Your reference to subsection 15(5) is what we're looking at too, and it says:
the reasonable expectations of the individual and the sensitivity of the personal information
Both of those have to be considered in that scenario in order to be considered, so when you say “and the sensitivity”, and by definition you construct a bill that says that this information is always sensitive, you obviate the ability to take advantage of implied consent. You now default to a scenario of express consent, and that's the issue we're raising for consideration.