I would agree with that. I think it's the definition of “harm”. If you set a threshold of material harm in various areas, you're going to almost certainly capture high-impact use cases. For instance, we've dealt with the delivery of health care services, but Nicole referenced human rights issues, so it adds that target. Accommodation, employment or credit opportunities raise human rights issues and should probably be defined as high impact.
I don't think you have to capture every possible use case, but if you at least set a legal threshold of material harm, you're going to capture most high-impact cases.