Canadian CANNAINVESTOR Magazine Canadian Publicly Traded April / May 2019 | Page 177

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first legal cannabis purchase in Canada. These customers may have taken the OPC’s “warning”, which advised cannabis buyers to purchase in cash to avoid any issues with entry to foreign countries, to heart. The first of Ontario’s private cannabis retailers opened its doors and caused some concern with an ID scan at the front door. Although the ID scan was allegedly programmed not to build a record without a customer’s consent, it came as a shock to customers trying to stay under the radar.

Concerned customers like the ones at that store are entitled to ask questions. Retailers are required to designate someone to ensure compliance with PIPEDA and must provide that information to customers when requested. If a customer feels its information is at risk, that customer ought to make proper inquiries of the retailer and the privacy officer.

For retailers, there are some primary ways to ensure compliance with PIPEDA. This is not a complete list of all measures that retailers can use.

1. Retailers ought to ensure that you are clear about the type of information it needs to collect and ought to be explicit about what that information will be used for;

2. Retailers ought to ensure to implement the least intrusive measures necessary to fulfil goals or meet requirements of the retail legislation;

3. Retailers ought to implement internal policies and practices for the collection and safe storage of personal information that is well known across all staff members handling personal information;

4. Retailers ought to designate a privacy officer and make that privacy officer available for customer questions.

If you are a retailer who requires assistance with respect to the development of compliant security measures and collection of personal information, please feel free to contact

Whitney Abrams

at Minden Gross LLP 416-369-4148 | [email protected] or connect on Twitter @whitneyeabrams.