The problem with the proposed subsection 15(5), which also ties to proposed subsection15(6), which also ties to proposed subsection 18(1) and proposed subsection 18(2), is that the implied consent is allowed on a wide variety of things, including “any other prescribed activity”— whatever that is. It leaves it wide open.
Earlier in the bill, in the consent section, it says that if express consent is required and if there is a new provision or a new use of that person's data, the express consent needs to be given again.
It seems to me that this is contradictory, in saying, “Well, I can apply it anyway. I don't have to pay attention to the earlier part of the bill that says I have to get express consent for a new purpose, except when I look at proposed subsections 15(5), 15(6), 18(1) and 18(2).”