(c) Coverage provisions should be construed broadly; exclusion
causes should be interpreted narrowly: Monenco, at para. 31.
(d) Courts should avoid interpretations of policies that substantially nullify coverage: Consolidated Bathurst Export Ltd. v.
Mutual Boiler and Machinery Insurance Co.,  1 S.C.R.
888,  S.C.J. No. 133, at para. 27.
A. “Acting under the direction” of the named insured
 Aviva concedes that Ms. Oliveira was a hospital employee
but submits that she was not acting under the direction of the
hospital in respect of the impugned conduct. Aviva’s factum
describes Ms. Oliveira as “lone wolf, deliberately engaging in
activities that are not in any way related to her employment at
the Hospital, and in fact are contrary to her obligations as an
employee of the Hospital . . . ”. Aviva argues that Ms. Oliveira
is alleged to have abused her position at the hospital to access
private information of a person who was never her patient and
therefore acted contrary to the hospital’s practices and procedures. As a result of the foregoing, she could not be acting
under the direction of the hospital and should not be afforded
a duty to defend.
 I do not accept that these submissions relieve Aviva of
a duty to defend.
 The explicit language of the policy is, in fact, contrary to
the position Aviva advocates.
 As already noted, the policy specifically provides coverage
for “invasion or violation of privacy” and for “invasion or violation of the right of privacy”. Legal liability for invasion of privacy
was examined by the Ontario Court of Appeal in Jones v. Tsige
(2012), 108 O.R. (3d) 241,  O.J. No. 148, 2012 ONCA 32. In
doing so, the Court of Appeal quoted from a seminal article of
William Prosser, “Privacy” (1960), 48 Cal. L.R. 383, in which
Professor Prosser noted that the concept of legal liability for
breach of privacy consisted of four separate torts: intrusion upon
seclusion; public disclosure of embarrassing private facts about
the plaintiff; publicity which places the plaintiff in a false light
in the public eye; and appropriation of the plaintiff’s name or
likeness (Jones, at para. 18).
 The most relevant for our purposes is the tort of intrusion
upon seclusion. At para. 70 of Jones, the Court of Appeal adopted
into Ontario law the definition of intrusion upon seclusion from
the restatement (second) of torts (2010) as follows: