What is the impact of a police undercover investigation on privacy rights?

In her reasons, Karakatsanis J. states that “rogue police undercover investigations” should be appropriately characterized as a threat to the integrity of the justice system itself: para. 62. She looks to mechanisms such as abuse of process and the entrapment doctrine to redress these types of police tactics: paras. 62-63. I agree that police action that “offends our basic values” (Rothman v. The Queen, 1981 CanLII 23 (SCC), [1981] 1 S.C.R. 640, at p. 689, per Lamer J.) can and should be addressed in a number of ways; this is for the good. However, when that state action also intrudes on a reasonable expectation of privacy, it is intended to be addressed, inter alia, via s. 8 of the Charter. What is at issue in this appeal is not only the actions of one officer, but also the general rule that should govern how the state may gain access to private communications using current technologies. In my view, placing communications outside s. 8 because the state recipient can now obtain a record of the conversation simply by engaging in it, undermines the purpose of privacy rights and upsets the careful balance between the ability of the state to investigate crime and the rights of individuals to private areas of expression.