Mr. John Devitt:

The definition of DPO, designated public official, has been the subject of some debate. Some time back, we also recommended that officials above the grade of principal officer be included as DPOs. We were then made aware there were concerns that this might pose an undue burden on public bodies in listing those principal officers. In those circumstances, we would suggest that where there is uncertainty about the identity of a principal officer, the lobbyist would make a return citing the Minister responsible for the Department rather than naming the principal officer. We do this regularly in making submissions to Departments where we have lobbied a civil servant below the grade of assistant secretary and, instead, will name the Minister or Minister of State responsible for that particular Department rather than the principal officer, if the principal officer is not listed as a designated public official.