L'Écuyer v. Aéroports de Montréal

L'Écuyer v. Aéroports de Montréal

The appeal is dismissed because the trial judge's findings that the appellant had at least implicitly consented to the disclosure and that the employer had a duty to disclose to the union were not shown to be palpably or overridingly erroneous; therefore the merits dispose of the case without resolving the...

Source-derived case information.

Citation
2004 FCA 237
Parties
Appellant: Diane L'Écuyer; Respondent: Aéroports de Montréal; Intervener: Privacy Commissioner of Canada
Court
Federal Court of Appeal
Jurisdiction
Canada
Judgment Date
17 June 2004
Procedural Posture
Appeal / Decision (judgment)
Outcome
Appeal dismissed
Legal Topics
PIPEDA Section 14, Jurisdictional Allocation Between Privacy Commissioner and Grievance Adjudicator, Consent to Disclosure (implicit Consent), Employer Duty to Disclose to Union
Source Language
en
Privacy Administrative Law Labour/employment Law Access to Information PIPEDA Section 14 Jurisdictional Allocation Between Privacy Commissioner and Grievance Adjudicator Consent to Disclosure (implicit Consent) Employer Duty to Disclose to Union

Source-derived case record

Summary, issues, holding and outcome

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Parties

Diane L'Écuyer

Appellant

Aéroports de Montréal

Respondent

Privacy Commissioner of Canada

Intervener

Procedural Posture

Appeal / Decision (judgment)

  1. 1 Whether the Privacy Commissioner and Federal Court had jurisdiction under s.14 of PIPEDA or whether the grievance adjudicator had exclusive jurisdiction
  2. 2 Whether the appellant implicitly consented to the disclosure of the February 8, 2001 letter to union representatives
  3. 3 Whether the employer had a duty to disclose its reply to the access to information request to the union

Ratio Decidendi

The appeal is dismissed because the trial judge's findings that the appellant had at least implicitly consented to the disclosure and that the employer had a duty to disclose to the union were not shown to be palpably or overridingly erroneous; therefore the merits dispose of the case without resolving the jurisdictional question.

Court Disposition

Appeal dismissed

Orders

  • Appeal dismissed
  • Dismissed without costs under the circumstances