Tom Wright

The appellant requested access to the exact salaries of the Chief and Deputy Chief of Police for 1991.

The Board denied access under various exemptions of the Municipal Freedom of Information and Protection of Privacy Act.

The Commissioner found that the exact salaries were exempt as personal information whose disclosure would constitute an unjustified invasion of personal privacy.

However, finding that the disclosure of salary ranges is in the public interest, the Commissioner ordered the Board to prepare and disclose salary ranges for the positions.

The appellant appealed the Ministry of Health's decision to deny access to two records under the Freedom of Information and Protection of Privacy Act.

The Ministry claimed exemptions under section 12 (Cabinet records) for a draft report and section 19 (solicitor-client privilege) for a legal memorandum.

The Commissioner found that parts of the draft report did not qualify for the section 12 exemption as they would not reveal the substance of Cabinet deliberations, and ordered their disclosure.

The Commissioner upheld the Ministry's decision to deny access to the remainder of the draft report and the legal memorandum in its entirety.

The appellant requested access to consultant reports from Stadium Corporation of Ontario Limited (SkyDome) under the Freedom of Information and Protection of Privacy Act.

SkyDome provided a fee estimate and required a deposit before processing the request, but did not issue a final decision on access.

The Commissioner found that SkyDome failed to properly discharge its obligations under sections 26 and 29(1)(b) of the Act, as it did not provide a final decision letter within 30 days.

SkyDome was ordered to issue a final decision letter to the appellant.

The Ministry of the Solicitor General received a request under the Freedom of Information and Protection of Privacy Act for a police inspection report.

The Ministry granted partial access, denying parts under sections 14 and 21.

The requester appealed.

The Commissioner upheld most of the Ministry's exemptions, finding that the severed information contained personal information and law enforcement details whose disclosure could interfere with an investigation or endanger safety.

However, the Commissioner ordered the disclosure of two pages where the exemptions did not apply.

The requester appealed the Ministry of Transportation's decision to deny access to a nine-page investigation report regarding complaints against a company holding licences under the Truck Transportation Act.

The Ministry claimed exemptions under sections 14 and 17 of the Freedom of Information and Protection of Privacy Act.

The Commissioner found that the record met the three-part test for exemption under section 14(2)(a) as a report prepared in the course of an investigation by an agency with the function of enforcing compliance with a law.

The Ministry's decision to deny access was upheld.

The Ottawa Police Force received a request under the Municipal Freedom of Information and Protection of Privacy Act for all information relating to the requester.

The Police decided to release certain records relating to two third parties, who then appealed the decision.

The Commissioner found that the records contained personal information and that their disclosure would constitute a presumed unjustified invasion of privacy under section 14(3)(b).

However, the Commissioner upheld the Police's exercise of discretion under section 38(b) to disclose the records, noting that the information had already been revealed in court proceedings.

The Information and Privacy Commissioner considered nine appeals regarding access to a police investigation report concerning the Windsor Board of Education.

During the appeals, the Commissioner was notified of two Ontario Court (General Division) orders restricting the disclosure and dissemination of the record to parties in an ongoing civil action.

The Commissioner determined that proceeding with the appeals could violate the injunctive court orders and risk contempt of court.

Consequently, the Commissioner ordered the appeals discontinued and the files closed without deciding the substantive exemption issues.

The appellant requested access to police reports and witness statements concerning a first-degree murder charge.

The Sudbury Regional Police denied access to most of the records, citing various exemptions under the Municipal Freedom of Information and Protection of Privacy Act.

The Commissioner found that most of the records contained personal information of individuals other than the appellant, compiled during a law enforcement investigation, and their disclosure would constitute an unjustified invasion of personal privacy under section 38(b).

The Commissioner also found that the 'Alcohol Influence Test Report' qualified for exemption under section 8(2)(a) as a law enforcement report.

However, the Commissioner ordered the disclosure of a few specific pages, including a consent form and a 'will say' statement, finding that they did not qualify for the claimed exemptions.

The appellant requested access to Toronto Fire Department records relating to an incident where a deceased individual was found.

The City denied access to portions of the records, citing the personal privacy exemption under the Municipal Freedom of Information and Protection of Privacy Act.

The Commissioner found that while the records contained personal information, the appellant did not establish they were the personal representative of the deceased.

However, the Commissioner concluded that the privacy interest diminishes upon death, and in these circumstances, disclosure would not constitute an unjustified invasion of personal privacy.

The City was ordered to disclose the records.

The appellant requested information from the City of Mississauga regarding its use of private investigators, specifically concerning an investigation into the appellant.

The City refused to confirm or deny the existence of the records under section 8(3) of the Municipal Freedom of Information and Protection of Privacy Act, claiming they would be exempt under law enforcement provisions.

The Commissioner found that the records related to an employment disciplinary matter, not 'law enforcement' as defined in the Act.

Therefore, the exemptions did not apply, and the City could not rely on section 8(3).

The Commissioner ordered the City to disclose the non-identifying portions of the records.

The appellant requested access to ambulance incident reports relating to the discovery of a deceased individual's body.

The Municipality denied access under the personal privacy exemption in section 14 of the Municipal Freedom of Information and Protection of Privacy Act.

The Commissioner found that the appellant could not exercise the deceased's right of access under section 54(a) without proof of being the personal representative.

However, the Commissioner determined that disclosing the deceased's personal information would not constitute an unjustified invasion of privacy, as the privacy interest diminishes upon death.

The Municipality was ordered to disclose the records, with the personal information of other identifiable individuals severed.

The appellant appealed a decision by the Hamilton-Wentworth Regional Board of Commissioners of Police to deny access to police records relating to an alleged offence.

The Commissioner found that the records contained personal information of both the appellant and affected persons.

The Commissioner upheld the police's decision to deny access under section 38(b) of the Municipal Freedom of Information and Protection of Privacy Act, concluding that disclosure would constitute an unjustified invasion of the affected persons' personal privacy as the information was compiled as part of an investigation into a possible violation of law.

The appellant appealed a decision by the Metropolitan Toronto Police denying access to portions of a police report regarding alleged threats made by the appellant.

The Commissioner found that the severed information, except for the occurrence number, constituted personal information and its disclosure would be an unjustified invasion of the affected person's privacy under section 38(b) of the Municipal Freedom of Information and Protection of Privacy Act.

The police were ordered to disclose only the occurrence number, as it did not qualify for exemption under sections 8(1)(e) or 8(2)(a).

The appellant requested a copy of an estimate of the cost to complete a subdivision agreement from the Township of Mara.

The Township denied access under section 7(1) of the Municipal Freedom of Information and Protection of Privacy Act, claiming the record contained advice or recommendations.

The Commissioner found that the record, a preliminary estimate of costs prepared by an engineering firm, contained mere information and not a suggested course of action.

The Township was ordered to disclose the record.

The requester sought the home address of a hot dog vendor from the Metropolitan Licensing Commission in order to pursue a civil action for injuries allegedly caused by glass particles in a hot dog.

The Commission denied access under section 14 of the Municipal Freedom of Information and Protection of Privacy Act.

The Information and Privacy Commissioner upheld the decision, finding that the address was personal information and its disclosure would constitute an unjustified invasion of privacy, as it was not required for the requester to proceed with a civil action.

The appellant, retained by an insurance company for a subrogated claim, requested the names and addresses of two nine-year-old children investigated by the police in relation to a fire.

The police denied access under section 14 of the Municipal Freedom of Information and Protection of Privacy Act, claiming disclosure would be an unjustified invasion of privacy.

The appellant argued that since the children were under twelve, they could not be charged under the Young Offenders Act, meaning there was no 'possible violation of law' under section 14(3)(b).

The Commissioner rejected this narrow interpretation, finding the police conducted an investigation into a possible violation of law before deciding not to lay charges.

The Commissioner also found that while section 14(2)(d) (fair determination of rights) was a relevant consideration, it was not sufficient to rebut the presumption of an unjustified invasion of privacy.

The police's decision to deny access was upheld.

The appellant requested access to information relating to the classification of his position under the institution's proposed pay equity plan, specifically the points given for each category.

The institution denied access, claiming exemptions under sections 10(1)(a) and 11(c) of the Municipal Freedom of Information and Protection of Privacy Act.

The Commissioner found that the record, which included a job evaluation manual prepared by a consulting firm, did not meet the three-part test for exemption under section 10(1)(a) because it was not supplied in confidence and disclosure would not cause the specified harms, noting that disclosure under the Act does not infringe copyright.

The Commissioner also found that section 11(c) did not apply, as disclosure could not reasonably be expected to prejudice the institution's economic interests or competitive position.

The institution was ordered to disclose the records.

A requester sought access to City of Toronto files relating to storm sewer construction.

The City decided to release the records, but a third-party company appealed, arguing the records contained confidential commercial information, economic interests, and personal information of its representatives.

The Commissioner dismissed the appeal, finding that the information was not supplied in confidence, the company could not claim a discretionary exemption not raised by the City, and the names of corporate representatives did not constitute personal information.

The City was ordered to disclose the records.

The appellant requested copies of work orders issued by the City of Kitchener against residential rental properties for non-compliance with property standards.

The city denied access under the law enforcement exemptions in sections 8(1)(a) and 8(2)(a) of the Municipal Freedom of Information and Protection of Privacy Act.

The Commissioner found that the Orders to Comply were not 'reports' under section 8(2)(a) and that the city failed to establish a reasonable expectation of interference with a law enforcement matter under section 8(1)(a).

The city was ordered to disclose the records with the names and addresses of the property owners severed.

The appellant requested access to the number of hours worked by three municipal office staff members during January 1991.

The township denied access under the personal privacy exemption of the Municipal Freedom of Information and Protection of Privacy Act.

The Commissioner found that the records contained personal information and that, because the exact hourly wage of each employee was public knowledge by by-law, disclosing the hours worked would reveal their actual income.

This constituted a presumed unjustified invasion of personal privacy under section 14(3)(f), which was not rebutted by any other factors.

The township's decision to deny access was upheld.