Information and Privacy Commissioner for British Columbia (OIPC BC) — Canadian Tire Associate Dealers
OIPC Investigation Report 23-02 found four BC Canadian Tire stores contravened PIPA by using facial recognition (2018-2021) to collect customers' biometric data without notice, a demonstrated reasonable purpose, or consent.
Key takeaway — how to prevent this
Biometric data (faces, iris, fingerprints) needs an explicit lawful basis or consent. Scraping or capturing it without one is unlawful across the EU/UK and many US states (e.g. Illinois BIPA) — and draws the largest fines.
Case brief
Read from the authority's press release on 2026-09-19. Every holding carries a short verbatim quote from that text.
- Decided by
- OIPC
- Parties
- OIPC v. Canadian Tire Associate Dealers
- Decision date
- April 20, 2023
- Remedy
- The summary text notes findings of PIPA contraventions but does not specify a particular monetary penalty or enforcement order.
- Appeal
- Appeal status not stated
Key holdings
Four Canadian Tire stores in British Columbia violated PIPA by using facial recognition technology to collect and retain biometric data between 2018 and 2021.
“Four BC Canadian Tire stores using facial recognition technology (FRT) to collect and retain customer’s biometric information between 2018 and 2021 contravened the Personal Information Protection Act (PIPA).”
The stores failed to adequately notify individuals, lacked a reasonable purpose, and failed to get consent from individuals entering the stores.
“The investigation found that the stores did not properly notify people entering the store that FRT was in use, failed to demonstrate a reasonable purpose for using FRT”
In plain English
This blog post from the Office of the Information and Privacy Commissioner for British Columbia (OIPC) summarizes Investigation Report 23-02 concerning four Canadian Tire stores in British Columbia. Between 2018 and 2021, these store locations used facial recognition technology to collect and retain the biometric information of customers. Following an investigation, the Commissioner determined that the Canadian Tire stores contravened the Personal Information Protection Act (PIPA). Specifically, the investigation established that the stores failed to properly notify individuals entering the premises that facial recognition technology was active. Additionally, the stores failed to demonstrate a reasonable purpose for deploying facial recognition technology and did not obtain the required consent from people entering the store locations. While the provided text outlines these key findings of statutory contravention, it does not specify any monetary penalties, fines, or explicit enforcement orders issued against the store operators. The document highlights the regulatory oversight of biometric data collection under provincial privacy legislation in Canada.
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