There's no reference to internal organizations nor internal fraud. The new (d.1) is talking about “a breach of an agreement or a contravention of the laws of Canada or a province” that's either been committed or, even, that might be about to be committed. It's anticipatory: I think something might happen, and so I'm going to move forward. We're talking about breach of contract even. Someone could then say that I'm entitled to voluntarily disclose. The notion that Canadians ought to be assured that there's a reasonableness standard in there doesn't strike me as providing much comfort whatsoever. This is very broad. There are no limits and there are no clear limits, limits other than that reasonableness, but that's a very limited standard, and there are no limitations set on what can happen to that information afterwards. We're not talking about security breach. We're not talking about fraud. We're not talking about internal investigations here. We're talking about something much, much broader.
On March 10th, 2015. See this statement in context.