Whether it is a request-based model where something is released, or something is released unless there's an argument not to, redaction is the process of separating the releasable from the unreleasable. It does require the exercise of judgment and interpretation of the law and the practices.
The first screen should be clarity and definitions, with very precise and clear language and definitions, which could be updated from the 1980s version of them to catch up with current practice. Then I think you have to give the commissioner a role in challenging and overseeing, and the ability to call out what he or she sees as inappropriate redaction.
At the end of the day, you can go to the Federal Court, and the courts would have the final say on a lot of issues. I believe the Federal Court should have the final say on any issue to do with whether cabinet confidences are involved or not.
My recommendation, which you'll see in the brief, is that the definition of cabinet confidence is far too broad right now.