Commissioners Open Investigation into Privacy Practices of Tim Hortons’ App

July 6, 2020

A joint investigation is looking into Tim Hortons (Restaurant Brands International Inc.) and its mobile app, specifically geolocation tracking and other privacy practices.

The investigation is being undertaken by the:

  • Office of the Information and Privacy Commissioner of Alberta
  • Office of the Privacy Commissioner of Canada
  • Commission d’accès à l’information du Québec
  • Office of the Information and Privacy Commissioner for BC

Numerous media reports about Tim Hortons’ app have raised questions and concerns among privacy authorities. The investigation will review whether Tim Hortons is obtaining consent to collect, use and disclose geolocation and associated data, including for the creation of detailed user profiles. Privacy Commissioners will also review whether Tim Hortons’ privacy practices are reasonable in the circumstances.

The four privacy regulators will examine whether Tim Hortons’ practices are in compliance with each jurisdiction’s private sector privacy legislation, including Alberta’s Personal Information Protection Act. (An overview of Canadian private sector privacy laws is available here.)

As this is an active investigation, no additional details are available at this time.