The problem with proactive disclosure—as it sits in the law and Bill C-58, which changed the access act—is that it defines a very small number of documents, so-called ministerial documents, that are going to be released on the government's timetable, with no watchdog.
To me, proactive disclosure is a red herring. It's a way to divert our attention from fixing the main problem, which is the Access to Information Act's dysfunctionality.
On the issue of the immigration files, there's a big privacy issue, and I don't think proactive disclosure in that sense is possible. It has to be a client-to-client kind of disclosure.
I don't accept proactive disclosure as some kind of panacea for the system. It's not. It diverts our energies and attention from the big problem, which is a dysfunctional act.