When PIPEDA was a bill in 1999-2000, that sort of moment, it didn't really apply to health or where you're coming from. But then in the fall of 2003, when, after that delay period, it was going to apply, the health care providers said to Health Canada and Industry Canada, “We're hearing all kinds of different stories about how it's going to apply as express consent and we need to bring together some guidelines for clearance.”
There was something like a four-year gap between those communications. That's my understanding.