I would agree with that.
I think there is difficulty in relying on the good faith obligation. I'm not condoning bad faith disclosures, but oftentimes people think of good faith as having, for example, a proper motivation. So if somebody is disclosing something because they want to get back at their supervisor, that's going to be bad faith and we don't want to deal with that disclosure. However, it could very well be that the supervisor was engaged in wrongdoing as well. Simply because there's some animus there on behalf of the discloser, that shouldn't disqualify that complaint. I do think we have to be careful with that.
I also think that, historically, in cases where people have gone public and they have been disciplined, the employer has often taken the position that you can't disclose wrongdoing unless you know the allegations to be true, the proof of truth requirement. That's going way too far, because sometimes you don't know and you can't know. Sometimes you just have a suspicion and want somebody to investigate to make sure whether it's true. Frankly, that's the whole role of the commissioner. If somebody has a suspicion, that should be sufficient, as long as it's reasonable and they're not acting in bad faith.