First of all, thank you very much for having me. Hello, everyone.
To give you some context as to why you might be listening to me, my area of research is political marketing and communication in Canada. A lot of my research surrounds...[Technical difficulty--Editor]...people who work in campaigns at the national and local levels. As well I have reviewed party and local expense declarations for my research.
I thought probably the best use of my time and your time would be if I went through the elections act and tried to identify some areas that I thought may warrant a little bit of scrutiny. I came up with what I would call...[Technical difficulty--Editor]. I'm happy to follow up by email outlining what these are. I'll just summarize them very briefly, if that's all right.
The first one is in proposed sections 348.16 to 348.19, which mention scripts and recordings. What I would like to suggest in that area is, while there is mention that the script will be available for a year, I wonder if it would be more transparent if it said that this script would be publicly available after a year. So rather than it just disappear, it would be publicly available to researchers and others who are interested one year later.
The next one is in proposed section 350. There's mention of third-party spending being no more than $150,000. I don't have any issue with that, but there is one thing that I think everybody should think about. That is that the cost of advertising is changing. We are ostensibly seeing a big change occur at the moment, because what is happening is that you now have video advertising. Due to video advertising online, all of a sudden now there are all sorts of groups who are able to communicate in ways that don't involve money and yet our Elections Act, for the most part, is focused on stopping people from spending too much money. So I'd just like to bring that to your attention as a consideration.
Proposed section 366 mentions receipt for contributions of $20 or more. To me this is something that is worth thinking about because political parties are actively looking for very small donations. They're often saying, “Can you please donate $3?” Because of this, it starts raising questions about anonymous contributions as well. I think the $20 limit to me is one for which I would like to have better understanding of the justification.
Under proposed subsection 376(3), there are expenses for soliciting money. It's not an election expense if directed to people who have donated $20 or more in the past five years. Not that I have a big problem with that but I find it a bit confusing because it's very hard to establish, the way it's worded, who exactly those people are. How do we make sure that we're not also communicating broader messages, or how do we make sure that we're only focused on those particular people and not casting a wider net?
Another comment I have is on proposed subsection 383(2), which is regarding public availability of the election campaign return for six months and retention for three years. I'm wondering if those documents could be publicly available for an indefinite period of time through Elections Canada.
Proposed section 348.01 provides a definition of automatic dialing-announcing devices. I assume this is related to robocalling. In my opinion, it's important to differentiate between helpful outbound calls that are merely about providing information, and calls that are more of a research nature where information is being provided by the person on the other end of the phone. Increasingly we're seeing research interviews being done through electronic means. I think it is important not to confuse that somebody may be making a phone call to try to conduct a survey, and that is different than simply providing information to somebody about going to a polling booth.
As well there is a proposed subsection 421(1), which mentions a party merger is not allowed 30 days before issue. I'll just bring it to your attention that it does occur to me, what if there was a snap election? I'm not a lawyer, you'd need to look at the wording. But is there a possibility that two parties could merge and the Prime Minister could request a snap election in order to defeat the merger of those parties? I just raise that for your attention.
I have two more points to make. Proposed subsection 431(2) and proposed section 477.52 make mention of the prohibition of collusion for...[Technical difficulty--Editor]. I just wonder if there's any mention of prohibiting collusion for donation purposes.
The last thing I'll mention, which I am I personally hoping for a little bit of clarity on is proposed section 445. It just makes me wonder if the whole matter of quarterly allowances is being reintroduced—the ones that caused a kerfuffle earlier—or if I'm missing something and I didn't interpret it properly.
So thank you very much, and as I said, if you're open to it, I'll follow up by email with those comments.