Privacy Commissioner of Canada
112 Kent Street
Dear Mr. Radwanski,
Please find enclosed PIAC's report, Consumer Reporting and Privacy: The Need for Better Consumer Protection. The main finding of the report is that the new Personal Information Protection and Electronic Documents Act has the potential to bring much needed improvements in privacy protection to the consumer reporting system. However, some vigilance will be required to ensure that these improvements actually occur.
In particular, we would like to draw your attention to two subjects we discuss in the report:1. Credit Scores: We found that consumer reporting agencies and financial institutions compute scores based on consumers' financial and demographic information. Yet, the existence of such scores, and the scores themselves, are kept secret from consumers. We feel that consumers should be informed about the use of their personal information to compute these scores, and that consumers should be given access to scores about themselves upon request. 2. Consent Forms: We found that the forms in which consumers give their consent to having their personal information disclosed to consumer reporting agencies, and used by these agencies to create dossiers on them, did not clearly explain these uses and disclosures or the purposes for them. We feel that consumers should be fully informed about how their information is used and disclosed in the consumer reporting system.
We hope that you will conduct a full investigation of consumer reporting practices in the financial sector in light of the fact that the Personal Information Protection Act will apply to both consumer reporting agencies and major creditors on January 1.
Please feel free to contact me should you have any questions or comments on this matter.