Under the interpretation, financial information is sensitive information. As the court in Trang notes, “financial information is one of the types of private information that falls at the heart of a person’s ‘biographical core’.... However, the degree of sensitivity of specific financial information is a contextual determination.” My understanding, based on the Privacy Commissioner's interpretation, is that you can still list information as sensitive and allow for a contextual argument to be made in the operationalization of the law.
What the department is saying right now is that they're predetermining the application and operationalization of sensitive information within the apple context that was provided today. I think that's a little over the top because we have well-defined processes in Canada between every banking customer and the bank that allow for sensitive information to be treated wisely. I don't see the basis of that...in addition to the nature of the Supreme Court ruling, which was about implied consent.
I'll ask you another question. In freedom of information in Canada, is financial information deemed sensitive or not under the freedom of information act?