I want to come back to clause 6. It's asking for three things when you make a request: the subject, the type of record you are looking for, and the time period.
To me, that sounds exceedingly reasonable. I read also the intention of the clause. It's meant to provide an experienced employee—not even a new one, but an experienced employee of the institution—with help to identify the record with a reasonable effort. I find that part exceedingly reasonable.
We received testimony from Canada Border Services Agency and IRCC, and they welcome this clause because they believe it will make them more efficient in fulfilling the ATIPs, but you're against it. It seems reasonable to me, and the people who have to do the work see it as reasonable, but you're saying it's not reasonable.