No, not a data breach at all. The language used in Bill S-4 is exceptionally broad. It refers to the ability to disclose this information—here, I can try to call it up for you—where it is reasonable for the purposes of investigating a breach of an agreement or a contravention of a law that's either been, has been, or might even be committed, and where it is reasonable to think that if the individual were made aware of that disclosure, it would compromise the investigation.
We're not talking about data breaches here; we're talking about virtually carte blanche voluntary disclosures.