Mr. John Devitt:

I am happy to take that again. We recommended that a cooling-off period be applied to any official engaging in lobbying irrespective of whether he or she is making a direct communication with his or her former colleagues. Some officials who move from a senior Department role such as in the Department of the Taoiseach or Department of Finance and who have day-to-day dealings with colleagues in other Departments such as the Departments of Health, Education, Justice and so on, bring with them a great detail of know-how and expertise from their time in those Departments, as well as contacts. Those contacts and that know-how is very valuable to a future employer in the private sector.

Furthermore, many will be employed not as lobbyists per sebut as senior management in public affairs consultancies or in the corporate sector. While the Act currently requires future lobbyists to consult the commission when assuming a role in the private sector or as a lobbyist where they may engage in direct communications, it does not prohibit them from directing lobbying efforts from working as, say, managing director of a public affairs consultancy or lobbying firm or, indeed, working in-house for a private company or corporation. Therefore, we would recommend that the cooling-off period be applied to public officials engaged in any capacity who may direct lobbying or even in those cases where someone may be in an advisory role to lobbyists or private interests who might engage in lobbying.