Based on the Supreme Court of Canada Ruling in O'Connor

Based on the Supreme Court of Canada ruling in O'Connor, what is the first element a judge has to consider when determining if a victim's counselling records can be accessed by the defence?

A) whether the counselling records are likely to be of sufficient relevance to the defence
B) whether access is necessary to achieve the goal of justice
C) whether the counselling records balance the interests of the defence with the impact such information might have upon the complainant's right to privacy, dignity, and security
D) whether access is necessary to resolve a substantive criminal law issue