Data Breach Confessions of a Reasonable Person

A little trivia:

Q: How many times do the words "reasonable" or "reasonably" appear in the new data breach notification laws?

A: 38, according to lawyer, Peter Moon serving up his take on a recent panel including Telstra's Chief Privacy Officer, Jason Holandsjo and the Australian Information Commissioner Timothy Pilgrim, where Holandsjo:

"doubted that either he or the nation's top privacy watchdog could stand in the shoes of that mythical character the law calls the ordinary, reasonable person."

If not them, then who?