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Privacy commissioners launch joint investigation into Tim Hortons mobile app


June 30, 2020, Gatineau, Que. – The Office of the Privacy Commissioner of Canada, along with three provincial counterparts, will launch an investigation into a Tim Hortons mobile ordering application after media reports raised concerns about how the app may be collecting and using data about people’s movements as they go about their daily activities.

The joint investigation will be undertaken by the Office of the Privacy Commissioner of Canada (OPC), Commission d’accès à l’information du Québec, Office of the Information and Privacy Commissioner for B.C., and Office of the Information and Privacy Commissioner of Alberta.

The OPC will examine whether Tim Hortons is in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada’s federal private sector privacy law.

More specifically, the OPC will look at whether the organization is obtaining meaningful consent from app users to collect and use their geolocation data for purposes which could include the amassing and use of detailed user profiles, and whether that collection and use of the data is appropriate in the circumstances.

The federal Privacy Commissioner’s office said in a statement that it considers this to be an issue of great importance to Canadians given the privacy issues it raises. Geolocation data can be very sensitive as it can reveal information about the habits and activities of individuals, for example, medical visits or places that they regularly frequent.

As this is an active investigation, no additional details are available at this time.


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