If you look at the provisions of the act, it would apply generally to whether the manner of outsourcing worked five years ago or today. As my colleague has pointed out, the law says you are responsible for that personal information. When you outsource or use agents, you have to have them agree to protect it the same way you have to protect it.
I'm not sure it's the delivery method, with the exception of business e-mail addresses, where perhaps e-mail was less trusted five years ago than it is perhaps in the business community today. I'm not sure there are significant changes that aren't captured by the existing wording. If you examine that, you might come to the conclusion that the existing wording does deal with some of these changes and might have been worded generally enough to accommodate future changes in technology or relationships.