I understand the government's view, which was taken during the Bill C-51 debates, that the new act doesn't authorize new collection, but it depends how you measure collection. Sufficiently broad information sharing allows for the pooling of information within the hands of one agency. The information that would not legally have been able to accrue in one agency is now available to it. Technically that's not collection in the sense that it's not been extracted from outside of government from an individual, but rather it's the amalgamation of information in a database in the hands of an agency.
Then the question becomes what the agency can do with that new amalgamated database. Are there controls on the searches it can run through that mother of all databases? Are there provisions that guard how it can then be combined with public-source information to paint an intimate portrait of an individual?
In the world of big data, the boundaries between collection and use are beginning to blur because of the amount of information that is currently in circulation and easily extractable from the public domain. In the absence of safeguards on how information is amalgamated by an agency and then what it can do with that information, I think that we run the risk that the net result is that the government knows more about people than it would otherwise know.