My comments would be quite similar, in that as I said, physicians had already been protecting patient privacy as part of their ethical and professional obligations in the day-to-day interaction between physicians and patients. But there was the added impetus with PIPEDA to have written policies and notices to inform patients about their office privacy practices.
This is not a bad thing, but it is done in an already time-pressed environment. But where we found some assistance for this was in the PARTs guidelines for health care providers. These guidelines outlined in greater detail exactly what the obligations of health professionals were under PIPEDA, while also acknowledging the priority assistance and protection offered by the physicians' codes of ethics and regulatory obligations. This is part of our rationale and reasoning for wanting to have the PARTs guidelines also recognized in the legislation, because that eased the burden.