Canada: Closed Investigation into Home Depot of Canada Inc.’s compliance with PIPEDA

On 26 January 2023, the Office of the Privacy Commissioner of Canada (OPC) closed an investigation into Home Depot of Canada Inc. for alleged disclosure of customers' personal information to Facebook's Meta Platforms without obtaining proper knowledge and consent. The company had been utilizing a tool called "Offline Conversions" which allows businesses to measure the effectiveness of their ads on Meta. The investigation revealed that Home Depot was forwarding customers' hashed email addresses and purchase details to Meta when customers provided their email addresses to Home Depot at the time of check-out for e-receipts. The OPC found that the company's claim of obtaining implied consent through their privacy policy and Meta's privacy policy was not sufficient and that express opt-in consent should have been obtained. As a result, Home Depot agreed to implement the OPC's recommendations and discontinued the use of the Offline Conversions tool in October 2022.