I'll read you 4.2.2 of the “Policy on Privacy Protection” from the Treasury Board. It says:
Notifying the Privacy Commissioner of any planned initiatives (legislation, regulations, policies, programs) that could relate to the Act or to any of its provisions, or that may have an impact on the privacy of Canadians. This notification is to take place at a sufficiently early stage to permit the Commissioner to review and discuss the issues involved.
It's that same point. Do it before, not after, so we can flag concerns.