Edmonton, Alberta, Canada—Public Interest Commissioner of Alberta Kevin Brezinski today provided commentary on a June 1, 2026 ruling by the Alberta Court of Appeal, Campbell v Alberta (Public Interest Commissioner), 2026 ABCA 184. The Court of Appeal overturned a lower court ruling about an investigation by the Commissioner, found the investigation was procedurally fair, and restored the Commissioner’s report that identified wrongdoing in a public school district.
“I welcome this week’s significant ruling by the Alberta Court of Appeal. The Court’s decision upholds the spirit of Alberta’s Public Interest Disclosure (Whistleblower Protection) Act and aligns with recommendations we provided to the Legislative Assembly during the Act’s recent review. This decision reinforces the importance of protecting whistleblowers.”
– Kevin Brezinski, Public Interest Commissioner of Alberta
Key findings
- The Commissioner’s original report protected the identities of witnesses and whistleblowers, which the Court found was consistent with the Commissioner’s mandate under the Public Interest Disclosure (Whistleblower Protection) Act (PIDA).
- Further, the Court identified confidentiality as a central feature of PIDA, noting that “To the extent that PIDA sets a baseline or a norm, it is non-identification [of witnesses].”
- The Court’s decision sets an important precedent for offices tasked with administering whistleblower legislation across Canada. It emphasizes the important role confidentiality can play in these investigations, clarifying that if those under investigation know and can meaningfully respond to the allegations against them, witness and whistleblowers can remain anonymous.
Concerns about confidentiality and retaliation are the largest barriers for reporting workplace wrongdoing, according to the Commissioner’s office’s expansive 2024 survey of Alberta’s public sector employees.
The Commissioner’s most recent submission to Alberta’s Standing Committee on Resource Stewardship included specific proposals for legislative mechanisms that would further protect the identities of whistleblowers and witnesses.
Although there remain circumstances where the disclosure of identity may be required, the Commissioner is optimistic this decision will advance whistleblower confidentiality. The Commissioner will continue to recommend legislative amendments that bolster confidentiality.