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John Doe v Ontario (Information and Privacy Commissioner)

John Doe v Ontario (Information and Privacy Commissioner) is a notable Canadian legal case concerning the balance between privacy rights and the public interest. The case involved an application to the Information and Privacy Commissioner of Ontario (IPC) for access to information held by the Ministry of Health and Long-Term Care. The information requested related to a doctor, pseudonymously referred to as "John Doe," who had been disciplined by the College of Physicians and Surgeons of Ontario (CPSO) for professional misconduct.

The central issue in the case was whether the public's right to know about the disciplinary actions taken against a doctor outweighed the doctor's privacy interests, particularly given the sensitivity of the information and the potential for harm to his reputation.

The IPC initially ordered the Ministry of Health and Long-Term Care to disclose certain information, reasoning that the public interest in transparency and accountability of medical professionals outweighed John Doe's privacy concerns. John Doe appealed this decision.

The case ultimately reached the courts, which considered the relevant factors under the Freedom of Information and Protection of Privacy Act (FIPPA). The courts assessed whether the disclosure was necessary to protect the public health and safety, and whether the information was already available through other sources, such as the CPSO's public register. The courts also considered the potential impact of disclosure on John Doe's privacy and professional reputation.

The outcome of the case generally affirmed the IPC's authority to balance privacy rights and the public interest. However, the specific details that were ultimately disclosed, and the extent to which John Doe's identity was protected, depended on the application of the principles of necessity and proportionality under FIPPA to the particular facts of the case. The case is important for its contribution to the legal framework governing access to information and privacy in Ontario, and for its guidance on how to weigh competing interests in similar situations.