, so that aspect of the complaint was not well-founded. However, the bank's inaccurate explanation for requesting the information contravened Principle 4.2.5. The bank revised its procedures and circulated new guidelines to staff, leading to a well-founded and resolved outcome for the latter issue.

• Whether the bank limited its collection of personal information to that which was necessary for the purposes identified by the organization (Principle 4.4 PIPEDA)
• Whether the bank ensured its employees were able to explain the purposes for which personal information was being collected (Principle 4.2.5 PIPEDA)