Our program was put in place before the privacy impact assessment directive was issued. That doesn't mean that privacy isn't important. When the directive was issued in 2010, we felt that our program hadn't undergone any major changes since it was established in 1996. In 2010, we were already using flip phones and devices in the Nokia and Blackberry lines. Then came smart phones, but we didn't think that adding those new, more advanced devices constituted a radical change to our program.
However, in response to the Privacy Commissioner's testimony and to news that came out in December, we contacted the Office of the Privacy Commissioner and started the process.