AM v. Halton Children’s Aid Society, 2020 CFSRB 16

CHILD AND FAMILY SERVICES REVIEW BOARD

BETWEEN:

AM Applicant

-and-

Halton Children’s Aid Society Respondent

DECISION

Adjudicator: Brenda Bowlby Date: February 20, 2020 Citation: 2020 CFSRB 16 Indexed As: AM v Halton Children’s Aid Society (CYFSA s.120)

APPEARANCES

AM, Applicant Self-represented

Halton Children’s Aid Society, Respondent Diane Skrow, Counsel

Introduction

1This is an Application filed under section 120 of the Child, Youth and Family Services Act, 2017, S.O. 2017, c.14, Sched.1, (the “Act”).

2The Child and Family Services Review Board (“CFSRB”) found the Application to be eligible to proceed under subsections 120(4)4 and 120(4)5 of the Act. I must decide whether the Society met its obligations regarding both aspects of the Applicant’s complaint

3A Pre-Hearing was held on December 6, 2019, in which it was determined that there would be a hearing with respect to the Applicant’s complaints respecting the interactions between the Respondent’s staff and the Applicant and his family on September 26, 2018 and the alleged flaws in the way in which the Respondent dealt with the Applicant’s concerns on September 26, 2018, including during the ICRP.

4The hearing was held on January 29, 2020. I heard evidence from the Applicant, and, on behalf of the Respondent, I heard from Child Protection Worker Ariela Babiev (“AB”) and Executive Director, Janice Robinson (“JR”). Following the completion of evidence, the parties agreed to provide their arguments by way of written submissions. They agreed that both parties would submit their written arguments at the same time on February 5, 2020 and that they would forego any opportunity to respond to the other’s arguments.

5The Applicant focused his case on the following issues:

• His son was not accorded the right to be heard because the questions asked were not open ended as required by Ministry Standards;
• He was not accorded the right to be heard by the ICRP because the members of the committee did not appear to have prepared properly for the meeting and, in particular, had not read his file.
• The reasons provided by the ICRP are so lacking in substance and reason that they did not meet the test of what constitutes adequate reasons.

DECISION

6While the Applicant has raised genuine concerns about the manner in which his son was questioned by the child protection worker, I find that the evidence does not support his complaints. I find that the Applicant’s son was provided with an adequate opportunity to be heard. Further, I find that the Applicant was given an opportunity to be heard by the ICRP and was provided with adequate reasons for the dismissal of his complaint.

the law

7The relevant sections of the Act are as follows:

119 (1) A person may make a complaint to a society relating to a service sought or received by that person from the society in accordance with the regulations.

(5) If a complaint relates to one of the following matters, the complainant may apply to the Board in accordance with the regulations for a review of the decision made by the society upon completion of the complaint review procedure:

1. A matter described in subsection 120 (4).

120 (4) The following matters may be reviewed by the Board under this section:

4. Allegations that the society has failed to comply with subsection 15 (2).

5. Allegations that the society has failed to provide the complainant with reasons for a decision that affects the complainant’s interests.

15(2) Service providers shall ensure that children and young persons and their parents have an opportunity to be heard and represented when decisions affecting their interests are made and to be heard when they have concerns about the services they are receiving.

8The Act does not mandate or permit the CFSRB to make determinations as to the clinical wisdom or validity of decisions made by the Respondent and for which the Respondent is giving reasons under s. 120(4)5.

background

Investigation of abuse report

9On September 26, 2018, the Respondent received a report from the teacher of the Applicant’s four-year-old son (“Z) regarding a statement that Z allegedly made the preceding day. The Respondent’s notes detailing this report are as follows:

a. Yesterday they were outside playing and walking through the park back to the kindergarten pen. Child said to caller: my dad and I are making bombs in my basement. Caller asked him what they put in them. Child replied: Gasoline, other stuff too….I don’t know all the other stuff you put in. Caller asked him why they make bombs. He said: because there are bad guys out there. Caller asked him how he knows that and he said: b/c my mommy tells, my mommy tells me the stories.

b. They then arrived back to the school and they carried on with the day. Caller did review this with the principal. The principal asked caller to phone CAS. The principal just called police now and they are waiting for a return phone call from the community police officer.

c. Mom is pregnant and due any day.

d. Caller has met mom but not dad. Mom presents as “lovely”. She is soft-spoken and very friendly. She presents as very kind. No other concerns have been noted.

e. Z is very chatty and quite precocious. He talks a lot to caller and the ECE and presents as very imaginative. He wears a Superman or Batman cape daily.

f. The vice principal is Erin Keen. She is currently on the phone with the police right now.

g. Child is not present today – the reason is illness/injury.

10The Respondent assessed the report as “2.2.B. (Harm by Omission, Neglect of Child’s Basic Needs, Moderately Severe)”. It was determined that a worker would attend at the home within 12 hours and that the attendance would be coordinated by police.

11At about 3:00 p.m. on the day the report was received, in the company of three police officers, AB attended at the Applicant’s home, where the Applicant resided with his wife and Z. The Applicant initially declined to allow AB and the police officers into his home until they told him what they wished to speak to him about. One of the police officers finally told the Applicant that Z had allegedly made a statement at school on the prior day that Z and the Applicant made bombs in the basement of their home. A fourth officer arrived and asked AB if she had concerns about a child in the home. When she said that she did, the officer entered the Applicant’s home without consent and told AB to enter the home and interview the child. She did so.

12At one point, prior to entering the house, the Applicant said he wanted to record the interaction and began to reach for his phone but was told not to do so by the police as they said he might be reaching for a detonation device.

13The Applicant is a lawyer and his wife is employed in a professional capacity.

14AB interviewed Z in a room adjoining the entranceway of the home. Immediately after she left the Applicant’s home, AB made her notes about the dialogue between herself and Z. While the Applicant’s recollection of the interview does not precisely accord with AB’s recollection, the Applicant made no notes and he did not generally dispute that AB’s notes captured the essence of what transpired during her interview of Z. Her notes provide as follows:

a. Who is bobba - daddy

b. What do you and bobba do for fun - play jurassic park

c. Do you know what the word safe means - no

d. If I told you to run across the street when a car is driving, is this safe or not safe - not safe – I told him this was correct

e. Do you feel safe at home - yes

f. Were you at school yesterday - yes

g. Were you at school today - no. me and mommy took a chuti today.

h. What is a chuti? - it is something in another language

i. Do you remember talking to your teacher yesterday - yes

j. About what - I forget

k. Do you remember telling your teacher you and daddy make bombs in the basement - yes

l. Do you and daddy make bombs in the basement - yes and bobba makes them with me

m. Why do you and daddy make bombs in the basement - to fight the bad guys

n. Are they real bombs or pretend bombs - real bombs

o. What else do you and daddy do in the basement - fix stuff, broken nails, put wood together, drill holes

p. Who are the bad guys - they are real life bad guys

q. Who told you this - mommy told me there are bad guys in real life

r. How do you and bobba make the bombs - take screws, throw the bomb at 7, throw it at the bad guys and it explodes

s. Are there bombs in the basement right now? - no we didn’t make them yet

t. When was the last time you made bombs with bobba - never made them yet

u. What stuff is in the basement to make the bombs - bobba has a really sharp saw

v. Are you scared of anyone or anything? - no

w. Are you going to make bombs or is it just pretend? - we are going to make bombs

x. Who is? me and bobba to be like a real super hero [sic]

15The Applicant said that AB appeared to be flustered and nervous, which AB denied. However, given the way AB’s position that she had to find out quickly whether there were bombs in the basement and how this impacted the questions she asked Z, it appears likely that she did display some nervousness.

16AB told the police that Z had verified that he and his father made or would be making bombs in the basement, that the basement would have to be searched and that she could not leave until the basement was inspected.

17The police and the Applicant proceeded down to the basement. The police found no evidence of bomb making or materials for bombs. They found only “very clean” construction site which posed no hazards to the child.

18While the Applicant and the police were in the basement, AB spoke with the Applicant’s wife, who denied that there had been any bomb making in the basement. She told AB that Z has a “wild imagination”, that he is obsessed with superhero books, that there are always “good guys” and “bad guys” in these books, and that some of the books featured bomb making. The Applicant’s wife showed AB a couple of books to confirm this and told AB that it was from these books that Z got ideas about bomb-making.

19When the Applicant came up from the basement, he declined to be interviewed. AB told the Applicant and his wife about the next steps and told them that she was deeming the situation to be safe.

20On November 14, 2018, the Society worker sent a letter to the Applicant and his wife confirming that their file would be closed.

Ministry Standards regarding Interviews

21The Applicant placed into evidence an excerpt from the Ministry of Child and Youth Services’ Ontario Protection Standards (2016) (“the Standards”). The introduction to the Standards includes the following statement:

The standards are the mandatory framework within which child protection services are to be delivered. They clarify expectations regarding the minimum level of performance for child protection workers, supervisors and CASs, and create a norm that reflects a desired level of achievement.

22Standard #2 regarding Planning and Conducting a Child Protection investigation includes the following statements:

As part of the investigative plan a decision is made regarding which investigative approach is appropriate:

• the “traditional” approach is chosen for cases where a criminal assault is alleged against a child and/or for extremely severe cases; or

• the “customized” and more collaborative approach is chosen for lower severity cases.

Both investigative approaches utilize a family-centred, strengths-based orientation and require that: ….

• Forensic interviewing techniques are used in interviews when discussion the alleged child protection concerns (condition or incident).

23The Practice Notes for Standard 2 provide that;

Forensic interviewing techniques are used whenever discussing child protection concerns with the interviewee. These techniques are designed to elicit a valid, unbiased and complete statement in relation to allegation or sources of abuse or neglect. Children are to be interviewed in a developmentally sensitive manner taking into account their developmental level with respect to memory and language.

Forensic interviews:

• assume skeptical neutrality on the part of the interviewer,

• use techniques that are grounded in research;

• are child centred;

• take into consideration that possibility of interviewer influence; and

• are focused on the collection of data that requires minimal interpretation and hypothesis testing;

Additional training resources with respect to forensic interviewing are available through the OACAS. (Also see References section (Poole and Lamb, 1998).

24Attached to the Application was an except from the text, Investigative Interviews of Children by Poole and Lamb (“Poole and Lamb”), which is cited in the Standards as a “Reference”. The Applicant pointed to portions of the excerpt that dealt with asking open-ended questions versus specific questions, and the difference between them. Poole and Lamb define open ended question as requiring a multiple word response (e.g. Tell me about that?) while specific questions are defined as those asking about a specific detail and often can be answered with a single word (e.g. What colour is the sky?)

25The Applicant also pointed to a citation from the text that explains that the interviewer should avoid leading or suggestive questions, such as “how long have you been considering divorce?” The authors explain that this is due to the probability for adult authority figures to influence the behaviour of children during adult-style conversations, especially pre-school age toddlers who readily accept ideas from any authority figure and cannot distinguish reality from imagination. The text strongly advises against the use of questions that elicit one-word answers.

Respondent’s evidence on the appropriateness of the interview questions

26JR explained that there are two approaches in carrying out an investigation: the traditional approach and a customized approach. Traditional approaches are “by the book” investigations in which a very forensic approach is taken and usually involve allegations of abuse by caregivers. AB gave as examples where the traditional approach is used as including sexual or physical abuse.

27JR said that a customized approach is less forensic. In this approach, the child protection worker is given some latitude do things out of the traditional order to take a more individualized approach to a family, to gauge how things are going and adjust accordingly. AB said that the customized approach is used in less severe cases.

28When directed to the Ministry standards and the definition of “open ended questions” from Poole and Lamb, AB said that she did not agree with that definition and that open-ended questions were not limited to this definition. She said that she was trained in questions.

29With respect to her interview of Z, AB’s evidence was that she began with introductory questions and then open-ended questions pertaining to the allegation. She said that because she was in a situation where she needed to make a determination quickly about whether there was any truth to the statements Z made to his teacher, she moved quickly to a direct question when Z said he forgot what he talked to his teacher about. She maintained that it was appropriate to do so in the circumstances.

30AB agreed that she could have asked more open-ended questions to ascertain the information she sought from Z but said that this would have taken much longer. She specifically denied that the questions, “Do you remember telling your teacher that you and Daddy make bombs in the basement?” and “Do you and Daddy make bombs in the basement?” were closed or leading questions. She said that asking, “You told your teacher this didn’t you?” would be leading, but that is not what she asked. She said that while the questions she asked invited yes or no answers, they did not suggest which answer Z should give.

31JR testified that, based on her review of the interview, AB followed the forensic approach initially, asking open ended questions relevant to the allegation. After Z said he forgot what he talked to his teacher about the day before, AB shifted into more narrow and direct questions to lead Z to the issue. JR said that this was reasonable in circumstances as there was a concern about a possible bomb in the basement and AB needed to immediately determine whether there was any truth to the statement Z made to his teacher.

32JR explained that since the report had been made by the teacher pursuant to her duty to report under the Act, the Respondent assumed that Z made these comments to the teacher; however, no assumptions were made about the truth of the comments. JR said that the direct questions asked by AB were closed in that they invited one-word answers, but that the questions were not pointing Z to the answer. Rather, AB was setting up an ability for Z to share what he said to the teacher.

33In its written argument, in reciting AB’s evidence, the Respondent included the following statement about the questions asked by AB: “As such, she had to move quickly to a leading question once Z said he forgot what he talked to his teacher about, and that it was appropriate to do so in the circumstances.”[Emphasis added.] I have understood the use of the work “leading” in this statement not to mean that the Respondent is agreeing that AB asked questions leading to specific answers, but rather that AB asked a question that was guiding Z to the issue. This understanding is consistent with the evidence given by AB and JR.

34The Standards indicate that a child’s age and level of development must be taken into account in determining the questions to be asked. Both JR and AB said that the questions asked of Z were appropriate given his age and level of development.

35JR was asked, in cross examination, what the basis was for her decision that the interview was appropriate. She explained that the flow of the conversation led to the confirmation of the information received from the teacher that Z made a statement about bombs being made in the basement and then to the ultimate conclusion, after further investigation, that while Z made this statement to his teacher, it was not true.

ICRP

36On May 13, 2019, the Applicant sent a formal complaint to the Respondent’s Internal Complaints Review Panel. An ICRP meeting was scheduled for July 24, 2019.

37The Applicant’s written complaint set out the nature of the Applicant’s concerns with the investigation and the questions asked of his son in a comprehensive manner. Included were references to the Standards and the Poole and Lamb excerpt.

38The Respondent provided a copy of the complaint to AB who prepared a six-page response that specifically addressed the points raised by the applicant.

39JR testified that the panel both the Applicant’s complaint and AB’s response prior to the meeting. Further, they received a file overview from the Supervisor.

40The meeting lasted for approximately one hour and twenty minutes. Both parties agreed that the Applicant did most of the talking during the meeting. By the conclusion of the meeting, the panel agreed that the Applicant’s file would be reviewed. JR testified that she undertook to review the file and report back to the panel.

41Following her review of the investigation file, the Applicant’s written complaint and attachments, AB’s response and her own notes taken during the ICRP meeting, JR reported back to the rest of the ICRP panel. Her conclusions were that the Society’s investigation was conducted properly and that AB’s questions in her interview of Z followed the standard of investigative practice that allows for both a traditional and customized approach. The ICRP adopted these conclusions.

42By letter dated August 7, 2019, the ICRP advised the Applicant of its conclusions. The letter sets out succinctly and correctly the gist of the Applicant’s complaint, outlined the steps taken on behalf of the ICRP following the meeting to deal with his complaint and then sets out its conclusions. The letter includes reasons for the conclusion reached by the ICRP.

ANALYSIS

43The CFSRB set out the considerations to be had in hearing an application under ss. 120(4)4 and 120(4)5 in JB v Children's Aid Society of Toronto (s.120 CYFSA), 2018 CFSRB 46, starting at paragraph 13:

The Society’s obligations are set out in P.O. v. Family and Child’s Services Niagara, 2012 CFSRB 38, at paras.13-14, as follows:

The obligations under s. 68.1(4)4 and 5 reflect the importance of active participation for parents, providing them with the opportunity to have some degree of influence in the process. This is facilitated through genuine communication, giving Applicants the opportunity to have input into decision making and to have enough information to make informed responses to, or accept decisions.

To be heard involves active listening, discussions, the Society’s taking steps to address the Applicant’s concerns and communicating this to her so that she feels that her concerns are taken seriously and dealt with thoroughly.

The “right to reasons” under the Act, means a right to a meaningful explanation about decisions that affect the Applicant’s interests. In J.G. v. Windsor- Essex Child’s Aid Society, 2013 CFSRB 8, at para. 8, the CFSRB held that:

With respect to s. 68.1(4)5, what constitutes sufficient reasons is a matter to be examined in each case in the context of that particular situation. This may include an examination of the timeliness and the level of detail provided. A parent must be given sufficient information regarding the factors that were taken into account in making the decision to allow him or her to understand why and how the decision was made.

The obligation to hear an applicant requires the Society to do more than accept information or documentation provided by the applicant. There must be meaningful engagement, in contrast to going through the motions, and must provide explanations that are sufficiently detailed that the Applicant can understand the reasons for the decisions that have been made. [Emphasis added.]

Was Z provided with an opportunity to be heard?

44The Applicant argues that in order to comply with its obligation to provide children with an opportunity to be heard, a children’s aid society (“CAS”) must, when interviewing children, follow “two primary rules” which he says are set by the mandatory Standards that “bind” the Respondent. He says that these two rules are:

1. focus completely on open-ended questions initially to ensure the witness exhausts their memory on the topic of the allegation,

2. do not lead a vulnerable witness by having the interviewer introduce facts first

45The Applicant argues that the Standards underpin the right of children to be heard and represented, as required by s.15(2). He states that the “right to be heard and represented is a substantive, protective right satisfied only through robust age-appropriate engagement with a child.” He asserts that, “the critical right to procedural fairness is the foundational protection for children and families seeking to avoid the arbitrary power of government agents entering into their private lives.”

46In addition to his argument that AB’s failure to put questions to Z that complied with the Standards resulted in Z being denied an adequate opportunity to be heard, the Applicant also argues that AB failed to comply with the Standards in respect of her case notes. However, this is a clinical issue which does not have a sufficient nexus to the requirements of s.15(2). The CFSRB’s mandate does not extend to considering this issue.

47The Respondent submits that the CFSRB does not have jurisdiction to consider the manner in which an investigation is carried out. The Respondent says that the CFSRB is neither required or permitted to make determinations as to the quality of a CAS’s investigation or its clinical decisions regarding process – i.e. traditional versus customized approach. The Respondent submits that the CFSRB’s functions under ss. 120(4)4 and 120(4)5 are limited to determining whether children, young persons and/or their parents have had an opportunity to be heard and represented when decisions affecting their interests are made, and to be heard when they have concerns about the services they are receiving.

48In the alternative, the Respondent says that Z was given an opportunity to be heard.

49The requirement in s. 15(2) that a child have an opportunity to be heard means that children must be given a fair opportunity to express themselves in their own words rather than providing answers they have been directed or unduly influenced to give through leading or suggestive questions. This includes in interviews conducted in the course of investigations that can result in decisions that affect their interests.

50I agree with the applicant that a central requirement in providing a child with an opportunity to be heard is that the child must be allowed to speak without words being put into the child’s mouth. If a question put to a child directs the child to a particular answer, that answer may not accurately reflect what the child might otherwise say or think, especially if the child is at an earlier stage of cognitive development. Moreover, the requirement in s.15(2) cannot be met if a child is asked a question that is overly complex or is so compound in nature that the child is unable to comprehend exactly what is being asked or is unable to distinguish between different issues raised in the question. This is particularly important for children who are at a stage of development where there is a risk that they many not fully understand what they are being asked or may be unduly influenced by the questioner.

51I do not, however, accept the Applicant’s arguments regarding Ministry Standards. First, the “two primary rules” cited by the Applicant are not contained in the Standards. It appears that the Applicant may have attempted to distill these “rules” from Poole and Lamb, which is cited only as a “Reference” in the Standards and is not elevated to the level of setting mandatory principles that CASs must follow in every situation. Second, and in any event, the question which I must answer is whether the Respondent provided an opportunity for Z to be heard, not whether the Respondent met the Standards. An assessment of whether or not the Respondent has met the Standards is neither determinative of the question I must answer nor within my jurisdiction to make.

52Further, I do not agree with the Applicant’s assertion that the Respondent “utilized a manipulative, controlling and interrogational approach” in questioning his son. While concerns do arise regarding certain of the questions asked by AB, none of the questions – either individually or together – can be described as manipulative, controlling or interrogational.

53The concern that I have with AB’s questions, arises with respect to the two questions she asked when she abruptly segued from open to more direct/specific questions: “Do you remember telling your teacher you and daddy make bombs in the basement?” and “Do you and daddy make bombs in the basement?” The first of these two sentences had a high degree of complexity because it required a yes or no answer in respect of 3 distinct pieces of information: i) did Z remember telling his teacher; 2) that he and his father made bombs; and 3) in the basement. Moreover, the concept of “bombs” in the context of the first of these two questions was introduced out of the blue without any preliminary open questions to ensure that Z was familiar with the term. This complexity raised the risk that Z’s one-word answer of “yes” might have been to any part of the question that he understood rather than to the whole question.

54AB said that she needed to be direct and to do so quickly because Z could not remember what he said to his teacher the day before. However, when the teacher’s report was received that morning, the coding given to the case was moderately severe and a 12-hour window was given for the worker to visit the Applicant’s home. AB would have been well within that time frame when she arrived at the Applicant’s home at 3 p.m., even with the 15 to 20-minute delay at the front door when the Applicant refused to allow her inside. It would not have taken AB much longer to ask Z some additional lead up questions of less complexity. For example, AB could have asked “What is a bomb?” or “Can you tell me what a bomb is?” Then, AB could have asked more directly, “Did you say anything to your teacher about bombs yesterday?

55Further, both questions put to Z about making bombs in the basement were very closed in that they invited only a yes or no answer – and the first, as noted above, was complex. In addition, there was a risk that because these questions were coming from an adult who was unknown to this four-year-old child and who had just walked into his home with police officers, that he might just simply agree whether or not “yes” was the true answer.

56However, in assessing whether Z had an opportunity to be heard – whether there was “meaningful engagement” in which he could provide answers and information that reflected what he really believed or knew -- it is necessary to review the entire interview. I am satisfied that, overall, the interview between AB and Z reached the minimal level of what could be considered to be “meaningful engagement”. It is clear in reviewing AB’s notes of the interview that Z is a little boy with a “wild imagination” who loves superheroes, that he has heard about “good guys and bad guys” and using bombs to fight the bad guys. His answers to AB’s questions reflect this – as does the fact that no bombs actually had been made in the basement, which he told AB. As such, I conclude that there was sufficient meaningful engagement that gave Z an opportunity to communicate what he believed – based though it was on his vivid imagination – and what he knew, that no bombs had been made.

57Accordingly, I find that the Respondent met its obligation to provide Z with an opportunity to be heard.

Was the Applicant provided with an opportunity to be heard by the ICRP?

58The Applicant provided no argument on this issue.

59Both the Applicant and JR said that for most of the ICRP meeting, the Applicant did the talking. JR testified that all three members of the ICRP read the Applicant’s detailed complaint. JR also testified that the ICRP agreed at the meeting to review the Applicant’s file and that she did so and reported her findings back to the ICRP.

60While the Applicant said in his opening statement that he felt he had not had an opportunity to be heard by the ICRP because they had not read his file in advance of the meeting, I do not agree. That the ICRP undertook at the meeting to conduct a review of the file and that this was done confirms that they did hear him.

61I am satisfied that the Applicant had an opportunity to be heard by the ICRP.

Was the Applicant provided with reasons by the ICRP for its decision?

62The letter sent to the Applicant setting out the ICRP’s decision contains reasons for that decision.

63In his cross examination of JR, it became apparent that the Applicant’s objection was not that there were not reasons set out, but that he disagreed with those reasons. This was also apparent in his opening statement in which he called the reasons “laughable.” However, the CFSRB does not have any jurisdiction to rule on the correctness of reasons.

64I am satisfied that the reasons provided contained sufficient information to permit the Applicant to understand why his complaint was rejected by the ICRP.

CONCLUSION

65It is understandable that the Applicant was upset by the arrival of a child protection worker (“CPW”) in the company of four police officers at his home. This upset was exacerbated by the manner in which Z was questioned by the CPW when she deviated abruptly from using a forensic approach based on her expressed belief that there was an immediate need to know if there were bombs in the basement. However, while questions may arise about what factors prompted this response to the report, such questions are beyond the jurisdiction of this Board.

66For the reasons set out above, this Application is dismissed.

order

67The Application is dismissed.

confidentiality order

68Pursuant to Rules 9.3 and 9.4 of the CFSRB’s Rules of Procedure, parties and their representatives must not use, share, discuss or disclose any CFSRB documents or decisions or any other documents or information provided or used in this Application with anyone, including through the media or online. The CFSRB prohibits the use of any of this information for any purpose outside of the CFSRB’s proceedings, except with an order of the Court or the CFSRB, as appropriate.