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Canada: OPC publishes report of findings following joint investigation into Tim Hortons mobile app

The Office of the Privacy Commissioner of Canada ('OPC') published, on 1 June 2022, the report of findings following the investigation that it had launched into Tim Hortons Inc., along with the Office of the Information and Privacy Commissioner for British Columbia, the Office of the Information and Privacy Commissioner of Alberta, and the Quebec Commission on Access to Information. In particular, the OPC noted that the investigation involved an examination into the Tim Hortons app and its data collection and processing of individuals' personal data and movements, which concluded that people who had downloaded the app had their movements tracked and recorded every few minutes of every day, even when their app was not open, in violation of Canadian privacy laws. In addition, the OPC indicated that Tim Hortons' app had lacked a robust privacy management program and that the vast collection of location information was not proportional. Lastly, the OPC outlined recommendations for Tim Hortons to bring the app into compliance with applicable privacy legislation.

You can read the press release here and the report of findings here.

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