A landlord organization was found in violation of Alberta’s Personal Information Protection Act (“PIPA”) for collecting a tenant’s social insurance number on a rental application form. In Order P2012-11 of the Office of the Information and Privacy Commissioner of Alberta (“OIPC Alberta”) released yesterday, the adjudicator stated that:
I do not believe it would be reasonable for the Complainant in this inquiry to voluntarily provide her Social Insurance Number … for the purpose of determining her suitability as a tenant, because the complainant’s Social Insurance Number has no connection to her suitability as a tenant. A Social Insurance Number is an identifying number used by the government and is required for someone to legally work in Canada or to access government programs.
Although the ability to pay rent is a reasonable qualification for being a suitable tenant, having a Social Insurance Number is not indicative that a person is actually working or has the means to pay rent. … As having a Social Insurance Number has no meaningful connection to the Complainant’s suitability as a tenant, the collection of her Social Insurance Number would require a specific purpose.
The organization was also found by the OIPC Alberta to have violated PIPA when it disclosed the tenant’s name on her mailbox without consent, and collected her personal information using security cameras without appropriate notice. With respect to the security cameras, the organization was ordered to replace its current signage to provide details on the purpose for which the personal information was collected, the circumstances in which the personal information would be disclosed, and the names of staff who could be contacted to answer questions.