Canada: Privacy Commissioner found Google non-compliant with the Personal Information Protection and Electronic Documents Act (PIPEDA) following decision not to follow recommendation to de-list articles

On 27 August 2025, the Office of the Privacy Commissioner (OPC) found that Google violated the Personal Information Protection and Electronic Documents Act (PIPEDA). The OPC concluded that Google should de-list certain media articles from its search results because the harm caused to the complainant’s safety and dignity outweighed the public interest in access. Google did not agree to remove the articles and argued that further direction from the courts is required before it would be appropriate for news articles to be de-listed. The OPC, therefore, considered this part of the complaint to be well-founded and unresolved. The finding followed an examination of whether Google had met the accuracy requirements under PIPEDA and whether it collected, used or disclosed personal information only for a reasonable purpose by continuing to display the search results. The OPC determined that Google’s accuracy obligations under PIPEDA do not extend to the content of the articles themselves. It also found that there are limited situations in which it would be inappropriate for a search engine to return results containing personal information about an individual. The case began in June 2017 when an anonymous individual filed a complaint alleging that Google had contravened PIPEDA by including certain media articles in the list of results displayed when their name was searched. Google challenged the OPC’s jurisdiction to investigate. In July 2021, the Federal Court confirmed that the OPC had jurisdiction, and in September 2023, the Federal Court of Appeal upheld that decision.