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
Alberta health care blockbuster: Province eliminating AHS Health Zones in favour of local decision-making!
Hospital Based Leadership: Eliminating the bureaucratic vortex in hospitals
Since Alberta’s government announced plans to refocus the health care system in November 2023, a consistent message has emerged from patients, front-line health care workers and concerned Albertans alike about the flaws of the prior system. Alberta Health Services’ current zone-based leadership structure is overly complex and bureaucratic. It lacks the flexibility and responsiveness needed to effectively support facilities and staff – particularly when it comes to hiring, securing supplies and adopting necessary technologies.
That’s why Alberta’s government is changing to a hospital-based leadership structure. On-site leadership teams will be responsible for hiring staff, managing resources and solving problems to effectively serve their patients and communities. Hospitals will now have the flexibility to respond, freedom to adapt and authority to act, so they can meet the needs of their facilities, patients and workforce in real time.
“What works in Calgary or Edmonton isn’t always what works in Camrose or Peace River. That’s why we’re cutting through bureaucracy and putting real decision-making power back in the hands of local hospital leaders, so they can act fast, hire who they need and deliver better care for their communities.”
“Hospital-based leadership ensures decisions on hiring, supplies and services are made efficiently by those closest to care – strengthening acute care, supporting staff and helping patients get the timely, high-quality care they need and deserve.”
“By rethinking how decisions are made, we’re working to improve health care through a more balanced and practical approach. By removing delays and empowering our on-site leaders, we’re giving facilities the tools to respond to real-time needs and ultimately provide better care to Albertans.”
AHS’ health zones will be eliminated, and acute care sites will be integrated into the seven regional corridors. These sites will operate under a new leadership model that emphasizes site-level performance management. Clear expectations will be set by Acute Care Alberta, and site operations will be managed by AHS through a hospital-based management framework. All acute care sites will be required to report to Acute Care Alberta based on these defined performance standards.
“Standing up Acute Care Alberta has allowed AHS to shift its focus to hospital-based services. This change will enable the local leadership teams at those hospitals to make site-based decisions in real and tangible ways that are best for their patients, families and staff. Acute Care Alberta will provide oversight and monitor site-level performance, and I’m confident overall hospital performance will improve when hospital leadership and staff have more authority to do what they know is best.”
“AHS is focused on reducing wait times and improving care for patients. By shifting to hospital-based leadership, we’re empowering hospital leaders to make real-time decisions based on what’s happening on the ground and respond to patient needs as they arise. It also means leaders can address issues we know have been frustrating, like hiring staff where they’re needed most and advancing hospital operations. This change enables front-line teams to act on ideas they see every day to improve care.”
The Ministry of Hospital and Surgical Health Services, Acute Care Alberta and Alberta Health Services will work collaboratively to design and establish the new leadership and management model with an interim model to be established by November 2025, followed by full implementation by summer 2026.
Quick facts
- Countries like the Netherlands and Norway, and parts of Australia have already made the shift to hospital-based leadership.
- The interim hospital-based leadership model will be implemented at one site before being implemented provincewide.
- Hospital-based leadership, once implemented, will apply only to AHS acute care facilities. Other acute care organizations will not be affected at the time of implementation.
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Alberta
Alberta is investing up to $50 million into new technologies to help reduce oil sands mine water
Technology transforming tailings ponds
Alberta’s oil sands produce some of the most responsible energy in the world and have drastically reduced the amount of fresh water used per barrel. Yet, for decades, operators have been forced to store most of the water they use on site, leading to billions of litres now contained largely in tailings ponds.
Alberta is investing $50 million from the industry-funded TIER system to help develop new and improved technologies that make cleaning up oil sands mine water safer and more effective. Led by Emissions Reduction Alberta, the new Tailings Technology Challenge will help speed up work to safely reclaim the water in oil sands tailing ponds and eventually return the land for use by future generations.
“Alberta’s government is taking action by funding technologies that make treating oil sands water faster, effective and affordable. We look forward to seeing the innovative solutions that come out of this funding challenge, and once again demonstrate Alberta’s global reputation for sustainable energy development and environmental stewardship.”
“Tailings and mine water management remain among the most significant challenges facing Alberta’s energy sector. Through this challenge, we’re demonstrating our commitment to funding solutions that make water treatment and tailings remediation more affordable, scalable and effective.”
As in other mines, the oil sands processing creates leftover water called tailings that need to be properly managed. Recently, Alberta’s Oil Sands Mine Water Steering Committee brought together industry, academics and Indigenous leaders to identify the best path forward to safely address mine water and reclaim land.
This new funding competition will support both new and improved technologies to help oil sands companies minimize freshwater use, promote responsible ways to manage mine water and reclaim mine sites. Using technology for better on-site treatment will help improve safety, reduce future clean up costs and environmental risks, and speed up the process of safely addressing mine water and restoring sites so they are ready for future use.
“Innovation has always played an instrumental role in the oil sands and continues to be an area of focus. Oil sands companies are collaborating and investing to advance environmental technologies, including many focused on mine water and tailings management. We’re excited to see this initiative, as announced today, seeking to explore technology development in an area that’s important to all Albertans.”
Quick facts
- All mines produce tailings. In the oil sands, tailings describe a mixture of water, sand, clay and residual bitumen that are the byproduct of the oil extraction process.
- From 2013 to 2023, oil sands mine operations reduced the amount of fresh water used per barrel by 28 per cent. Recycled water use increased by 51 per cent over that same period.
- The Tailings Technology Challenge is open to oil sands operators and technology providers until Sept. 24.
- The Tailings Technology Challenge will invest in scale-up, pilot, demonstration and first-of-kind commercial technologies and solutions to reduce and manage fluid tailings and the treatment of oil sands mine water.
- Eligible technologies include both engineered and natural solutions that treat tailings to improve water quality and mine process water.
- Successful applicants can receive up to $15 million per project, with a minimum funding request of $1 million.
- Oil sands operators are responsible for site management and reclamation, while ongoing research continues to inform and refine best practices to support effective policy and regulatory outcomes.
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