My understanding of the charter statement that was issued by the Department of Justice is that it set out that programs that are uploaded by an unaffiliated user of social media would not be subject to the act unless prescribed by regulation. In deciding to prescribe such regulation, the statement then goes on to list the number of factors that are set out in Bill C-11.
It would appear that the Department of Justice charter statement did in fact have these provisions within their contemplation when they made the statement that Bill C-11 is charter compliant.