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.