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.”
Louisiana Governor Jeff Landry and New Hampshire Governor Chris Sununu of the Governors’ Coalition for Energy Security
Premier Danielle Smith has joined the Governors’ Coalition for Energy Security to further support advocacy of Alberta’s energy and environmental interests with key U.S. states.
The coalition was established in September 2024 by U.S. State governors Jeff Landry (Louisiana) and Chris Sununu (New Hampshire) with the aim of ensuring energy security, lower energy costs, increased reliability, sustainable economic development and sensible management of energy resources and the environment. With 12 U.S. states already signatories to the coalition, Alberta is the first non-U.S. state to enter into this agreement.
By expanding energy ties with the U.S. and promoting cross-border energy trade and participation, Alberta is helping to build upon its North American Energy strategy. Alberta already accounts for 56 per cent of all oil imports to the U.S. – twice as much as Mexico, Saudi Arabia and Iraq combined – which is helping to drive job creation and prosperity on both sides of the border. Natural gas also plays an important role in North America’s energy mix. Alberta is the largest producer of natural gas in Canada and remains positioned to support the U.S. in filling their domestic supply gaps.
“I am honoured to join the Governors’ Coalition for Energy Security and would like to extend my sincere thanks to governors Landry and Sununu for the invitation. Alberta plays a vital role in North American energy security, serving as the largest supplier of crude oil and natural gas to the United States. With 200 billion barrels of recoverable oil, 200 trillion cubic feet of recoverable natural gas, significant natural gas liquids and ample pore space for carbon capture, Alberta’s contribution is set to grow even further as we look to work with the Trump Administration and other U.S. partners to increase our pipeline capacity to our greatest friend and ally, the United States. We are proud to collaborate with this coalition of allied states in advancing energy security, reliability and affordability for Americans and Canadians.”
“Our mission as an organization has not changed but Alberta’s welcome arrival to our group sparked a conversation about what our core mission is, and that is ensuring energy security in all its forms. Our members all share the common goal of enhancing and protecting energy options for our people and businesses, which leads to lower energy costs, increased reliability, sustainable economic development and wise management of energy resources and the environment. I welcome Premier Smith and the insights she will bring as the leader from a fellow energy-producing province, that like my state, is under a federal system of government where national imperatives are not always aligned with state or provincial interests.”
Alberta is a global leader in emissions reduction technology and clean energy solutions. The province has captured about 14 million tonnes of carbon dioxide through carbon capture, utilization and storage technology, and has the ability to support the U.S. in developing new infrastructure and supply chains for future energy markets in the areas of hydrogen, renewables, small modular reactors and others.
Alberta is also unlocking its untapped geological potential to help meet the increasing demand for minerals – many of which are used worldwide to manufacture batteries, cell phones, energy storage cells and other products. This includes the province’s lithium sector where Alberta’s government is supporting several innovative projects to develop new ways to extract and concentrate lithium faster and with higher recovery rates that are less capital and energy intensive and have a smaller land-use footprint.
As part of this coalition, Alberta looks forward to sharing best practices with states that already have expertise in these areas.
Quick facts
- The U.S. is Alberta’s largest trading partner, with C$188 billion in bilateral trade in 2023.
- In 2023, energy products accounted for approximately C$133.6 billion, or more than 80 per cent of Alberta’s exports to the U.S.
- The Governors’ Coalition for Energy Security’s 12 signatory states include Louisiana, New Hampshire, Indiana (Governor Eric Holcomb), Alabama (Governor Kay Ivey), Georgia (Governor Brian Kemp), Tennessee (Governor Bill Lee), South Dakota (Governor Kristi Noem), Mississippi (Governor Tate Reeves), Arkansas (Governor Sarah Huckabee Sanders), Oklahoma (Governor Kevin Stitt), Wyoming (Governor Mark Gordon) and Virginia (Governor Glenn Youngkin).
Helping builders by putting an end to housing delays
Alberta’s new Stop Housing Delays online portal will allow developers, municipalities and other housing partners to report red tape and unnecessary home-building delays.
Alberta’s government is focused on ensuring Albertans have access to the housing they need, and that means working to streamline processes, cut red tape and reduce delays that are slowing housing construction down. As part of this work, government has launched a new online portal to help in these efforts.
The Stop Housing Delays online portal is now available for developers and municipal authorities to help identify areas that are preventing fast and efficient residential construction. This portal will help government identify and address barriers to building homes across the province.
“The Stop Housing Delays portal will allow Alberta’s government to hear directly from developers, municipalities and other partners on where delays are happening in the construction process. This will help identify and remove barriers, ultimately getting homes built faster and continuing Alberta’s record home-building pace.”
“Alberta’s government will continue to work with municipalities and find solutions to speed up the home-building process. The Stop Housing Delays portal will give us another tool to inform those discussions and identify areas where we can improve the pace of home building.”
Once developers, municipalities or industry partners have submitted their issue using the online form, government will collect and assess the information provided. Alberta’s government will be taking a collaborative, cross-ministry approach to ensure the appropriate departments are working together to find solutions where possible. Solutions may range from minor changes to policy reform.
Alberta’s government continues to support builders and encourage new residential housing construction by reducing red tape, incentivizing housing construction and supporting innovative strategies to build homes faster than ever.
“This webpage is an excellent opportunity to gather knowledge and further eliminate red tape. Government has been persistent in our approach of cutting red tape and removing roadblocks, and this will help to speed up residential construction. I look forward to hearing from developers and our other partners on how we can help get projects moving and Albertans in homes.”
Alberta continues to see strong housing starts and increases while other provinces across Canada are seeing a reduction in housing starts. The first half of 2024 saw 9,903 apartment unit starts in the province. This marks the highest amount in any half year in Alberta’s history, breaking the previous record of 9,750 set in 1977. Albertans will benefit from 33,577 new housing starts from January through September 2024, up 35 per cent from the same period last year. Alberta’s government remains focused on working with industry and non-profit partners to ensure that the province’s growing population has access to the housing it needs.
“This portal is a valuable tool for industry to highlight gaps, barriers and delays that may need to be prioritized and addressed by either local or provincial governments. Real solutions can only emerge through transparency, open communication and collaboration. This is an important step toward identifying the unique challenges each region and municipality faces in delivering attainable housing.”
Quick Facts
- Housing starts for January – September 2024 compared with January – September 2023
- Provincewide: 33,577 compared with 24,904 (up 35 per cent)
- Edmonton: 13,359 compared with 9,099 (up 47 per cent)
- Calgary: 17,414 compared with 14,141 (up 23 per cent)
- Lethbridge: 599 compared with 148 (up 305 per cent)
- Red Deer: 314 compared with 146 (up 115 per cent)
- Data shows Alberta had 10,699 purpose-built rentals, making up 32 per cent of all housing starts.
- Since 2019, Alberta’s government has invested almost $850 million to build more than 5,100 units and close to 900 shelter spaces. This includes projects we have committed to, that are in progress and that are complete.
- Together with its partners, Alberta’s government is supporting $9 billion in investments into affordable housing to support 25,000 additional low-income households by 2031.
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