I do understand the objections of my colleagues, Mr. Housefather and Mr. Fergus. Yet the process is not at all clear in the current wording of the act. By leaving the phrase “in a form acceptable to the Commissioner”, absolutely no guidelines are provided as to that form. It simply restricts the process. There is nothing in the bill saying that the commissioner may not accept a verbal complaint in a particular case, for instance.
This is a recommendation that was made by certain witnesses, specifically Mr. Hutton, if I am not mistaken. The witnesses made two important points. First, they said that a complaint had to contain very specific words, the magic words, in order to be deemed acceptable, and that the absence of those words was in some cases a reason for the complaint to be dismissed. Secondly, they said that restricting as much as possible the form in which a complaint can be submitted served to restrict the process.
The current process is not any clearer. The commissioner has full latitude to determine what is acceptable. Nothing prevents the commissioner from setting guidelines and providing tools for whistle-blowers to use without necessarily excluding other methods.