The Office of the Privacy Commissioner of Canada announced health analytics company Biron Groupe Santé halted improper marketing emails following an investigation. Biron administered COVID-19 tests at Montreal-Trudeau International Airport and used subsequent contact information from tested travelers to serve marketing emails without consent. The OPC made clear that when "seeking consent from individuals to use their personal information for secondary purposes" entities must consider "the specific circumstances" around collection along with sensitivity of the data and reasonable expectations of the data subject.