Ms Sherry Perreault:

I suppose that depends on the circumstance. That is why persons would have to seek the consent of the commission if they believe their obligations under section 22 of the Act might be engaged. The Act as currently drafted states that a person is prohibited from either engaging in certain lobbying activities themselves or being employed by or providing services to somebody who engages in those lobbying activities. If someone is, for example, invited to be on the board of directors of a charitable organisation, and that position is not remunerated, I would still view that as providing services to the organisation. If the organisation is a registered lobbyist and lobbies the public body the board member was formerly involved with, consent of the commission would be required. It depends on the circumstances of both the individual who has left office and the employment they are seeking to take up.