I would separate them into the access to information system and the privacy system.
The access to information system is easily defeated on the basis that it relies on an honour system. As we heard in testimony from the deputy minister, there's no standard procedure under which different groups across the department are required to respond, so there's ripe opportunity for abuse where records can be withheld or deleted and very little accountability.
In terms of the privacy system, a significant barrier and challenge I'll highlight is that you are required to name the individual record holder in trying to get access to your personal information. As an example, I would welcome any member of this committee to name the individual Canada Revenue Agency employee who helped process your tax return to know whether you could get information on that under the Privacy Act. I can tell you that a victim of sexual misconduct does not have information about the totality of the headquarters and who is involved in their files.