Information & Ethics committee  Yes, the errors have tended to be dates. But Bruce also mentioned that sometimes people are not clear on the designated public office-holder, so they include directors general. But there are also some who feel that because it's free they want to make sure they're protected, so they put in their names.

Information & Ethics committee  That would be one of the factors. But first it would be what they were actually doing while they were in government. The act is quite specific in terms of designating certain individuals and wanting to ensure, as I mentioned earlier, that they could not use personal contacts that they may have gained.

Information & Ethics committee  I'm sorry if I was misunderstood. The lobbyist is required to file the monthly communication entry. The requirement in terms of the designated public officer-holder is if they were requested by me to verify that entry.

Information & Ethics committee  Since we put a process in place, we're verifying roughly 40 entries a month. Between July and November we verified more than 300 entries, which is roughly 13% of the communication entries that had been filed. The responses we've received seem to indicate an error percentage of about 7%.

Information & Ethics committee  There may be some of that, but it's too early to tell.

Information & Ethics committee  Good question. It has not been revised to date, other than by the previous registrar, who changed the opening message. The previous message from Howard Wilson, the registrar who had brought in the code in 1997, indicated that a breach of the rule would be necessary to determine a breach of the code.

Information & Ethics committee  The principles of the act have not changed. The four principles I mentioned during my introductory remarks are actually the same four principles in the code. I don't see the changes in the act affecting that at all.

Information & Ethics committee  The act is quite specific in terms of the paid lobbyist and types of communication. We have had individuals call our office saying they were doing such-and-such an event and asking whether they need to register it. The act does have formal communication as well as informal communication.

Information & Ethics committee  That is a good question. In fact, each month some 600 reports are generated within the system. One person in my office has been given the task of checking the system regularly, to determine where errors might occur. In order to be more efficient, we can send a letter to the public office holder and determine whether there is more than one entry for a given person.

Information & Ethics committee  If we find errors, we communicate with the public office holders in question. We go back to the lobbyists themselves, since they are responsible for the statement, and we ask them to make any changes needed. At present, it is not possible for the lobbyists themselves to make those changes, but we ask them to respond within 10 days so that we can enter the changes in the system ourselves.

Information & Ethics committee  Frankly, I don't have any details on that.

Information & Ethics committee  On the investigations side, the six that were remaining were opened sometime between 2005 and 2007. One of the reasons for the delay with the investigation, as you may be aware, was that there was a court case filed on the four that we did table with Parliament. When we received the results of the decision from the court in March 2008, the decision of the judge actually questioned the registrar's ability to investigate breaches of the act where the individual had not been registered.

Information & Ethics committee  No matter what level they are at in the RCMP or armed forces, they would be public office-holders. So if a consultant lobbyist were communicating with a person at any level there, then they would have to register. In house, they would become part...and they would have to factor in the significant amount of duties to determine whether registration was required.

Information & Ethics committee  I must say that I honestly have difficulty answering the question, because we were not responsible for the legislation. At the time, Treasury Board was responsible for enforcing the act.

Information & Ethics committee  Yes.