PIPEDA-2015-009
Date: 2015
Summary: OPC determined that consent obtained through a 2008 credit application and a 2010 contract was insufficient for future or ongoing credit checks. Each “hard pull” of a credit report—given its sensitivity, disclosure to credit bureaus, and potential to affect credit scores—requires separate, explicit, and timely consent. The report distinguished “hard pulls” from “soft pulls,” noting that hard pulls can harm creditworthiness and are visible to other lenders, while soft pulls do not have these effects.
