I think what is most useful in that process, which includes a necessity test, by the way, for a privacy impact assessment—a “necessity of collection” is part of it. In our conversations with, for instance, the Office of the Privacy Commissioner, when we explain what a new program is going to look like, I can recall that in one circumstance they asked why we would expect to retain the documentation for such a long period of time.
In that particular circumstance, we were talking about citizenship. To determine citizenship, we often have to go back several generations. We had to explain why we retain data on file for 150 years, in some cases.
It's that kind of back-and-forth that gives clarity to them and gives us pause, frankly. It makes us think for a moment about whether we really need to retain it, or whether, while it was a circumstance that was necessary 20 years ago that, for some other reason, we can change now because, for instance, of new technology that would enable us to trace in a different way.
Yes, it is a useful process.