I welcome the addition of the intelligence commissioner review role. That is an important improvement that was made, and I fully support it. I think the addition of necessity and proportionality to the scope of orders that could be made by the Governor in Council and by the minister is critical. That's a concept in privacy law that's shared around the world. In fact, the signatories to the OECD's December 2022 declaration on government access to private sector information unanimously and expressly called for “necessity” and “proportionality”. It's very important.
I believe Intelligence Commissioner Noël also talked about the notion of reasonableness and proportionality. That is a very important standard. There's some language in the legislation that calls for a consideration of privacy impacts. That's a good thing, but it needs to go further, in my view, to be necessary and proportional.