This notice explains how Aeroplan and its service provider, Persona Identities Inc. (“Persona”), handles the personal information of minors and their parent or legal guardian in connection with Aeroplan’s minor identity verification and fraud prevention service (“Instant Verification for Minors”).
Only the parent or legal guardian of an Aeroplan member aged 17 or younger (the “minor”) may complete the Instant Verification for Minors process and consent to the collection and use (including storage and deletion) of personal information required to validate the identity of the minor with Instant Verification for Minors.
1. How Instant Verification for Minors works
If you check the checkbox to confirm that you are the parent or legal guardian of the minor and that you consent to the collection and use of both the minor’s personal information and your own as described in this notice, then:
- You will be guided to use your mobile device to take photos of the minor’s passport, driver’s license, NEXUS card or other accepted and valid government ID (“government ID”).
- You will be asked to upload the photos of the minor’s government ID.
- Persona will validate the authenticity of the minor’s government ID and confirm that the information on it matches their Aeroplan member information.
- If the government ID is authentic and matches the minor’s Aeroplan member information, the minor’s identity is verified. If the government ID is not authentic and/or the information does not match the minor’s Aeroplan member information, the minor’s identity is not verified. This decision is based solely on the automated processing of information.
- The photos of the minor’s government ID will be deleted promptly after they are used to verify the minor’s identity. Your information will be retained until the minor turns 18, subject to any legal requirement (see Section 2).
2. Personal information collected and used for Instant Verification for Minors
- Minor’s information
- Aeroplan Member Information (member number, name, address and date of birth)
- photos of the government ID and the information it contains, excluding data restricted by law where the minor lives
The Aeroplan member information is used to ensure that a valid account associated with a minor matches the information on the minor’s government ID. The government ID is used to verify the minor’s identity. The photos of the minor’s government ID will be deleted promptly after the Instant Verification for Minors process is completed.
- Parent or legal guardian information
- first and last name and Aeroplan number
- Technical and connection information such as: IP address, device operating system (OS), device type, browser type and general geolocation data.
This information will be used to identify the person who provided parental or legal guardian consent and to prevent and detect fraud related to Aeroplan accounts. This information will be retained until the minor turns 18, or for a longer period if required by law, after which it is destroyed.
3. Protection of personal information collected and used for Instant Verification for Minors
Persona and its subcontractors are contractually required to handle the personal information collected and used for Instant Verification for Minors only on the instructions of Aeroplan. They may not disclose it or use it for their own business or commercial purposes. The information will be processed in Canada and in the United States of America, possibly outside the province or state where you or the minor live. This means the personal information may be subject to the laws of these jurisdictions, which may permit access by courts, law enforcement or other governmental authorities.
Persona and its subcontractors are contractually required to meet stringent data protection requirements. All information used for Instant Verification for Minors will be protected by physical, technological and organizational security measures. For example, the information is encrypted in transit and at rest, and the systems that process it are subject to a vulnerability management program. Access to personal information is monitored and limited to authorized personnel who need it to perform their duties in connection with Instant Verification for Minors. At the end of the retention period, the personal information is destroyed.
4. Other options for verifying the minor’s identity
The minor’s identity can be verified without using Instant Verification for Minors if:
- The minor flies or has already flown on two Air Canada, Air Canada Rouge or Air Canada Express operated flights on two separate bookings within the last five years. In this case, Air Canada verifies their identity in person when checking their government ID at boarding.
or
- The parent or legal guardian of the minor presents the minor’s proof of identity in person to an Air Canada representative at one of the following airports: Montreal Trudeau (YUL); Chicago O’Hare (ORD) or Charles de Gaulle (Paris-CDG).
Find out more about these options for identity verification.
5. More Information
For more information on how Aeroplan handles your personal information, consult the Aeroplan Privacy Policy
If you have concerns or further questions or wish to withdraw your consent, make a formal access or correction request or terminate your Aeroplan membership, please contact our Principal Privacy Officer using the contact information below.
Email:
AeroplanPrivacy@aircanada.ca
Address:
Aeroplan Principal Privacy Officer
P.O. Box 23000
Station Pointe-Claire-Dorval
Pointe-Claire, QC H9Y 1K2
Please note that we will need to take reasonable steps to validate your identity prior to disclosing any personal information via the above communication channels.