We aren't necessarily suggesting that the documents be destroyed within a short time frame. We are recommending a risk-based approach. A great deal of information is collected on a huge number of transactions, the vast majority of which relates to the financial transactions of law-abiding Canadians. That is the basis of the approach used to detect criminals or terrorists and is very similar to the procedure proposed in Bill C-51 and Bill C-59. It has merit, but the information has to be screened using numerous pieces of data to uncover threats and individuals who are security threats or criminals.
I am not calling the process into question, but it's helpful to keep some figures in mind. Over the past few years, the ratio of actionable disclosures to law enforcement or other organizations has been one for every 10,000 reports received. For every 10,000 reports received, only one disclosure is made to police, the Canada Revenue Agency, or security agencies. We found that a significant amount of information is collected but that people pose a security threat in a very small number of cases.
I'm not saying that the information should no longer be collected, but I am recommending that a risk-based approach be adopted, as the Canada Revenue Agency officials more or less suggested. A considerable amount of information can be gathered initially, but a risk-based approach—one that takes into account the usefulness of the information for forensic evidence purposes—can be applied. That could be one of the factors given consideration. However, a risk analysis should be conducted fairly early on to determine whether the information needs to be retained or not. It is possible that, for a variety of reasons, a certain number of reports would need to be retained for a long period of time. On the flip side, I think many other reports would need to be destroyed rather quickly, as proposed in Bill C-59.
Personally, I see similarities between the approach set out in Bill C-59, which proposes extensive data collection in order to identify the small number of people who pose a threat, and the collection of financial transaction information under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, in order to identify a small number of criminals who are laundering money or contributing to terrorist financing.