I would disagree. I think that Bill C-12 which was previously there, had made the effort to set a bar for material breach reporting to OPC, which was based on the seriousness of the information lost and the number of people affected. Again, it also threw in this business about systemic problems, which I think is complicating things. That would mean that the number of material breaches reported to the Privacy Commissioner would not be overwhelmingly burdensome because it would be larger breaches affecting people in a serious way.
On February 19th, 2015. See this statement in context.