Privacy Commissioners in Canada Launch Joint Investigation into Tim Hortons Mobile App

On June 29, 2020 the Office of the Privacy Commissioner of Canada (OPC) announced that it and the provincial privacy commissioners of Alberta, British Columbia and Québec will commence a joint investigation into a Tim Hortons mobile ordering application after reports were brought to light by the media concerning its improper collection and use of personal information, particularly users’ geolocation data as they go about their daily activities.

The OPC will investigate whether the Tim Hortons app is in compliance with its obligations under the Personal Information Protection and Electronic Documents Act, while each province will investigate compliance with its respective provincial privacy legislation. The investigation will focus on whether the organization is obtaining meaningful consent from app users to collect and use their geolocation data and whether said collection and use is appropriate given the circumstances.

In its news release, the OPC stated that it considers the investigation to be “an issue of great importance to Canadians given the privacy issues it raises”, citing the sensitive nature of geolocation data and what it may reveal about the app user’s habits and activities.

The news release for each privacy commissioner and its involvement with the joint-investigation can be found below:

• Office of the Privacy Commissioner of Canada
• Office of the Information and Privacy Commissioner of Alberta
• Office of the Information & Privacy Commissioner for British Columbia
• Commission d’accèss à l’information du Québec

Summary By: Hashim Ghazi