The Canadian Office of the Privacy Commissioner (the
Commissioner) released policy guidelines on online behavioural
advertising (OBA). OBA involves tracking an individual's web
activities across sites and over time to deliver targeted
advertising to the individual. These guidelines are directed to all
parties involved in OBA (including advertisers, browser developers,
and web site operators) and help clarify obligations under the
Personal Information Protection and Electronic Documents
Act (PIPEDA) relating to OBA practices.
The Commissioner generally considers all information collected
for the purpose of OBA to constitute "personal
information" as defined in PIPEDA. While the much of the
information collected in online behaviour tracking may not be
personally identifying by itself, when combined and used for the
purpose of profiling to infer an individual's interests, the
information can become highly personalized about an identifiable
individual. In particular, the
