The plaintiff moved to certify a proposed class action against the Province of Ontario following an inadvertent data disclosure.
An employee of the Ministry of Children, Community and Social Services mistakenly emailed a spreadsheet containing the names, email addresses, and identification numbers of approximately 45,000 Ontario Disability Support Program recipients to 103 clients.
The plaintiff alleged intrusion upon seclusion, negligence, breach of confidence, and publication of private facts, claiming the disclosure caused distress.
The court found that no actual harm had materialized in the six years since the incident and that the plaintiff had publicly disclosed his own status.
Consequently, the court dismissed the motion for certification.
