In Bertucci v. Royal Bank of Canada​, the Federal Court allowed two applications for disclosure of personal information brought by customers whose accounts were closed without written explanation. The applicants wanted access to their personal information in order to be able to correct inaccuracies that might affect them negatively in the future. In declining to provide the information, the bank relied upon section 9(3)(b) of the Personal Information Protection and Electronic Documents Act, which provides that an organization is not required to give access to personal information if to do so would reveal confidential commercial information. The Court found the Act to be quasi-constitutional in nature and agreed with the applicants that according to the Act, exceptions to the access requirement should be limited and specific. The Court ordered the respondent to provide personal information to the applicants, with the exception of a due diligence report and internal email. The Court also awarded costs to the applicants. It is worth noting that the bank argued that the requests for information constituted an attempt to circumvent the legal rule that banks are not required to provide specific reasons for terminating a customer's account, only to provide reasonable notice. Importantly, the case does not hold that the bank was required to give reasons for terminating the accounts. However, the decision appears to conclude that the general legal rule that reasons are not required does not override a bank's obligations to disclose personal information under PIPEDA.

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