Registrar of Consumer Reporting Agencies, Ontario

The letter · 30 September 2026

Written complaint under section 16 of the Consumer Reporting Act: TransUnion of Canada bars section 12 disclosure to a consumer who holds no driver licence and no Canadian passport

Attention: Registrar of Consumer Reporting Agencies, Consumer Services Operations Division, PO Box 450, Toronto, Ontario [postal code]

Hello,

This is a written complaint under section 16 (1) of the Consumer Reporting Act. The agency is TransUnion of Canada, Inc.

On 17 September 2026 I requested my consumer report and my consumer score. TransUnion closed every written channel it publishes, and then put the bar in writing.

The online portal at http://ocs.transunion.ca returned http://system_error.page twice. Fax line [phone], published by TransUnion for disclosure requests, rejected the transmission twice. A live chat agent who gave his name as Scott sent me to a telephone line at 18:20: "As a front-line agent, I don't have access to credit file details through chat due to privacy and security reasons... Please contact them at [phone]."

At 18:41 the same agent stated: "Based on the accepted ID list available to us, Ontario Photo Card and IMM 1442 Work Permit are not listed as accepted primary identification documents."

At 19:12 he returned from checking the policy and confirmed it: "I have checked the identification requirements, and at least one Primary Government-Issued Identification document is required. Accepted primary IDs include: Driver's License / Canadian Passport / Certificate of Indian Status / Birth Certificate / Permanent Resident Card. Additional documents... may be used as supporting identification but do not replace the requirement for a primary ID document."

At 19:21 he excluded the passport I hold: "a Canadian Passport is the accepted passport listed as Primary Government-Issued Identification."

At 19:19 he named no written route to an exception: "As a front-line agent, I do not have access to policy owner details, or internal policy documents."

Four of those documents go only to citizens and permanent residents. The fifth is a driver licence. The Ontario Photo Card is the only photographic identity document this province issues to a person who does not drive, and TransUnion excludes it. The IMM 1442 work permit is the federal document that establishes my status here, and TransUnion excludes it. A lawful resident of Ontario who does not drive and is not yet a citizen therefore has no route to his own file.

Section 12 (1) gives that consumer the same right as everyone else. It sets no condition of citizenship, status or a driver licence. Section 12 (6) (a) requires the consumer to provide "a copy of any prescribed identification and a copy of any other identification the agency may reasonably require to verify the consumer's identity". R.R.O. 1990, Regulation 177 is the only regulation made under the Act. It prescribes no identification: the word identification does not appear in it. The list is TransUnion's own instrument. It holds only to the extent the Act allows an agency to require it. A list that excludes every document a lawfully resident non-driver can hold is not identity verification. It is a bar to the right, and TransUnion put it in writing.

Three further provisions were breached the same day. Section 12 (7) requires disclosure by the method the consumer chooses, and mail and electronic delivery are on that list. I chose both, and TransUnion answered with a telephone number. Section 12 (8) 2 sets electronic disclosure at two business days. Section 12 (11) requires trained personnel to explain the information disclosed. The only person TransUnion made available held no access to the file or the policy. My file also carries an address in London, England where I have never lived, and section 13 (1) obliges TransUnion to correct it.

I sent a written access request to [email] at 19:47 on 17 September 2026. TransUnion acknowledged it that evening and undertook a response in "two business days or less". Nine business days later it has produced nothing.

The Registrar is required to act on the following.

Direct TransUnion under section 16 (1) to furnish its identification policy, the date that policy took effect and the officer who owns it. Direct it to name the written route by which a consumer holding none of the five listed documents obtains disclosure under section 12.

Inquire under section 16.1 (1) into the practice of gating section 12 disclosure behind documents issued only to citizens, permanent residents and drivers. Inquire into the telephone condition as well. Order that practice amended or discontinued under section 16.1 (3).

Order TransUnion under section 14 (1.1) to correct the London, England address on my file.

State whether any identification is prescribed under section 12 (6) (a). If none is prescribed, state that TransUnion's list carries no force beyond what section 12 (6) (a) allows an agency to require.

Confirm in writing which documents TransUnion must accept from a consumer whose identity documents are an Ontario Photo Card and an IMM 1442 work permit.

Answer by 22 October 2026. That is the fifteenth business day from today, and it is the period your own complaint page sets for contacting a complainant.

Section 23 (1) (c) makes a contravention of section 12 an offence. The fine reaches $50,000 for an individual and $250,000 for a corporation. If the Registrar takes no step by 22 October 2026, this file goes to the Ombudsman of Ontario as administrative inaction. The identification bar goes to the Human Rights Tribunal of Ontario under section 1 of the Human Rights Code. The grounds are citizenship and place of origin, in the provision of a service.

Respectfully,

Danilo Dzyuban
Ottawa, Ontario [postal code]