Organizations, large and small, must make sure that all employees are aware of their privacy obligations. There has to be a mechanism to ensure that all privacy-related incidents, large and small are brought to the attention of a senior officer, whose job includes constant awareness of the big picture and what is going on. The problem at CIBC was that each individual fax was a "minor incident" that was probably easy to dismiss as a "one off". When this happens hundreds of times, and nobody thinks to report it to senior management, it can quickly turn into a major disaster. There hasn't been any suggestion (yet) that anyone has been harmed as a result of this incident, but the bank has been working overtime to address customer concerns.
The Commissioner also notes, in her press release:
In light of these events and other current investigations by the Office of the Privacy Commissioner into similar cases involving misdirected faxes within the banking sector, we strongly urge all organizations subject to PIPEDA to assess their policies and privacy management practices and address any shortcomings.
The current environment of identity theft and increased concern about privacy among the general public means that this is no longer an issue that businesses can afford to become complacent about. "Can this incident happen to us?" is a question that has to be asked. For too many businesses, the answer is yes and, for some, it is merely a matter of time.
For more coverage, see
- The Globe and Mail: Errant faxing may be 'systemic'
- Yahoo! News - Privacy watchdog says misdirection of CIBC faxes could have been prevented
- eLegal Canton: Privacy Commissioner Releases Report on CIBC junkyard faxes
- CBC News: Privacy commissioner raps CIBC over misdirected faxes
- CTV.ca | CIBC faxes a 'wake-up' call: privacy watchdog
- CIBC gets tongue-lashing from Privacy Commissioner
- CIBC drafts privacy plan in wake of faxing fiasco
- Canadian Press - Privacy watchdog says Canadian businesses should learn from CIBC's fax fiasco - Includes interview with me.
- London Free Press: Business Section - Business told to learn from CIBC fax fiasco
- CTV.ca | CIBC faxes a 'wake-up' call: privacy watchdog - Includes link to CTV Video footage.