Thomas-Henry questions COIB on education and prevention
Thomas-Henry asks what additions are needed given the rapidly changing environment. Carolyn responds that education is more effective than annual disclosure for preventing violations, since disclosure reports cover conduct from nearly a year prior.
Thank you.
So I have a couple of questions.
You mentioned that this may be more than what is necessary.
So given that this rapid changing environment, has your team looked at what would be
needed or should be added to make sure that
we deal with this?
I think generally the annual, well, so there's like always two things.
The first thing is first education, because the goal is not to sort of catch people after the fact, but to prevent violations before they occur.
So our focus is always on public servants to try to educate them about their obligations under the conflicts of interest law and to protect confidential city information.
And we do that all the time.
We're very rigorous in trying to reach out to public servants in every way we possibly can about protecting confidential city information.
And there's all kinds of confidential city information that one might not place an event contract on.
Confidential information about someone's public assistance benefits, about child abuse and neglect investigations, things that public servants are incredibly private that
we have for decades ensured that that information is kept confidential.
The annual disclosure law in particular is sort of a very difficult way to regulate that conduct because it has to do with
things that happened almost a full year.
So, right, the council has just reported recently on conduct from 2025.
So it's the most effective way to change people's behavior is forward-looking, is the advice and education context and not in the annual disclosure realm.