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
Unified message for Ottawa: Premier Danielle Smith and Premier Scott Moe call for change to federal policies

United in call for change: Joint statement |
“Wednesday, Alberta’s and Saskatchewan’s governments came together in Lloydminster to make a unified call for national change.
“Together, we call for an end to all federal interference in the development of provincial resources by:
- repealing or overhauling the Impact Assessment Act to respect provincial jurisdiction and eliminate barriers to nation-building resource development and transportation projects;
- eliminating the proposed oil and gas emissions cap;
- scrapping the Clean Electricity Regulations;
- lifting the oil tanker ban off the northern west coast;
- abandoning the net-zero vehicle mandate; and
- repealing any federal law or regulation that purports to regulate industrial carbon emissions, plastics or the commercial free speech of energy companies.
“The federal government must remove the barriers it created and fix the federal project approval processes so that private sector proponents have the confidence to invest.
“Starting with additional oil and gas pipeline access to tidewater on the west coast, our provinces must also see guaranteed corridor and port-to-port access to tidewater off the Pacific, Arctic and Atlantic coasts. This is critical for the international export of oil, gas, critical minerals, agricultural and forestry products, and other resources. Accessing world prices for our resources will benefit all Canadians, including our First Nations partners.
“Canada is facing a trade war on two fronts. The People’s Republic of China’s ‘anti-discrimination’ tariffs imposed on Canadian agri-food products have significant impacts on the West. We continue to call on the federal government to prioritize work towards the removal of Chinese tariffs. Recently announced tariff increases, on top of pre-existing tariffs, by the United States on Canadian steel and aluminum products are deeply concerning. We urge the Prime Minister to continue his work with the U.S. administration to seek the removal of all tariffs currently being imposed by the U.S. on Canada.
“Alberta and Saskatchewan agree that the federal government must change its policies if it is to reach its stated goal of becoming a global energy superpower and having the strongest economy in the G7. We need to have a federal government that works with, rather than against, the economic interests of Alberta and Saskatchewan. Making these changes will demonstrate the new Prime Minister’s commitment to doing so. Together, we will continue to fight to deliver on the immense potential of our provinces for the benefit of the people of Saskatchewan and Alberta.”
Alberta
Calls for a new pipeline to the coast are only getting louder

From Resource Works
Alberta wants a new oil pipeline to Prince Rupert in British Columbia.
Calls on the federal government to fast-track new pipelines in Canada have grown. But there’s some confusion that needs to be cleared up about what Ottawa’s intentions are for any new oil and gas pipelines.
Prime Minister Carney appeared to open the door for them when he said, on June 2, that he sees opportunity for Canada to build a new pipeline to ship more oil to foreign markets, if it’s tied to billions of dollars in green investments to reduce the industry’s environmental footprint.
But then he confused that picture by declaring, on June 6, that new pipelines will be built only with “a consensus of all the provinces and the Indigenous people.” And he added: “If a province doesn’t want it, it’s impossible.”
And BC Premier David Eby made it clear on June 2 that BC doesn’t want a new oil pipeline, nor does it want Ottawa to cancel the related ban on oil tankers steaming through northwest BC waters. These also face opposition from some, but not all, First Nations in BC.
Eby’s energy minister, Adrian Dix, also gave thumbs-down to a new oil pipeline, but did say BC supports expanding the capacity of the existing Trans Mountain TMX oil pipeline, and the dredging of Burrard Inlet to allow bigger oil tankers to load Alberta oil from TMX at the port of Vancouver.
While the feds sort out what their position is on fast-tracking new pipelines, Alberta Premier Danielle Smith leaped on Carney’s talk of a new oil pipeline if it’s tied to lowering the carbon impact of the Alberta oilsands and their oil.
She saw “a grand bargain,” with, in her eyes, a new oil pipeline from Alberta to Prince Rupert, BC, producing $20 billion a year in revenue, some of which could then be used to develop and install carbon-capture mechanisms for the oil.
She noted that the Pathways Alliance, six of Canada’s largest oilsands producers, proposed in 2021 a carbon-capture network and pipeline that would transport captured CO₂ from some 20 oilsands facilities, by a new 400-km pipeline, to a hub in the Cold Lake area of Alberta for permanent underground storage.
Preliminary estimates of the cost of that project run up to $20 billion.
The calls for a new oil pipeline from Bruderheim, AB, to Prince Rupert recall the old Northern Gateway pipeline project that was proposed to run from Alberta to Kitimat, BC.
That was first proposed by Enbridge in 2008, and there were estimates that it would mean billions in government revenues and thousands of jobs.
In 2014, Conservative prime minister Stephen Harper approved Northern Gateway. But in 2015, the Federal Court of Appeal overruled the Harper government, ruling that it had “breached the honour of the Crown by failing to consult” with eight affected First Nations.
Then the Liberal government of Prime Minister Justin Trudeau, who succeeded Harper in 2015, effectively killed the project by instituting a ban on oil tanker traffic on BC’s north coast shortly after taking office.
Now Danielle Smith is working to present Carney with a proponent and route for a potential new crude pipeline from Alberta to Prince Rupert.
She said her government is in talks with Canada’s major pipeline companies in the hope that a private-sector proponent will take the lead on a pipeline to move a million barrels a day of crude to the BC coast.
She said she hopes Carney, who won a minority government in April, will make good on his pledge to speed permitting times for major infrastructure projects. Companies will not commit to building a pipeline, Smith said, without confidence in the federal government’s intent to bring about regulatory reform.
Smith also underlined her support for suggested new pipelines north to Grays Bay in Nunavut, east to Churchill, Manitoba, and potentially a new version of Energy East, a proposed, but shelved, oil pipeline to move oil from Alberta and Saskatchewan to refineries and a marine terminal in the Maritimes.
The Energy East oil pipeline was proposed in 2013 by TC Energy, to move Western Canadian crude to an export terminal at St. John, NB, and to refineries in eastern Canada. It was mothballed in 2017 over regulatory hurdles and political opposition in Quebec.
A separate proposal known as GNL Quebec to build a liquefied natural gas pipeline and export terminal in the Saguenay region was rejected by both federal and provincial authorities on environmental grounds. It would have diverted 19.4 per cent of Canadian gas exports to Europe, instead of going to the US.
Now Quebec’s environment minister Benoit Charette says his government would be prepared to take another look at both projects.
The Grays Bay idea is to include an oil pipeline in a corridor that would run from northern BC to Grays Bay in Nunavut. Prime Minister Carney has suggested there could be opportunities for such a pipeline that would carry “decarbonized” oil to new markets.
There have also been several proposals that Canada should build an oil pipeline, and/or a natural gas pipeline, to the port of Churchill. One is from a group of seven senior oil and gas executives who in 2017 suggested the Western Energy Corridor to Churchill.
Now a group of First Nations has proposed a terminal at Port Nelson, on Hudson Bay near Churchill, to ship LNG to Europe and potash to Brazil. And the Manitoba government is looking at the idea.
“There is absolutely a business case for sending our LNG directly to European markets rather than sending our natural gas down to the Gulf Coast and having them liquefy it and ship it over,” says Robyn Lore of project backer NeeStaNan. “It’s in Canada’s interest to do this.”
And, he adds: “The port and corridor will be 100 per cent Indigenous owned.”
Manitoba Premier Wab Kinew has suggested that the potential trade corridor to Hudson Bay could handle oil, LNG, hydrogen, and potash slurry. (One obvious drawback, though, winter ice limits the Hudson Bay shipping season to four months of the year, July to October.)
All this talk of new pipelines comes as Canada begins to look for new markets to reduce reliance on the US, following tariff measures from President Donald Trump.
Alberta Premier Smith says: “I think the world has changed dramatically since Donald Trump got elected in November. I think that’s changed the national conversation.”
And she says that if Carney wants a true nation-building project to fast-track, she can’t think of a better one than a new West Coast oil pipeline.
“I can’t imagine that there will be another project on the national list that will generate as much revenue, as much GDP, as many high paying jobs as a bitumen pipeline to the coast.”
Now we need to know what Mark Carney’s stance on pipelines really is: Is it fast-tracking them to reduce our reliance on the US? Or is it insisting that, for a pipeline, “If a province doesn’t want it, it’s impossible.”
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