OPC, PIPEDA Findings #2026-001 (Loblaw, PC Optimum): the standard for anonymized information (PIPEDA Findings #2026-001, Office of the Privacy Commissioner of Canada (5 March 2026))
PIPEDA has no statutory definition of anonymous. The OPC's test is no serious possibility of re-identification, alone or combined with other data, and the organization must be able to show it. Removing names, emails and phone numbers alone was not enough in this case.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“The term "made anonymous" is not defined in PIPEDA. ... We therefore find that for information to be considered anonymized for the purpose of Principle 4.5.3, the organization must take steps to ensure that there is no serious possibility that the information retained may be reidentified, either alone or in combination with other available information. ... Based on the data points that Loblaw described, we find that stripping accounts of names, phone numbers and email addresses alone is insufficient for Loblaw to demonstrate that the data it retains is anonymized.”
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