Retailer requires photo identification to exchange an item

PIPEDA Case Summary #2006-361

[Principles 4.2, 4.3, 4.3.2, 4.3.3 and subsection 5(3)]

When a customer attended a store to exchange a defective item, he was annoyed to learn that he had to provide photo identification in order to make the exchange. Although the store had notices posted in a number of places indicating that photo identification is required for a return or an exchange, there was no explanation of why it is needed or how it may be used.  The Assistant Privacy Commissioner found the store’s purpose for requiring this information appropriate, and agreed that the provision of photo identification could be a condition of service in certain circumstances. However, she was concerned that the purpose was not being identified, nor the use or disclosure of personal information explained. She made a number of recommendations to the store, which the store agreed to implement.

This complaint is similar to others that were investigated by the Alberta and British Columbia Offices of the Information and Privacy Commissioner. The relevant investigation reports can be found at: