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The author of this blog, David T.S. Fraser, is a Canadian privacy lawyer who practices with the firm of McInnes Cooper. He is the author of the Physicians' Privacy Manual. He has a national and international practice advising corporations and individuals on matters related to Canadian privacy laws.

For full contact information and a brief bio, please see David's profile.

Please note that I am only able to provide legal advice to clients. I am not able to provide free legal advice. Any unsolicited information sent to David Fraser cannot be considered to be solicitor-client privileged.

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The views expressed herein are solely the author's and should not be attributed to his employer or clients. Any postings on legal issues are provided as a public service, and do not constitute solicitation or provision of legal advice. The author makes no claims, promises or guarantees about the accuracy, completeness, or adequacy of the information contained herein or linked to. Nothing herein should be used as a substitute for the advice of competent counsel.

This web site is presented for informational purposes only. These materials do not constitute legal advice and do not create a solicitor-client relationship between you and David T.S. Fraser. If you are seeking specific advice related to Canadian privacy law or PIPEDA, contact the author, David T.S. Fraser.

Sunday, January 11, 2004

Public Interest Advocacy Centre on Privacy

In my previous post below, I made a reference to the Public Interest Advocacy Centre. They have been very active on the privacy front, making well-reasoned submissions on PIPEDA when it was still "Bill C-6" and on the Canadian Standards Association Model Code for the Protection of Personal Information in 2002.

In 2001, the PIAC complained to the Privacy Commissioner about the consent practices of a number of high-profile businesses, including Scotiabank, Bell (and a bunch of its subsidiaries), the Bay and Airmiles (operated by the Loyalty Group). The full-text of the Commissioner' findings are on the PIAC site, instead of the abbreviations that are on the Commissioner's site.

When I read the Commissioner's report on the Airmiles Program, it was interesting to read the following comment, made after reviewing the Airmiles privacy commitment:

Nor, curiously, does it mention two points that I suspect many prospective members would be relieved to learn: (1) that Loyalty limits its disclosure of information to the items that I have listed above and does not identify specific purchases; and (2) that Loyalty does not disclose Collectors' transaction information between Sponsors.

Most people I talk to assume that loyalty programs -- and at least this program -- collects detailed "shopping cart" information. With pharmacies as members of the Airmiles program, this would be a huge issue.

Labels: information breaches, loyalty cards, privacy