With respect to the Conflict of Interest Act, in proposed section 2 there are two definitions that concern us, the definition of public office holder and the definition of reporting public office holder.
Depending on whether you consider that the honorarium the foundation pays to the members of its board of directors to be a salary or not, our GIC appointments to the board are either reporting public office holders or public office holders. There follows in the Conflict of Interest Act a number of restrictions on the activities of these people, both while they're on the board and when they leave the board, that may not have been intended, and we would be interested to get some clarification on that point.
With respect to the amendments to the Lobbyists Registration Act, the foundation is already registered as a lobbyist, and we don't see any difficulty in meeting the additional requirements in clause 69.
With respect to amendments to the Access to Information Act, we have always behaved as though we were subject to the Access to Information Act, but we do anticipate some difficulty in ensuring the availability of documents in both official languages, given that the foundation's practice internally has always been to have the staff members produce the documents in the language of their choice. Any dealings with the public, of course, are in both languages of Canada.
The other difficulty we may encounter is respecting the time limits with respect to meeting retroactive requests. We believe that the exemptions proposed in the amendments to the Access to Information Act will be useful. We need to protect the personal information of the some 500,000 to 600,000 students on whom we have files, and we also need to protect the information that we receive from governments in confidence and the material we use in negotiations with governments.
With respect to the amendments to the Privacy Act, the foundation is already complying with some 13 privacy laws--those of the provinces and territories. We don't anticipate any difficulty in protecting the information, although this bill will require us to post information on the databanks where we hold personal information, and as I mentioned, we have a lot of it. So additional effort will be required to inform the public about the nature of the information that we hold in our banks.
The Auditor General Act has also been amended and the Auditor General has in the last couple of weeks arrived at the foundation. We believe this is an excellent opportunity for the foundation to make the public aware of its achievements in flatlining student debt, beginning in 2000 in real dollars, contributing to a significant decline in dropouts in higher education among high-borrower students, and to show that the foundation has delivered $1.28 of student financial assistance for every dollar it receives from the taxpayers and has done so with a staff of 40 and overheads of under 7%.