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ARTICLE · 06 APRIL 2016

Legal Trends 2016: Privacy

Blake, Cassels & Graydon LLP
Blake, Cassels & Graydon LLP
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Blake, Cassels & Graydon LLP

Blake, Cassels & Graydon LLP

As one of Canada’s top business law firms, Blake, Cassels & Graydon LLP (Blakes) provides...

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There were several important privacy developments in 2015 that may potentially impact organizations doing business in Canada in the year ahead and beyond.

CanadaPrivacy

There were several important privacy developments in 2015 that may potentially impact organizations doing business in Canada in the year ahead and beyond.

ONE | ONLINE BEHAVIOUR ADVERTISING AND CONSENT

In April, the Office of the Privacy Commissioner of Canada (OPC) released its investigation report regarding Bell's Relevant Ads Program (RAP). The RAP involved the creation of Bell Mobility customer profiles based on demographic and account information combined with network usage information, such as specific websites visited and apps used. Bell was to use the profiles to serve third-party ads, charging fees to the advertisers.

The OPC determined that Bell's use of an opt-out form of consent for the RAP was not appropriate given the sensitivity of the information (including sensitive website URLs) and the reasonable expectations of Bell's customers. According to the OPC, Bell customers paid a significant amount for their mobile services and would not reasonably

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