You're very right. The aim of the act is transparency and accountability, and it has been said over and over again by the court. In some ways you're going against the principle of the act itself. You are also going against a trend. The British House of Commons is now subject to the act.
If you want to retrench from that and say we're going to be having an exclusion or an exemption, you want to do it with some measure of caution, because from a political standpoint, with respect to transparency, you want to make it a little less transparent than what it actually is at the moment.
Whether or not you use a more cautionary approach for documents that are being released to government institutions, with the knowledge that some but not all of those documents may be accessible without having to submit a request, if it does happen, then you no longer should be able to count on getting notice, because you really are not entitled to such notice. Once the access to information coordinators have these records, they will process them as they do with all other records and probably will make them available to the individuals who have requested them.
The final analysis is whether or not the risk to the parliamentary privilege—and really that's what it boils down to—is such that you cannot take any risk of having any of it being disclosed, and by so doing, then you have to go to an exclusion or an exception.