I think your understanding of 'proactively' might just be different from parent's (and mine).
I'd agree that entities that provide their users' data upon a simple request, and a carveout in regulations that allows (not forces) them to do so, fits the definition of proactive.
Let's not get all Humpty Dumpty here. "Upon request" is reactive by definition. "Proactive" sharing would quite literally mean sharing on one's own initiative.