I don't think we can make any assumptions that there was a presumption of consent, not at all. I know consent is difficult. I agree that doing this on a large scale can be extremely difficult. I understand all of that. However, at the very least, provide notice, meaning you publicize. You are the government. You're PHAC. You publicize that you're doing this.
At the very least, you go to the Privacy Commissioner, you alert him, and ask for his input and assistance in making sure the public is aware of what's taking place. You alert him that it's being strongly de-identified and aggregated, and therefore the commissioner feels it's appropriate, something like that. You don't do it quietly, in my view. I think that's big mistake.