Mr. Giorno's memo says, in fact:
Staff members should also be aware that subsection 67.1(1) of the Access to Information Act makes it an offence to obstruct the right of access:
No person shall, with intent to deny a right of access under this Act,
(a) destroy, mutilate, or alter a record;
(b) falsify a record or make a false record;
(c) conceal a record; or
(d) direct, propose, counsel or cause any person in any manner to do anything mentioned in any of paragraphs (a) to (c).
While most political staff members are familiar with the law and their responsibilities, it is useful to refresh their knowledge and awareness.
I want to go back to the request that you asked to have unreleased. In looking at the (a), (b), (c), and (d), and “destroy, mutilate, or alter a record”, clearly when that information was ultimately released, what had been prepared by the bureaucrats I think was something in the order of 132 pages, and what finally went out was 30 pages. I think that's what it was.
So I guess I'm just asking: would you not consider that to be altering a record?