The Canadian Privacy Law Blog: Developments in privacy law and writings of a Canadian privacy lawyer, containing information related to the Personal Information Protection and Electronic Documents Act (aka PIPEDA) and other Canadian and international laws.

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The author of this blog, David T.S. Fraser, is a Canadian privacy lawyer who practices with the firm of McInnes Cooper. He is the author of the Physicians' Privacy Manual. He has a national and international practice advising corporations and individuals on matters related to Canadian privacy laws.

For full contact information and a brief bio, please see David's profile.

Please note that I am only able to provide legal advice to clients. I am not able to provide free legal advice. Any unsolicited information sent to David Fraser cannot be considered to be solicitor-client privileged.

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The views expressed herein are solely the author's and should not be attributed to his employer or clients. Any postings on legal issues are provided as a public service, and do not constitute solicitation or provision of legal advice. The author makes no claims, promises or guarantees about the accuracy, completeness, or adequacy of the information contained herein or linked to. Nothing herein should be used as a substitute for the advice of competent counsel.

This web site is presented for informational purposes only. These materials do not constitute legal advice and do not create a solicitor-client relationship between you and David T.S. Fraser. If you are seeking specific advice related to Canadian privacy law or PIPEDA, contact the author, David T.S. Fraser.

Thursday, January 27, 2005

E-mailing sensitive personal information after collecting it securely 

Risks Digest is a great source of information about the everyday risks the we face. Often, it carries examples of privacy risks. The latest issue contains a submission about an insecure practice that ... though sensitve personal information is collected securely using web-browser encryption, the information then treated pretty causally.

The Risks Digest Volume 23: Issue 68:

"HTTPS .ne. secure

Fri, 21 Jan 2005 7:25:35 -0500

I recently filed a change of address for some Qwest stock I own. Qwest uses The Bank of New York ( to manage stock accounts, so I went to their web page, and filled out the form using name, address, SSN, and account number. Checked for the padlock indicating HTTPS, and convinced there was *some* degree of due diligence, submitted the form. The confirmation screen starred out all but the last four digits of the SSN (i.e., ***-**-9999), which seemed reasonable.

Last night I got back an e-mail that they couldn't process my change request (the reason is unimportant), and included in the text of the message my name, e-mail address, account number, and SSN. No stars this time to shield sensitive information. Seems like a pretty useful e-mail to intercept!

What kind of security policies allow including this sort of information? The security & privacy policies don't say anything about safeguarding customer information.

If anyone has a privacy/security contact at Bank of New York, I'd certainly be interested in talking to them!

(This is certainly not a new type of problem; see RISKS 21.83 for another example I wrote about 3 years ago.)"


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