A journalist requested an electronic database of municipal election campaign contributors from the City of Toronto to investigate potential breaches of contribution limits.
The City and the Assistant Information and Privacy Commissioner refused disclosure, citing privacy exemptions under the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA).
On judicial review, the Divisional Court held that the Commissioner erred in interpreting the Municipal Elections Act, finding the database was a public record prepared under the Act.
The Court further held that the Commissioner's decisions on the privacy exemption and public interest override were unreasonable, as the public interest in scrutinizing the democratic process outweighed the minimal privacy intrusion of disclosing contributors' telephone numbers.
The application was allowed and the database ordered disclosed.
