Canadian privacy & access decisions

The OPC was alerted to a cable provider posting a list of customers with overdue accounts and the amounts owed on a municipal Facebook page. The cable provider believed this practice was permissible, citing municipal tax arrears publications as an example. The OPC informed the provider that publicly disseminating personal information for debt collection without consent is not permitted under PIPEDA, even though disclosure to a third-party debt collector may be. The cable provider subsequently removed the posting. The OPC also clarified with the NWT Commissioner that municipal tax arrears publications are mandated by territorial law, unlike the cable provider's actions. The OPC explained that PIPEDA's debt collection exemption does not authorize public disclosure.

• Whether publicly posting customer debt information on social media is permissible under PIPEDA
• Whether the debt collection exemption under paragraph 7(3)(b) of PIPEDA authorizes public dissemination of personal information
• Whether municipal practices of publishing tax arrears are comparable to private organizations publishing customer debt under PIPEDA