We think there needs to be a consultation process on what exactly “arranged communications” means. Is it the definition we were given when the act came into effect? Was it the definition that apparently and reportedly has been provided to other parties?
When we've seen them try to break it down, they get into how there's a request made, there's a time interval between the request and the acceptance, and that's what constitutes “arranged”. So if I were to approach you at a cocktail party and ask you if I can talk to you about an issue, and you think about it for a second and say yes, that's now an arranged communication. If I just walk up and blurt out my issue without asking you whether you want to hear me first, then it's not arranged.
The lines are pretty vague here. We think you need to have a pretty clear process to determine what the actual definition is. We don't agree with just getting rid of the word, because it's problematic: it would require designated public office holders to keep records of every conversation about files they have with anyone, in case that person happened to be a lobbyist.