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Not surprisingly, the OPC stressed that retailers should collect the least amount of personal information possible from customers, given the likelihood of potential data breaches and the possible disclosure of personal information across-border to foreign governments, and should avoid recording personal information where possible. The OPC also suggested collecting email addresses, but not names, for mailing lists and memberships.
When purchasing cannabis, the OPC also advises individuals not to provide the retailer with more personal information than necessary and specifically recommends that if users are concerned about using credit cards (and the option is available), then cash should be used to buy cannabis. Regrettably this approach is not available to users of the OCS website, which currently accepts VISA, Mastercard and American Express, VISA Debit, Debit MasterCard and pre-paid credit cards – but not cash.
The OCS requires customers to provide their names, addresses, email, telephone numbers and payment card information when products are ordered from the website. Customers are also asked to verify that they are at least 19 years old to confirm their purchase.
On a more positive note, while prospective customers that wish to peruse the OCS website are asked to enter their date of birth to confirm that they are 19 years of age or older to legally access the website’s content, the OCS’ Privacy Policy advises that the visitor’s date of birth is not used for other purposes, or kept or stored by OCS after the visitor closes their browser session.
Ensure adequate
security measures
Any personal information collected by a retailer, such as name, credit card number, email address or any other personal information must be stored securely in accordance with PIPEDA’s requirements.
The guidance emphatically states that cannabis retailers must protect the personal information of customers in their custody and control by making appropriate security