CIBC Ruling A Warning For All Marketers

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_This is a guest contribution from Amanda Maltby._
Federal Privacy Commissioner Jennifer Stoddart “issued her findings this week”:http://www.privcom.gc.ca/media/nr-c/2005/nr-c_050418_e.asp on the much-publicized case involving misdirected faxes containing customer information that were sent by “CIBC”:http://www.cibc.com/ca/personal.html to several unrelated third parties. The Commissioner’s office investigated when several CIBC customers complained that their personal data had been faxed to a U.S. and Quebec-based company over the course of a three-year period without their knowledge or consent.
While the Commissioner deliberated specifically on the bank’s practices, she also spoke more broadly about the impact these findings could have on any organization that collects, uses or discloses personal information for commercial purposes. And she’s right.


When the federal privacy law came into force across Canada in 2004, most in the private sector developed privacy policies and named chief privacy officers to meet the law’s minimal requirements. That’s great as long as you don’t make any mistakes with your customer’s personal information, your suppliers don’t make any mistakes with this information and those mistakes don’t get in the press. In the unfortunate case of CIBC most of these things occurred.
Marketers should consider that it’s one thing to develop a privacy policy and post it on your Web site but if you’re not educating your staff about the policy or paying attention to customer complaints or ensuring that customer data is properly safeguarded then you’re not “practicing good privacy”. This is what the Commissioner spoke about and she guessed that many companies maybe in this situation.
For good reason, marketers familiar with the federal privacy law have long held fears over this kind of public exposure when mistakes are made with customer data within their own companies. And I suspect that many are living on the edge when it comes to their own practices. Take a second look at your privacy policy to make sure you practice what you preach. That’s better then ending on the front page of the newspaper.
_Amanda Maltby recently joined “Ipsos-Reid Public Affairs”:http://www.ipsos.ca/pa/ as a Senior Vice President in the Toronto office. She brings over 15 years of insight and practical experience in public policy, communications strategy and opinion research on a wide range of economic and social issues in both the private and public sector environments._

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