And the scale of the risk is significant. In 2025-2026, the Office of the Privacy Commissioner of Canada<\/a> (OPC) received 696 breach reports<\/strong> from businesses affecting more than 20 million Canadians, as well as 3,044 PIPEDA complaints<\/strong>.<\/p>\n\n\n\n This guide explains who PIPEDA applies to, its core requirements, how it affects identity verification, and the practical steps businesses can take to build a compliant privacy program.<\/p>\n\n\n\n PIPEDA<\/strong> is Canada\u2019s federal private-sector privacy law, governing how organizations collect, use, and disclose personal information during commercial activities.<\/p>\n\n\n\n Personal information broadly means information about an identifiable individual. Depending on the context, that can include a name, contact details, account information, financial data, an IP address, an identity document, a photograph, or a biometric identifier.<\/p>\n\n\n\n In line with\u00a0PIPEDA<\/a>, businesses may collect, use, or disclose personal information only for purposes that\u00a0a reasonable person would consider appropriate in the circumstances. Organizations must also follow ten fair information principles covering accountability, purposes, consent, collection, use and retention, accuracy, safeguards, openness, access, and complaints.\u00a0<\/p>\n\n\n\n PIPEDA also plays an important international role. For example, the European Commission<\/a> continues to recognize Canada as providing an adequate level of data protection for transfers to commercial organizations subject to PIPEDA. This makes the Canadian framework relevant to companies managing data across both Canadian and European markets. <\/p>\n\n\n\n As of August 2026, PIPEDA remains Canada\u2019s current federal private-sector privacy law. The federal government has introduced Bill C-36<\/a>, which would replace PIPEDA\u2019s private-sector provisions with the proposed Protecting Privacy and Consumer Data Act if the bill is enacted and brought into force.<\/p>\n\n\n\n This means that businesses operating in Canada should comply with PIPEDA now and continue to monitor the legislation. <\/p>\n\n\n\n PIPEDA applies broadly to:<\/p>\n\n\n\n Certain exclusions exist. For example, PIPEDA does not apply to data collected for personal or domestic purposes, such as a home address book or family photo album. Information collected, used, or disclosed by federal government organizations is also regulated under the Privacy Act, not PIPEDA.<\/p>\n\n\n\n PIPEDA can apply sooner than many businesses expect.<\/p>\n\n\n\n If your organization collects, uses, or discloses personal information as part of a commercial activity in Canada, you may be in scope, even if privacy is not your core business.<\/p>\n\n\n\n You may also need to comply if your company is based outside Canada. A foreign business without a Canadian office can still fall under PIPEDA when it has a \u201creal and substantial connection\u201d to Canada.<\/p>\n\n\n\n To qualify, your business may be involved in targeting Canadian customers, collecting their information, or sending data to and from Canada.<\/p>\n\n\n\n EXAMPLE:<\/strong> A European online platform advertises to Canadian users, collects their identity documents during onboarding, and stores the information on servers in Europe. Its overseas headquarters do not automatically exclude it from PIPEDA requirements. If the business serves Canadians and handles their personal information, Canadian privacy obligations may still apply.<\/p>\n\n\n\n Provincial rules<\/a> can change, though. <\/p>\n\n\n\n That does not mean PIPEDA disappears from the picture. It can still apply to federally regulated businesses and to personal information that crosses provincial or national borders.<\/p>\n\n\n\n In practice, a single customer journey may involve both federal and provincial requirements. So, it is worth mapping where your business operates, where your customers are located, and where their data travels.<\/p>\n\n\n\n PIPEDA\u2019s principles become much easier to manage when translated into practical business actions. Here are key recommendations<\/a> and actions you should follow to ensure PIPEDA compliance.<\/p>\n\n\n\n You should assign responsibility for PIPEDA compliance to a specific person or a team. That person should oversee privacy policies, employee training, complaints, vendor controls, retention rules, and incident response.<\/p>\n\n\n\n Accountability also follows the information. If a third-party processor handles customer information on your behalf, your organization remains responsible for protecting it.<\/p>\n\n\n\n Before you collect any information, you should know why each category of personal information is needed.<\/p>\n\n\n\n If an online service needs a customer\u2019s date of birth to confirm eligibility, that does not automatically justify collecting their occupation, full employment history, or unrelated device information.<\/p>\n\n\n\n PIPEDA specifically requires<\/a> collection to be limited to what is necessary for the identified purposes.<\/p>\n\n\n\n People need to understand what they are agreeing to. That\u2019s why the OPC says organizations should clearly highlight four things:<\/p>\n\n\n\n For sensitive information or unexpected processing, expressed consent<\/a> will generally be appropriate. It\u2019s important to note that privacy information should be understandable at the point of decision, not hidden inside a long legal document. <\/p>\n\n\n\n Do not quietly repurpose customer information.<\/p>\n\n\n\n If data was collected for identity verification<\/a>, using the same information later for an unrelated advertising profile may require new consent and may not be an appropriate purpose at all.<\/p>\n\n\n\n Also, you should create documented retention periods. Personal information should only be retained for as long as necessary for its identified purpose or applicable legal obligations, after which it should be securely deleted, destroyed, or anonymized.<\/p>\n\n\n\n Anywhere the collected information is used to make decisions about customers, it should be sufficiently accurate and up to date.<\/p>\n\n\n\n Individuals also have the right<\/a> (subject to limited exceptions) to ask whether an organization holds their personal information, to understand how it has been used or disclosed, to obtain access to it, and to challenge inaccuracies.<\/p>\n\n\n\n Security should match the sensitivity of the information.<\/p>\n\n\n\n A mailing-list email address and a biometric identity<\/a> template do not carry the same level of risk. More sensitive information, therefore, should receive stronger technical, organizational, and physical safeguards, such as appropriate encryption, access controls, monitoring, employee permissions, and secure deletion.<\/p>\n\n\n\n Customers should be able to easily find information about your privacy practices and know who to contact with questions or complaints.<\/p>\n\n\n\n Moreover, your published privacy notice should match what actually happens inside your systems. If you add new providers, purposes, or technologies, review whether your notices and consent mechanisms also need updating.<\/p>\n\n\n\n A workable compliance program can be built in six stages:<\/p>\n\n\n\n STEP 1. Map your data<\/strong><\/p>\n\n\n\n Identify what personal information enters your organization, where it comes from, why it is needed, where it is stored, who can access it, and where it is transferred.<\/p>\n\n\n\n STEP 2. Determine which Canadian laws apply<\/strong><\/p>\n\n\n\n Check PIPEDA, provincial legislation, sector-specific requirements, and whether any information moves across borders.<\/p>\n\n\n\n STEP 3. Connect every data field to a purpose and retention rule<\/strong><\/p>\n\n\n\n If your team cannot explain why a piece of personal information is needed, reconsider collecting it.<\/p>\n\n\n\n STEP 4. Review customer-facing privacy flows<\/strong><\/p>\n\n\n\n Update consent screens, privacy notices, withdrawal mechanisms, and access-request procedures.<\/p>\n\n\n\n STEP 5. Review security and vendors<\/strong> <\/p>\n\n\n\n Assess providers before sharing information and include appropriate privacy and security obligations in contracts.<\/p>\n\n\n\n STEP 6. Test your program<\/strong><\/p>\n\n\n\n Train employees, rehearse breach response procedures, periodically review permissions and retention, and update your processes as products or regulations change.<\/p>\n\n\n\n Identity verification<\/a> can involve some of the most sensitive information a business handles: passports, driver\u2019s licenses, addresses, birth dates, photographs, financial information, and biometric characteristics.<\/p>\n\n\n\n That makes privacy-by-design particularly important.<\/p>\n\n\n\n Consider a digital onboarding<\/a> flow that asks a customer to photograph their identity document. The business should know exactly which fields it needs, why it needs them, and whether the full image must be retained after verification. If the business only needs proof that verification succeeded, retaining every raw document indefinitely creates unnecessary privacy and security exposure.<\/p>\n\n\n\n NOTE: <\/strong>Biometric information deserves additional attention. The OPC has described biometric data<\/a> as sensitive in almost all circumstances because it is closely and often permanently connected to an individual.<\/p>\n\n\n\n Express consent will generally be expected where sensitive biometric information is collected on the basis of consent.<\/p>\n\n\n\n That\u2019s why, when designing or selecting an identity verification process, as a business, you should consider:<\/p>\n\n\n\n Another important point to note is that using a third-party verification provider does not remove the organization\u2019s PIPEDA responsibilities<\/strong>.<\/p>\n\n\n\n Basically, this means that PIPEDA allows information to be transferred to processors, including those outside Canada, but the transferring organization remains accountable and must use contractual or other measures to provide comparable protection. Customers should also receive appropriate transparency about cross-border processing<\/a>. <\/p>\n\n\n\n PIPEDA requires every organization to keep records of all breaches of security safeguards, not only the most serious ones.<\/p>\n\n\n\nWhat is PIPEDA? <\/h2>\n\n\n\n
Whom Do PIPEDA Requirements Apply To? <\/h2>\n\n\n\n
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Does PIPEDA Apply to Your Business?<\/strong><\/h2>\n\n\n\n
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PIPEDA Compliance Requirements<\/h2>\n\n\n\n
![\"PIPEDA](\"https:\/\/ondato.com\/wp-content\/uploads\/2026\/08\/v02_2026-09_PIPEDA-Compliance_Featured-1-1024x576.webp\")
<\/figure>\n\n\n\nMake Someone Accountable for Privacy<\/h3>\n\n\n\n
Define Your Purpose Before Collecting Data<\/h3>\n\n\n\n
Obtain Meaningful Consent<\/h3>\n\n\n\n
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Control Use, Disclosure, and Retention<\/h3>\n\n\n\n
Keep Information Accurate and Give People Access<\/h3>\n\n\n\n
Apply Appropriate Security Safeguards<\/h3>\n\n\n\n
Be Transparent and Provide a Complaint Process<\/h3>\n\n\n\n
Practical Steps to PIPEDA Compliance<\/h2>\n\n\n\n
![\"PIPEDA](\"https:\/\/ondato.com\/wp-content\/uploads\/2026\/08\/v02_2026-09_PIPEDA-Compliance_Featured-2-1024x576.webp\")
<\/figure>\n\n\n\nPIPEDA and Identity Verification<\/h2>\n\n\n\n
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Data Breaches, Enforcement, and Penalties<\/h2>\n\n\n\n