DVD-rental store revises membership application process
Settled case summary #28
In order to become a member of a DVD-rental store, an individual was obliged to present identification, including his driver’s licence. He provided the store with his credit card information and showed his driver’s licence. However, he refused to allow the store to enter the details of his licence into its database, as he believed this to be unnecessary. As a result, the store would not allow him to rent any DVDs.
The store initially maintained that the driver’s licence information was a business necessity for the purposes of verifying identity and recovering overdue rental products. However, it became clear during the investigation that, although the company needed to view photo identification, it did not actually use driver’s licence data to trace a member; rather, it used publicly available information. When the store realized that it was collecting information that it would not be using, it amended its account set-up and customer authentication process.
Under the new membership process, an individual must produce two pieces of identification, one of which has to contain a photo but need not be a driver’s licence. Other options for photo identification include a military card; student card; gym membership card; and, if the customer volunteers it, a health card or passport. No matter which option is chosen, the only information entered into the store’s database is a general comment to the effect that the photo identification was verified.
The company committed to reviewing the new account set-up process with its staff and to updating its procedures manual to reflect the changes. The Assistant Commissioner and the complainant agreed that the matter should be considered settled.
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