Yes, that's correct. The department's interpretation is that understandings of who is vulnerable for different purposes changes over time. The risk of defining it by specifically listing some groups of vulnerable populations in the code is that it would need to be amended as often as understanding evolves.
The other thing to note about the way the term “vulnerable population” would be used in proposed section 493.2 of the Criminal Code is that there is some language there that suggests what would be vulnerable in that context.
It's not about who's overrepresented at large, but which vulnerable groups are disadvantaged by the bail process. This definition of “vulnerable population” addresses people who are vulnerable in the criminal justice process, but not necessarily for this purpose. The language in proposed section 493.2 would guide police and courts as to what type of vulnerability is relevant in this context.