🟠Mogo Finance Technology Inc.–Consumer Report Records, Risk & Consent Profile
Regulator(OPC), Privacy Contact Email privacy@mogo.ca
Last OS File: Successfully guided Mogo Finance Technology Inc., via the Office of the Privacy Commissioner, to improve disclosure of hard inquiry information and enhance access request procedures for clearer, more informed consumer access.
Consent Quality
❌ Incomplete
Secure e-signature not provided; no response to request
Risk Disclosure
đź”´ Absent
- No communication of risk, harm, or consequence.
- No disclosure of potential risks to the consumer, including bodily harm, humiliation, damage to reputation or relationships, loss of employment, business or professional opportunities, financial loss, identity theft, negative effects on the credit record, or damage to/loss of property.
Mandatory Notices
đź”´ Absent
- No written notice of intention to obtain a consumer report provided to the consumer before requesting the report. (s. 10(2))
- Notice of intention to obtain consumer report from a consumer reporting agency for the purposes of extending credit not provided at the time of application for credit. (s. 10(3))
- Consumer not notified in writing that personal information may be shared with other credit grantors or agencies. (s. 10(5))
- Notice not clearly set forth in bold or underlined text, or letters smaller than ten-point size. (s. 10(6))
Consumer Transparency Improvements
- Successfully led recommendations to Mogo Finance Technology Inc., through the Office of the Privacy Commissioner of Canada, to remove hard inquiry information from the informational pop-up — which was only triggered when a user clicked the information icon — and relocate it to a more visible, unobstructed section of the interface. This change will help consumers make more informed decisions when assessing services.
Successfully led Mogo Finance Technology Inc. to amend its policies and practices regarding access requests, ensuring more thorough searches for personal information are completed. This will help consumers gain access to personal information with due diligence and timely responses from the organization.
🔍 Key Recommendations from OPC
The Commissioner recommended to banks that application forms should indicate that:
- A customer does not have the option of withdrawing consent to the bank’s disclosure of credit information to the credit bureaus.
- Banks should include a statement of purpose for the ongoing disclosure of credit information to the credit bureaus(i.e., to maintain the integrity of the credit granting system)
- The collection of name, address, date of birth, and occupation of the applicant are required by law.
đź“„ Supporting Documents
- OPC Decision – File #2005-296
- Sample Credit Application Screenshot
- Guidelines for Obtaining Meaningful Consent
- Consumer Reporting Act
- Template: Request for Proof of Consent
đź“Ł User-Submitted Complaint
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