The catalogue

Canadian privacy & access decisions

The comprehensive archive of federal, provincial, and territorial commissioner decisions — each with a plain-language summary.

22,269 decisions in the archive
British ColumbiaPersonal Information Protection Act
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P17-03 — BC OIPC order 1958

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OntarioFreedom of Information and Protection of Privacy Act
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Order PO-3750

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New BrunswickRight to Information and Protection of Privacy Act
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2016-3311-AP-1792 — Kennebecasis Regional Police Force

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Quebec
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2017 QCCAI 174 — Centre universitaire de santé McGill

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SaskatchewanFreedom of Information and Protection of Privacy Act
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REVIEW REPORT 059-2017 — Public Complaints Commission

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AlbertaFreedom of Information and Protection of Privacy Act
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F2017-62 — City of Calgary

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OntarioMunicipal Freedom of Information and Protection of Privacy Act
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Order MO-3473

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QuebecAct respecting access to documents held by public bodies and the protection of personal information
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2017 QCCAI 177 — COMMISSION ON STANDARDS, EQUITY, HEALTH AND SAFETY AT WORK

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SaskatchewanFreedom of Information and Protection of Privacy Act
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Review Report 263-2016 to 268-2016 — Ministry of Highways and Infrastructure

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Federal (Canada)Privacy ActWell-founded
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Jul 19, 2017Indexed Jun 30, 2026

MyDemocracy website not designed in a privacy sensitive way

Privy Council Office

The Office of the Privacy Commissioner of Canada (OPC) investigated a complaint against the Privy Council Office (PCO) regarding its MyDemocracy.ca website. The complainant alleged that the website used "Facebook Connect" tracking, sharing user data with Facebook despite promises of anonymity. The OPC found that the website's design facilitated the disclosure of personal information, including IP addresses, browser characteristics, and for logged-in users, Facebook IDs, to Facebook upon loading the homepage and initiating share actions, without obtaining consent. PCO argued that the design was standard and that the shared data did not constitute identifiable personal information. However, the OPC concluded that this constituted a disclosure of personal information under section 3 of the Privacy Act and that PCO failed to meet its obligations under section 8. The complaint was found to be well-founded, and the OPC reiterated recommendations for PCO to ensure privacy-sensitive design, conduct PIAs, and obtain meaningful consent for future initiatives.

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Privacy ActWell-founded

MyDemocracy website not designed in a privacy sensitive way

Jul 19, 2017
Adjudicator: Daniel Therrien
Plain-Language Summary

The Office of the Privacy Commissioner of Canada (OPC) investigated a complaint against the Privy Council Office (PCO) regarding its MyDemocracy.ca website. The complainant alleged that the website used "Facebook Connect" tracking, sharing user data with Facebook despite promises of anonymity. The OPC found that the website's design facilitated the disclosure of personal information, including IP addresses, browser characteristics, and for logged-in users, Facebook IDs, to Facebook upon loading the homepage and initiating share actions, without obtaining consent. PCO argued that the design was standard and that the shared data did not constitute identifiable personal information. However, the OPC concluded that this constituted a disclosure of personal information under section 3 of the Privacy Act and that PCO failed to meet its obligations under section 8. The complaint was found to be well-founded, and the OPC reiterated recommendations for PCO to ensure privacy-sensitive design, conduct PIAs, and obtain meaningful consent for future initiatives.

Key Issues
  • Whether the MyDemocracy.ca website's design led to the disclosure of personal information to third parties (Facebook, Google Analytics) without consent.
  • Whether IP addresses, browser characteristics, and unique URLs constitute "personal information" under section 3 of the Privacy Act.
  • Whether the Privy Council Office (PCO) met its obligations under section 8 of the Privacy Act regarding the disclosure of personal information.
  • Whether PCO's amendments to the website and privacy policy were sufficient to obtain meaningful consent for data disclosure.
  • Whether PCO should have conducted a Privacy Impact Assessment (PIA) for the MyDemocracy.ca initiative.
  • Whether the collection of demographic information was justified and compliant with relevant standards.
  • Whether the use of Google Analytics complied with the Treasury Board of Canada Secretariat's (TBS) Standard on Privacy and Web Analytics.
QuebecAct respecting access to documents held by public bodies and the protection of personal information
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2017 QCCAI 204 — Commission scolaire de Portneuf

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AlbertaFreedom of Information and Protection of Privacy Act
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F2017-61 — Alberta Justice and Solicitor General

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OntarioMunicipal Freedom of Information and Protection of Privacy Act
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Order MO-3472

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OntarioMunicipal Freedom of Information and Protection of Privacy Act
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Order MO-3471

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OntarioFreedom of Information and Protection of Privacy Act
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Order PO-3749-R

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