A Double-Take On Double-Tracking: Takeaways From The Privacy Investigation Into The Tim Hortons' App

A recent investigation report into Tim Hortons, co-authored by the Office of the Privacy Commissioner of Canada (“OPC“), Commission d'accès à l'information du Québec, Office of the Information and Privacy Commissioner of Alberta, and Office of the Information and Privacy Commissioner of British Columbia (collectively, the “Commissioners“) has prompted renewed and pressing calls for change in Canadian privacy law.

The Report's findings have prompted calls for monetary penalties against companies engaged in privacy breaches. Outgoing federal Privacy Commissioner Daniel Therrien has been vocal about his concerns that the OPC's inability to impose financial penalties is recognized as a limit on its authority and power.