Thank you for the question.
First, the act already partly imposes something on injury tests in the provisions of section 20. It's also taken into account in provincial legislation in Quebec, in the provisions on protecting the interests of third parties.
That said, I'm not sure that it responds to all the concerns that third parties might have when it comes to access to their documents. Protection mechanisms already exist. For example, section 20 covers trade secrets. So, imposing the burden of proving injury on third parties for something that is basically a confidential trade secret, in particular, is perhaps something that goes too far for certain document categories.
In fact, it makes sense for some exemptions, but perhaps not all of them.