It's a difficult point, because we accept that metadata is more revealing of private conduct, of browsing history. But transmission data, information on the mere originator and recipient of a communication, can be revealing if it's repeated. The example we gave in our written submission is of a person repeatedly contacting a specific health care provider, spending a lot of time on a mental health line, for example. That is for biographical information, and that's why we say that transmission data provisions may reveal private conduct and should be subject to the higher standard of reasonable grounds to believe.
On May 27th, 2014. See this statement in context.