They are exigent circumstances, a reasonable law other than section 44, and common-law authority that police have. Those are the three circumstances that are set out in Spencer. Again, they are not cumulative. They are separate; it's either-or. Either there are exigent circumstances or there's a reasonable law or there is common-law authority whereby personal information that does not attract a reasonable expectation of privacy can be disclosed.
Those are the exact words in paragraph 71 of R. v. Spencer, which the Privacy Commissioner referred to.