First, for clarity it was in the province of Saskatchewan that we were undertaking this. Saskatchewan does not have a PIPA and is subject fully to the federal PIPEDA.
I first have to stress that in this pilot project, which was launched by the Privacy Commissioner of Canada and my office partnered with it, we weren't specifically looking to determine who was compliant and who wasn't. The focus was on determining whether there were things that could be done firstly to chart to what extent people were conversant and compliant and then to chart some strategies for those who were not.
Chantal wasn't directly involved at the time with the project, which was done by the federal office. The pilot project didn't end up producing a final report. I think we would have to say that there were some problems with the process, and so the pilot project did not get to a final report.
Certainly we found organizations that didn't have a privacy officer, that didn't have appropriate policies and procedures for their staff to follow to ensure that privacy was being protected. These are requirements, for organizations to be able to meet the requirements of the statute.
I'm not sure I'm being entirely responsive, but we weren't keeping track of people who were in violation; we were having meetings with groups of people and determining their level of awareness. We found that the level of awareness was not satisfactory and then found that there were a number of supports and tools and resources that they didn't have and needed to have, to be compliant.