Yes. This is the last point.
On the proactive disclosure piece, this is not a substitute for a strong access regime. The proactive publication regime established by the act lets the government decide what Canadians can see and applies primarily to financial information. Canadians have many other concerns that are not covered by this proactive publication. The Information Commissioner plays no role in overseeing the proactive publication regime. There appear to be no consequences for an entity that simply ignores the requirements. These appear, actually, to be proactive publication suggestions.
This is not the open and transparent government that Canadians want and deserve, and it's not the overhaul of the access act that is clearly needed.
Thank you.