We have consulted a number of experts, including academics and privacy researchers, and the concept of reasonably foreseeable, which is a well-established principle in law, is a necessary construct. It's mentioned almost 50 times in the existing PIPEDA, which we believe regulators and courts are adept at interpreting. Not including that term would have a potential chilling impact on the use of the technique, which ultimately leads to negative outcomes for privacy protection. We think there should be increased uses of anonymization to try to render as much of the information utilized in that format rather than unidentifiable or de-identifiable formats because of the privacy-protecting value of that.
In fact, using anonymized datasets could help in a number of heavy data user applications, including potentially in the space of AI.
That's our view of why reasonably foreseeable is an important construct.