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
‘Tragic accident’ blamed for recent death of giraffe at Calgary Zoo

The Wilder Institute/Calgary Zoo says a “tragic accident” led to the recent death of an adult Masai giraffe. A statement from the zoo says the female giraffe named Emara died May 19 after tangling one of her horns on a cable surrounding her enclosure. THE CANADIAN PRESS/HO-Wilder Institute/Calgary Zoo-Sergei Belskey
Calgary
The Calgary Zoo says a “tragic accident” led to the recent death of one of its adult Masai giraffes.
A statement from the zoo says a female giraffe named Emara died May 19 after tangling one of her horns in a cable surrounding her enclosure.
The statement says a necropsy revealed Emara fell against the enclosure fence and died almost instantly of a broken neck.
Emara, who had just turned 12, came to Calgary from the San Diego Zoo in 2016.
The statement says she was a treasured member at the zoo and was known for her cautious yet curious personality and gentle nature.
The zoo says it is checking fencing within its African Savannah Yard enclosure to see if changes are needed to better protect the other giraffes and animals that share the space.
Doug Whiteside, interim associate director of animal care and welfare at the zoo, said Emara was in her prime and was in excellent health when she died.
“Major life changes such as this not only affect our people but can affect our animal residents as well,” Whiteside said in the statement Monday.
He said the zoo’s remaining giraffes, Nabo and Moshi, are doing well.
Grief counsellors are being made available to Emara’s caregivers and other zoo staff.
This report by The Canadian Press was first published May 29, 2023.
2023 Election
Some of the memorable comments made during Alberta election campaign

United Conservative Party leader Danielle Smith makes an election campaign announcement in Calgary on Monday, May 1, 2023.THE CANADIAN PRESS/Jeff McIntosh
Candidates for both the United Conservative Party and New Democrats have been campaigning over the last four weeks for their party to form the next Alberta government. Election day is Monday.
Here are some memorable quotes from the campaign:
“(The NDP) devastated the Alberta economy. They created policies that drove investment out, drove jobs out, and we had to reverse all of that,” UCP Leader Danielle Smith said on May 1, the day the writ was dropped. “The choice in this election couldn’t be clearer. It’s a choice between a UCP government that will cut your taxes and make life more affordable or an NDP government that will make you pay more across the board.”
—
“Over the past four years, our health care has been thrown into chaos by the UCP,” NDP Leader Rachel Notley said during the first week of the campaign. “They’ll tell you they fixed it, but Albertans aren’t feeling it and they’re not buying it … our (emergency rooms) are still full, our ambulances are still delayed and many (patients) are waiting months and months for critical tests and surgeries.”
—
“I am satisfied Mr. Pawlowski intended to incite the audience to continue the blockade — intended to incite protesters to commit mischief,” Justice Gordon Krinke said in Lethbridge, Alta., on May 2, when he found Calgary pastor Artur Pawlowski guilty of charges related to his role in protests against COVID-19 public health measures. In a leaked phone call between Smith and Pawlowski, before his trial, Smith told Pawlowski the charges against him were politically motivated and she would make inquiries on his behalf and report back.
—
“(Smith) has a policy of not speaking publicly on matters before the courts, except when she’s talking to the person who’s before the courts about how she’s going to interfere with the matter before the courts,” Notley said when asked to comment on Smith’s no comment on the Pawlowski case. “That is the most ridiculous thing I’ve ever heard from her. OK, maybe it’s not the most ridiculous, because there’s a lot of ridiculous.”
—
“COVID was a really difficult and frustrating time for everyone, including me, and I don’t think that there is a single one of us that wasn’t deeply impacted in some way,” Smith said on May 9, after past comments surfaced in which she equated those vaccinated against COVID-19 to Nazi supporters and said she would not wear a Remembrance Day poppy out of disgust for pandemic restrictions imposed by political leaders. “Sometimes I let my frustrations get to me during that time. I clearly shouldn’t have.”
—
“That little bit of poop is what wrecks it … it does not matter that we’re in the top three per cent in the world,'” said Jennifer Johnson, UCP candidate for Lacombe-Ponoka. In a tape from September, she said Alberta’s high-ranking education system counts for little when set against the issue of transgender students and compared their presence to a batch of cookies laced with feces.
—
“(Judicial independence) is a fundamental pillar of our democracy. The premier breached this principle by discussing the accused’s case,” ethics commissioner Marguerite Trussler said in her report released May 18 into Smith’s actions as premier when she called her justice minister about Pawlowski’s case.
—
“I’ve asked the ethics commissioner to give advice,” Smith said May 19. “I am a non-lawyer. As premier, I do need to be able to get advice from my top official, my top legal adviser. If she has recommendations on how to do that better next time, I will absolutely accept them.”
—
“More and more conservatives are coming to me saying, ‘I’m a lifelong conservative voter, but what I see in Danielle Smith and this new UCP is not my values,'” Notley said on May 23.”They often say that they’re going to lend us their vote, and I say that’s just great. Because, quite frankly, I think all Albertans should always only ever lend their vote because leadership has to earn it.”
—
“(The phone call) was always about the charges, from the very beginning. I had nothing really else to say,” Pawlowski told reporters at the legislature in the final week of the campaign. “This phone call was always about the same thing: when are you going to introduce what you promised, the amnesty bill for people like me and thousands of other Albertans.”
—
This report by The Canadian Press was first published May 28, 2023.
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