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Subscribers required to provide information to renew e-mail news subscription

A subscriber to an e-mail media news service complained that he had to provide more information than was necessary in order to re-subscribe. It was the Department of Foreign Affairs and International Trade (DFAIT) that offered the subscription service. Specifically, the complainant objected to providing his postal code, telephone number and company affiliation. He also was upset that although DFAIT’s privacy notice said the provision of information was voluntary, it was actually obligatory.

The Office learned that DFAIT had been asking Canadian subscribers to its e-mail media releases to provide their e-mail address, city, province, postal code, telephone number and company affiliation. International subscribers were only being asked for their e-mail address and country of origin. We confirmed that the on‑line subscription application would not accept the subscription without this information.

DFAIT explained that telephone numbers are required so that the department can contact subscribers in the event of any technical problems with e-mail addresses. Postal code and company affiliation information is required so that some media releases can be targeted to a particular region or a particular type of business.

Our Office concluded that DFAIT was allowed under the Act to collect the subscriber information in order to facilitate access to and distribution of the media releases. The complaint was therefore considered to be not well-founded. However, we were pleased that DFAIT agreed that the use of the word “voluntary” in its privacy notice was somewhat misleading; it was, in fact, the participation in the subscription activity itself that was voluntary. DFAIT subsequently changed the notice to make it more accurate.

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