ARTICLE · 30 APRIL 2025

Ransomware Encryption Of Personal Information Can Be A Privacy Breach

Rosen Sunshine LLP

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A recent Privacy Complaint (MR21-00090) before the Information and Privacy Commissioner of Ontario (IPC) expanded the scope of what will be considered a privacy breach for Ontario public sector bodies.

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Introduction

A recent Privacy Complaint (MR21-00090) before the Information and Privacy Commissioner of Ontario (IPC) expanded the scope of what will be considered a privacy breach for Ontario public sector bodies. Privacy breaches are generally categorized as unauthorized collection, disclosure or use of personal information or personal health information ("PI" or "PHI"). In the context of privacy law, "use" generally means "viewing", "accessing" "handling", or "dealing with" PI or PHI. This recent IPC case, which involved a ransomware attack, expanded the scope of privacy breaches for public sector bodies by applying an expansive interpretation to "unauthorized use."

Ransomware Attack at Sault Ste Marie Police

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