PIPEDA Schedule 1, clause 4.2.4: a purpose not previously identified needs the individual's consent (Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, Schedule 1, cl. 4.2.4)
Licensing support tickets, email, chat or call recordings to a US AI company is a purpose the customer was not told about when the records were collected. The holder needs the individual's consent before the records are used that way, unless a statutory exception applies.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“When personal information that has been collected is to be used for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is required by law, the consent of the individual is required before information can be used for that purpose.”
Where it was read
Also read from the same source
- For customers or staff in Canada, has each person consented to this new use, or will the data be anonymised to the Canadian standard before it leaves? For Quebec, is the privacy impact assessment done and the written agreement ready?
- PIPEDA Schedule 1, clause 4.5: no use or disclosure for other purposes without consent (Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, Schedule 1, cl. 4.5)
- PIPEDA section 5(3): only purposes a reasonable person would consider appropriate (Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, s. 5(3))
- PIPEDA section 7.2(4): the business transaction exception excludes the sale or lease of personal information itself (Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, s. 7.2(4))
- PIPEDA section 7(3)(f): disclosure without consent for statistical or scholarly research (Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, s. 7(3)(f))
- PIPEDA sections 2 and 4(1): commercial activity, and staff data only for federal works (Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, s. 2 (commercial activity), s. 4(1))
Figures it counts in
It is shown on its own, not counted into a figure.
Cited in these 2 guides