1 A CONCEPTUAL APPROACH TO PRIVACY Miscellaneous Paper the strict sense. as richard Bruyer had considered in a different context, �e[b]y limiting the ambit of privacy, we may indeed strengthen it.�f¹⁶⁸ 108. crucially, however, allen has accepted that while a �edegree of inaccessibility�f is a �enecessary condition�f for �eprivacy to aptly apply�f, it is not a sufficient condition �efor the proper use of privacy�f. something more than �einaccessibility�f is required. she explains that �eprivacy�f and �einaccessibility�f are not synonymous.¹⁶⁹ there is, in her view, rough if not exact correspondence between the two. examples of synonymy and discordance between �eprivacy�f and �einaccessibility�f are supplied. �ea person is physically inaccessible if others are unable to experience her directly through at least one of the five senses.conversely, a person whose body can be directly seen, touched, tasted, heard, or smelled is physically accessible. Persons who are physically inaccessibly by virtue of physical structures or distance possess the form of privacy called �gseclusion�h and sometimes �gsolitude�h. thus, some familiar senses of privacy do correspond to the first familiar sense of �ginaccessibility�h.�f¹⁷⁰ 109. allen adds that �eOf course, �gprivacy�h and �ginaccessibility�h�c do not carry precisely the same meanings and connotations in each and every context�f.¹⁷¹ For one thing, �e �gprivacy�h has many �gwarm�h associations, �ginaccessibility�h many �gcold�h ones�f; for another, �e[w]e cannot exchange every occurrence of �gprivacy�h in an english-language sentence with �ginaccessibility�h and preserve the truth, value, and meaning of the sentence�f.¹⁷² Nevertheless, allen insists that �einaccessibility�f supplies insights. thus, an individual might be physically accessible in one or more of the senses by direct sight, physical contact, scent, taste, or aurally but be �edispositionally inaccessible�f or unforthcoming.¹⁷³ 110. Gavison�fs approach has certainly been influential. For instance, Burrows and cheer in Media Law in New Zealand observe (after ruth Gavison) that the three elements of �eprivacy�f are �esecrecy, solitude, and anonymity�f.¹⁷⁴ y et its failure is that it supplies a descriptive account that does not adequately address the subtleties of accessibility and individual choice in a social world. i now turn to examine this question. 168  richard B Bruyer, �ePrivacy: a review and critique of the literature�f (2006) 43 alberta law rev 553, at 553 (abstract) and 588. 169  a nita llen, Uneasy Access: Privacy for Women in a Free Society, 16. 170  i bid, 16-17. 171  i bid, 16. 172  i bid. 173  i bid, 17. 174  ursula cheer, �ePrivacy�f in John Burrows and ursula cheer, Media Law in New Zealand (Oxford u  niversity Press, Melbourne,5 th ed, 2005) at 234.