When you are looking at a particular record of data, you have to look at it in context in order to make a determination. Doing that is actually for privacy protection. “Reasonably foreseeable in the circumstances” is that contextual factor that needs to be articulated. It's consistent with best practices. This is the way in which risk management is implemented for the purposes of this analysis.
Khaled, I would ask you to please supplement that. You deal with this so practically. It would be very helpful.