I think that proposed section 15 on consent does need to be amended, and I speak to this in the document that I left with you.
On the concept of “legitimate interest”, I would give the following advice. This is a concept that exists in European law, which is considered to be the gold standard internationally. I think it is possible to have a “legitimate interest” type of exception to consent, provided that the sum total of proposed sections 2, 5, 12 and 94 actually do protect privacy as a fundamental right. There's no inconsistency between “legitimate interest” and considering privacy as a fundamental right.