Bank’s request for additional information was a fair and reasonable response to access request

Discontinued Case Summary #2014-002

July 31, 2014

Lessons Learned

  • An individual may be required to provide sufficient information to permit an organization to provide an account of the existence, use and disclosure of personal information.
  • Where an organization provides a fair and reasonable response to a complaint, an investigation can be discontinued pursuant to paragraph 12.2(1)(c) of PIPEDA.


In a complaint to our Office, an individual alleged that a bank failed to reply to access requests for her personal information that she had sent to the bank.

Discontinuance of Investigation

The complainant sent two similar access requests to the bank. It responded to her within ten days, via registered mail, stating that it did not possess one of the specific documents she requested access to and that the bank required further information from her in order to fulfill the remainder of the access request. One week later, a different department of the bank reminded the complainant (in an email addressing a different bank matter) that she still needed to provide the bank with additional information for her access request to be further actioned.

The complainant did not reply to either of the bank’s requests for additional information, but she did file a complaint with our Office, alleging that the bank had never responded to her access request.

Our investigation established that the bank had provided a timely response to the complainant's access request.  As the complainant's access request was overly broad, the bank could reasonably seek additional information pursuant to PIPEDA principle 4.9.2, in order to follow up. 

Accordingly, the actions taken by the bank represented a fair and reasonable response to the complaint within the meaning of paragraph 12.2(1)(c) of PIPEDA. Our Office therefore exercised its discretion and discontinued the investigation of this complaint pursuant to paragraph 12.2(1)(c).

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