We want a variety of solutions.
We're very aware of the privacy issues and the difficulties associated with filing a complaint on behalf of someone without their consent. This would be done primarily when systemic issues are at play. People should be able to point out a tendency without necessarily naming anyone, particularly when a number of individuals see the same thing happening to our members over and over again.
Furthermore, in our brief, we talk about a person filing a complaint themselves or consenting to a third party acting on their behalf. The member agencies could back up the complaint with other examples, without naming the individuals involved, to demonstrate that the problem is widespread and that it's not an isolated incident.
We're proposing various strategies, but they're not reflected in the current bill.