PIPEDA And The Internal Complaints Process Of Insurers And Banks

Case Study: Decision from the Office of the Privacy Commissioner of Canada

Insurers and banks function on personal information; insurers require that information to underwrite and adjust, and banks to assess risk. It is no surprise that these two entities are perhaps the largest targets of privacy law, specifically the sweeping Personal Information Protection and Electronic Documents Act (otherwise known as PIPEDA).¹

PIPEDA requires the full and timely disclosure of personal information generated in the course of commercial activity. However, personal information does not need to be disclosed when the information is generated in the course of a "formal dispute resolution process",² such as an arbitration.³