Thank you.
On this, I would say that what the Privacy Commissioner has called for is the Spencer test being put into the law.
When I look at the paragraph you quoted on that, I see three criteria: the criterion of “exigent circumstances”, the criterion of “a reasonable law” and the criterion of “prescribed circumstances”, which are the three criteria in the Spencer decision. What I want to make clear is that these are three separate criteria, so they are either-or. It can be exigent circumstances, or reasonable law, or prescribed circumstances. Actually, the Spencer decision doesn't refer to them as “prescribed circumstances” but rather as “the common law authority” that police have, which is in paragraph 71 of R. v. Spencer.
Those are the three criteria set out in R. v. Spencer. To the extent it should be defined, that is the definition currently used by law enforcement and organizations when they disclose pursuant to PIPEDA.