BIK,
Our exemption has some definitions of course, and they accord with what you said.
DUTY : Any task (including positioning) that a flight crew member is required to carry out associated with the business of an operator.
Duty Period : A period which starts when a flight crew member is required to report for duty, until a flight crew member is free of all duties.
It then has the paragraph virtually as per CAO 48 WRT to Private Operations, except it says "all" private flying WRT flight and duty times recording.
Interpretative only, I'm sure, but a potential trap for the unwary and an FOI who wants to play hardball????
As I said doesn't really affect me anymore, as I don't fly privately much now. The exemption also does away with the standing 40 hr in 7 day limitation we used to have for late night ops too. Only have to consider 40 hrs if you utilise the split duty provisions twice in a 7 day period.
It certainly is a little different to our last one anyhow........... More "flexible" if anything......