To go back, the premise for the legislation is based on the idea that it has to be personal information and it has to be commercial. There are a number of exceptions. Information that's collected for journalistic and artistic purposes, for example, is not captured by the act. It's exempt from the act. There are also a number of exemptions for particular types of research activity, even though scholarly activity is exempt from the act as well, correct?
There's a much broader definition of research for most people. Some research may be commercial. For that purpose, there are certain exceptions in the act for what I'll call commercial research purposes.
To get back to work product, I think you're right, it's a central issue around some questions in the health sector about the extent to which personal information is either protected individual information or work product information. You'll hear from witnesses that some provinces have looked at defining work product in such a way that it takes it out of the domain of personal information.
With respect to PIPEDA, a series of court judgments have defined personal information in such a way that certain types of data—like prescription information, if I'm correct—have been defined as not being personal information. In the federal law, we have not yet defined work product so that this area was exempt from the definition of personal information. Some provinces have. You will hear from some witnesses that there is merit in that approach. Others may have a different view.
So that's one approach. In terms of PIPEDA, essentially we in the health sector, at least, have gotten to a similar position due to court interpretations of the law.
I don't know if any of my colleagues want to elaborate, but that's how I see it working right now.