CHILD AND FAMILY SERVICES REVIEW BOARD
BETWEEN:
PT
Applicant
-and-
The Children’s Aid Society of London and Middlesex
Respondent
DECISION
Adjudicator: Henry Pateman
Date: April 16, 2026
Citation: 2026 CFSRB 57
Indexed as: PT v The Children’s Aid Society of London and Middlesex
(CYFSA s.120)
WRITTEN SUBMISSIONS
PT, Applicant
Self-Represented
The Children's Aid Society of London and Middlesex, Respondent
CD, Counsel
OVERVIEW
1This is an Application filed with the Child and Family Services Review Board (“CFSRB”) under section 120 of the Child, Youth and Family Services Act, 2017, S.O. 2017, c.14, Sched.1 (the “Act”).
2At the February 11, 2026, pre-hearing, the parties agreed to mediation and resolved the matter under dispute. The Settlement Agreement (“the Agreement”) was comprised of three Terms, with Term 1 consisting of nine parts (i.e., Terms 1(a)). The Agreement included an implementation date of March 16, 2026, and a non-compliance date of March 23, 2026.
3After the Agreement was executed, both parties alleged non-compliance by the other party.
4On February 12, 2026, the Applicant emailed the CFSRB upon receipt of the Settlement Agreement to advise that he had not consented to the exclusionary dates listed (post-June 24, 2025) and further that the Agreement did not accurately reflect his consent.
5On February 17, 2026, the CFSRB responded to the Applicant's concerns, copying the Respondent, stating:
‘Thank you for your email dated February 12, 2026, outlining your concerns related to the Settlement Agreement.
The terms of the Settlement Agreement, including the time frame, scope, and issues to be addressed within the ICRP process, were discussed at length and agreed upon by all parties involved in the mediation on February 11, 2026. This framework is also reflective of the concerns you raised in your initial application form, as well as during our discussion as part of the mediation process.
As such, the terms of the Settlement Agreement agreed to on February 11, 2026, will remain in effect.’
6On March 17, 2026, the Applicant emailed the CFSRB, copying the Respondent. In the email, the Respondent alleged procedural non-compliance with the Agreement, namely:
a. Section 1(c) – was in direct contradiction to Term 2
b. Term 1 – scope limitation eliminated contextual information
c. Term 2 – the disclosure process in Term 2 was ongoing and, as such, limited the effectiveness of the ICRP process.
7On March 24, 2026, the CFSRB emailed both parties confirming the Applicant’s allegation of non-compliance and provided the Respondent until March 31, 2026, to respond in writing.
8On March 31, 2026, the Respondent emailed the CFSRB, copying the Applicant, in response to the non-compliance allegation.
9Also contained within the Respondent's March 31, 2026, letter, the Respondent alleged the Applicant’s non-compliance with Term 1(a) of the Agreement, namely: that the Applicant failed to submit an ICRP complaint form before the required deadline.
10On March 31, 2026, the CFSRB notified both parties, in writing via email, acknowledging receipt of the allegations of non-compliance. The CFSRB also determined sufficient information existed to address the allegations in a written decision, and no further submissions would be required.
ISSUES
11The issues are two-fold:
Did the Respondent comply with Term 1 and/or Term 2 of the Agreement?
Did the Applicant comply with Term 1(a) of the Agreement?
RESULT
12I find the Respondent has complied with Term 1 and/or Term 2 of the Agreement.
13I find the Applicant has not complied with Term 1(a) of the Agreement.
HEARING FORMAT
14Rule 8.1 in the CFSRB Rules of Procedure outlines that the CFSRB may conduct hearings orally, in writing, or electronically by teleconference or videoconference.
15Based on the submissions of the Respondent and the Applicant, I find that there is sufficient evidence before me to decide the issue of non-compliance in writing, without a further videoconference.
ANALYSIS
Applicant’s allegation of non-compliance
16In reviewing the Applicant’s non-compliance submissions, several issues were raised. These issues were as follows:
a. That the required submission of an ICRP review form by the Applicant on or before February 18, 2026, was procedurally unfair. He referenced Term 2 of the Agreement, which dealt with disclosure from the Respondent that the Applicant found necessary to complete the ICRP review form. Having received disclosure after the submission of the ICRP Review form was procedurally unfair and placed him at a disadvantage.
b. The scope of the ICRP process, as identified in the Agreement, limited the Applicant because any decisions made after June 24, 2025, could not be meaningfully reviewed without reference to the full file (i.e. decisions made before June 24, 2025) to provide context.
c. That the disclosure process remained ongoing and that any part of the Settlement Agreement could not be implemented in a procedurally fair and meaningful manner.
17Term 1 (“the Term”) of the Agreement sets out that the Respondent will establish an Internal Complaints Review Panel (ICRP) to review the Applicant’s concerns with respect to his involvement with the Respondent commencing June 24, 2025. No facts or issues predating June 24, 2025, will be reviewed.
18In his email dated February 12, 2026, the Applicant advised the CFSRB, via email, upon receipt of the Agreement, that he had not consented to the time frame outlined within the Agreement. In his later submission dated March 17, 2026, the Applicant's concerns were related to the perceived procedural unfairness, as the disclosure elements listed in Term 2 of the Agreement constituted required information for completing the ICRP complaint process, and the identified timeframe for that disclosure was after the deadline for the ICRP complaint form.
19Within their submissions, the Respondent addressed these issues, stating,
‘The Settlement Agreement did not contemplate the provision of disclosure by the Respondent Society to the Applicant either prior to the Applicant’s filing a complaint for the ICRP or at any other time.
With respect to records, the Respondent Society was only required to provide a letter explaining redactions of the records previously provided by March 3, 2026, which it did.
It is further noted that the CFSRB has no jurisdiction over complaints regarding access to records under Part X of the CYFSA, as such complaints are under the jurisdiction of the Information and Privacy Commissioner.
The Applicant’s allegation appears to be that the Settlement Agreement itself was unfair, rather than that the Respondent Society failed to comply with that Agreement. The Settlement was consented to by all parties following a lengthy mediation.’
Terms 1 and 2 of the Agreement were met.
20Having considered the evidence and submissions of the parties, I find that the Respondent complied with Terms 1 and 2. Term 1 was predicated on the submission of an ICRP complaint form by the Applicant before February 18, 2026. The Respondent, by agreeing to the Agreement on February 11, 2026, intended to establish an ICRP review process once it received the ICRP complaint form from the Applicant. Since no ICRP Complaint form was provided by February 18, 2026, the Respondent had no further obligations to that process. Accordingly, there was no incident of non-compliance.
21Term 2 of the Agreement did not involve further disclosure of information; rather, it involved the Respondent providing to the Applicant an explanation of the redactions made to a previously provided Individual Request for Access to Records provided to the Applicant made on August 26, 2025. The settlement did not identify an obligation of further disclosure, only an explanation by the Respondent to the Applicant of why the redactions took place and the statutory basis of those redactions. Beyond an explanation of the redactions, full disclosure had already been provided to the Applicant. Accordingly, there was no issue of non-compliance.
Respondent’s allegation of non-compliance.
22The Respondent’s allegations of the Applicant’s non-compliance focused on Term 1(a), which set out the requirement for the Applicant to submit an ICRP form before 4:00 pm on February 18, 2026.
23In their submissions dated March 31, 2026, the Respondent noted that the Applicant did not file an ICRP form by the agreed-upon deadline of February 18, 2026, or any time thereafter. The Society, as a result, could take no further steps towards convening the ICRP.
24The Applicant, in his initial submissions, noted that submission of the ICRP form before having full disclosure was procedurally unfair and put him at a disadvantage in attempting to fulfil the ICRP form and process. As explained above in paragraph 21, beyond an explanation for redaction, full disclosure had already been provided to the Applicant at the time the settlement was entered.
Term 1(a) of the Agreement was not met.
25I find that the Applicant has not complied with Term 1(a). The Applicant did not submit an ICRP form by the February 18, 2026, deadline. The applicant’s reasoning for failing to meet the deadline, that the absence of further disclosure from the Respondent made the process unfair, is not borne out by either the evidence or the settlement agreement. The Applicant had, by the date of settlement, received full disclosure. Accordingly, the process to submit the ICRP form by February 18, 2026, was fair.
Remedies
26Under section 120(7) of the Act, the CFRSB has limited jurisdiction. The CFSRB may order a society to provide written reasons for a decision or dismiss the complaint. The CFSRB does not have jurisdiction to determine the validity of the Respondent’s decisions or substantive actions it may have taken, but rather focuses on the quality of communication between the Respondent and the Applicant. There is no remedy available to the Respondent for the Applicant’s non-compliance.
ORDER
27As the remedies available for complaints filed under section 120 of the Act are limited to providing reasons, there is no further action to be taken.
28The CFSRB’s file is now closed.
CONFIDENTIALITY ORDER
29Pursuant 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.
Henry Pateman
Henry Pateman
Member