Alberta
Tim Hortons app violated privacy laws in collection of ‘vast amounts’ of sensitive location data

People who downloaded the Tim Hortons app had their movements tracked and recorded every few minutes of every day, even when their app was not open, in violation of Canadian privacy laws, a joint investigation by federal and provincial privacy authorities has found.
The investigation concluded that Tim Hortons’ continual and vast collection of location information was not proportional to the benefits Tim Hortons may have hoped to gain from better targeted promotion of its coffee and other products.
The Office of the Privacy Commissioner of Canada, Commission d’accès à l’information du Québec, Office of the Information and Privacy Commissioner for British Columbia, and Office of the Information and Privacy Commissioner of Alberta issued their Report of Findings today.
The Tim Hortons app asked for permission to access the mobile device’s geolocation functions, but misled many users to believe information would only be accessed when the app was in use. In reality, the app tracked users as long as the device was on, continually collecting their location data.
The app also used location data to infer where users lived, where they worked, and whether they were travelling. It generated an “event” every time users entered or left a Tim Hortons competitor, a major sports venue, or their home or workplace.
The investigation uncovered that Tim Hortons continued to collect vast amounts of location data for a year after shelving plans to use it for targeted advertising, even though it had no legitimate need to do so.
The company says it only used aggregated location data in a limited way, to analyze user trends – for example, whether users switched to other coffee chains, and how users’ movements changed as the pandemic took hold.
While Tim Hortons stopped continually tracking users’ location in 2020, after the investigation was launched, that decision did not eliminate the risk of surveillance. The investigation found that Tim Hortons’ contract with an American third-party location services supplier contained language so vague and permissive that it would have allowed the company to sell “de-identified” location data for its own purposes.
There is a real risk that de-identified geolocation data could be re-identified. A research report by the Office of the Privacy Commissioner of Canada underscored how easily people can be identified by their movements.
Location data is highly sensitive because it can be used to infer where people live and work, reveal trips to medical clinics. It can be used to make deductions about religious beliefs, sexual preferences, social political affiliations and more.
Organizations must implement robust contractual safeguards to limit service providers’ use and disclosure of their app users’ information, including in de-identified form. Failure to do so could put those users at risk of having their data used by data aggregators in ways they never envisioned, including for detailed profiling.
The investigation also revealed that Tim Hortons lacked a robust privacy management program for the app, which would have allowed the company to identify and address many of the privacy contraventions the investigation found.
The four privacy authorities recommended that Tim Hortons:
- Delete any remaining location data and direct third-party service providers to do the same;
- Establish and maintain a privacy management program that: includes privacy impact assessments for the app and any other apps it launches; creates a process to ensure information collection is necessary and proportional to the privacy impacts identified; ensures that privacy communications are consistent with, and adequately explain app-related practices; and
- Report back with the details of measures it has taken to comply with the recommendations.
Tim Hortons agreed to implement the recommendations.
QUOTES
“Tim Hortons clearly crossed the line by amassing a huge amount of highly sensitive information about its customers. Following people’s movements every few minutes of every day was clearly an inappropriate form of surveillance. This case once again highlights the harms that can result from poorly designed technologies as well as the need for strong privacy laws to protect the rights of Canadians.”
“This report eloquently illustrates the risks inherent in the use of geolocation and the importance of transparent and accountable privacy practices. Without a suitable prior assessment, Tim Hortons collected sensitive information about its customers through its app, without their adequate knowledge or consent. It is to put an end to this kind of practice that Quebec has reviewed its legislation protecting personal information giving more powers to the Commission and making companies more accountable. ”
“This investigation sends a strong message to organizations that you can’t spy on your customers just because it fits in your marketing strategy. Not only is this kind of collection of information a violation of the law, it is a complete breach of customers’ trust. The good news in this case is that Tim Hortons has agreed to follow the recommendations we set out, and I hope other organizations can learn from the results of this investigation.”
“This investigation is yet another example where an organization has not effectively notified customers about its practices. Tim Hortons’ customers did not have adequate information to consent to the location tracking that was actually occurring. When people download and use these types of apps, it’s important that they know in advance what will happen to their personal information and that organizations follow through with their commitments.”
Alberta
Red Deer Justice Centre Grand Opening: Building access to justice for Albertans

The new Red Deer Justice Centre will help Albertans resolve their legal matters faster.
Albertans deserve to have access to a fair, accessible and transparent justice system. Modernizing Alberta’s courthouse infrastructure will help make sure Alberta’s justice system runs efficiently and meets the needs of the province’s growing population.
Alberta’s government has invested $191 million to build the new Red Deer Justice Centre, increasing the number of courtrooms from eight to 12, allowing more cases to be heard at one time.
“Modern, accessible courthouses and streamlined services not only strengthen our justice
system – they build safer, stronger communities across the province. Investing in the new Red Deer Justice Centre is vital to helping our justice system operate more efficiently, and will give people in Red Deer and across central Alberta better access to justice.”

Government of Alberta and Judiciary representatives with special guests at the Red Deer Justice Centre plaque unveiling event April 22, 2025.
On March 3, all court services in Red Deer began operating out of the new justice centre. The new justice centre has 12 courtrooms fully built and equipped with video-conference equipment to allow witnesses to attend remotely if they cannot travel, and vulnerable witnesses to testify from outside the courtroom.
The new justice centre also has spaces for people taking alternative approaches to the traditional courtroom trial process, with the three new suites for judicial dispute resolution services, a specific suite for other dispute resolution services, such as family mediation and civil mediation, and a new Indigenous courtroom with dedicated venting for smudging purposes.
“We are very excited about this new courthouse for central Alberta. Investing in the places where people seek justice shows respect for the rights of all Albertans. The Red Deer Justice Centre fills a significant infrastructure need for this rapidly growing part of the province. It is also an important symbol of the rule of law, meaning that none of us are above the law, and there is an independent judiciary to decide disputes. This is essential for a healthy functioning democracy.”
“Public safety and access to justice go hand in hand. With this investment in the new Red Deer Justice Centre, Alberta’s government is ensuring that communities are safer, legal matters are resolved more efficiently and all Albertans get the support they need.”
“This state-of-the-art facility will serve the people of Red Deer and surrounding communities for generations. Our team at Infrastructure is incredibly proud of the work done to plan, design and build this project. I want to thank everyone, at all levels, who helped make this project a reality.”
Budget 2025 is meeting the challenge faced by Alberta with continued investments in education and health, lower taxes for families and a focus on the economy.
Quick facts
- The new Red Deer Justice Centre is 312,000 sq ft (29,000 m2). (The old courthouse is 98,780 sq ft (9,177 m2)).
- The approved project funding for the Red Deer Justice Centre is about $191 million.
Alberta
CPP another example of Albertans’ outsized contribution to Canada

From the Fraser Institute
By Tegan Hill
Amid the economic uncertainty fuelled by Trump’s trade war, its perhaps more important than ever to understand Alberta’s crucial role in the federation and its outsized contribution to programs such as the Canada Pension Plan (CPP).
From 1981 to 2022, Albertan’s net contribution to the CPP—meaning the amount Albertans paid into the program over and above what retirees in Alberta received in CPP payments—was $53.6 billion. In 2022 (the latest year of available data), Albertans’ net contribution to the CPP was $3.0 billion.
During that same period (1981 to 2022), British Columbia was the only other province where residents paid more into the CPP than retirees received in benefits—and Alberta’s contribution was six times greater than B.C.’s contribution. Put differently, residents in seven out of the nine provinces that participate in the CPP (Quebec has its own plan) receive more back in benefits than they contribute to the program.
Albertans pay an outsized contribution to federal and national programs, including the CPP because of the province’s relatively high rates of employment, higher average incomes and younger population (i.e. more workers pay into the CPP and less retirees take from it).
Put simply, Albertan workers have been helping fund the retirement of Canadians from coast to coast for decades, and without Alberta, the CPP would look much different.
How different?
If Alberta withdrew from the CPP and established its own standalone provincial pension plan, Alberta workers would receive the same retirement benefits but at a lower cost (i.e. lower CPP contribution rate deducted from our paycheques) than other Canadians, while the contribution rate—essentially the CPP tax rate—to fund the program would likely need to increase for the rest of the country to maintain the same benefits.
And given current demographic projections, immigration patterns and Alberta’s long history of leading the provinces in economic growth, Albertan workers will likely continue to pay more into the CPP than Albertan retirees get back from it.
Therefore, considering Alberta’s crucial role in national programs, the next federal government—whoever that may be—should undo and prevent policies that negatively impact the province and Albertans ability to contribute to Canada. Think of Bill C-69 (which imposes complex, uncertain and onerous review requirements on major energy projects), Bill C-48 (which bans large oil tankers off B.C.’s northern coast and limits access to Asian markets), an arbitrary cap on oil and gas emissions, numerous other “net-zero” targets, and so on.
Canada faces serious economic challenges, including a trade war with the United States. In times like this, it’s important to remember Alberta’s crucial role in the federation and the outsized contributions of Alberta workers to the wellbeing of Canadians across the country.
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