Official Report: Minutes of Evidence

The Deputy Chairperson (Mr Donnelly): From the Northern Ireland Human Rights Commission, I welcome Ms Alyson Kilpatrick, chief commissioner; Dr Colin Caughey, director of policy; and Dr Ivanka Antova, policy and research officer. Thank you very much for coming. I give you the floor.

Ms Alyson Kilpatrick (Northern Ireland Human Rights Commission): Thank you very much for having us. You have already introduced my two colleagues, whose great efforts went into preparing much of what you have received, and I will be asking them to deal with some of your detailed questions.

I will make a very short opening statement because, as you know, the Bill is quite complicated, and it is probably best to leave it to you to ask the questions that you want to ask. The introduction of the Bill is a very positive step that goes some way to addressing several recommendations that were made by international human rights bodies and the commission.

The commission particularly welcomes clause 1, which outlines principles that a health and social care worker must have regard to when performing the functions that are set out under Part 1. There is a significant overlap with — it is very reassuring for us to see that it mirrors — human rights principles in the criteria that are set out. The European Court of Human Rights has made clear that the very essence of the European Convention on Human Rights is respect for human dignity and human freedom, so we are very pleased to see dignity included in the list of guiding principles.

The Bill could go further by making explicit reference to human rights standards. The commission considers that expressly anchoring the Bill within the national human rights framework would place the Department in a stronger position to ensure that all statutory actors comply with their corresponding obligations when performing functions of adult protection. That is consistent with recommendations from the independent review of Dunmurry Manor, which stated:

in safeguarding procedures. We agree, respectfully.

In Part 2, clause 32(5) provides that the adult protection board:

Noting the important role that such reviews can play in exploring the root causes of abuse, the commission considers that the Bill should provide further detail and procedural standards for serious case reviews, including requirements for independence, timeliness, public scrutiny and involvement of the next of kin in accordance with article 2 of the European Convention on Human Rights. All the arguments that we often discuss about article 2 investigations apply equally here.

Part 3 makes it an offence for an individual who has the care of an adult by virtue of being a care worker to ill-treat or wilfully neglect that adult. There is also an associated care-provider offence, which addresses one of the commission's long-standing recommendations. That recommendation is repeated in our annual statement, so we are very pleased to see that offence included. That measure will ensure important protection for individuals, particularly persons with disabilities who are reliant on others for their care.

In relation to Part 4, we note that the installation of CCTV cameras can provide an important safeguard for those at risk of abuse. We recognise, however, that they can also infringe or interfere with the rights of individuals. It does not take much for all of us to understand exactly the intrusion of privacy that can arise. That being the case, the human rights framework provides the appropriate backdrop for decisions on the deployment of CCTV cameras on a case-by-case basis. Part 4 would be strengthened by expressly incorporating human rights considerations into the governance framework around the deployment, including the relevance of Windsor framework article 2. We ask, again, that article 2 of the Windsor framework be expressly considered in all forthcoming legislation and policy. Conducting human rights impact assessments before deployment can provide a critical check and ensure effective decision-making, which will protect everybody, including those deploying and using the cameras and those responsible for their oversight.

Some of that will be supplemented with regulations and guidance. At that stage, therefore, we expect to be able to say more on how, for example, CCTV is going to be used, regulated and monitored. We must, however, be conscious of GDPR provisions because there will be processing of data. There is also the question — I do not know the answer to this, which may be an oversight on my part — of whether the CCTV will be covert or overt. If it is to be covert, the Regulation of Investigatory Powers Act 2000 (RIPA) might apply, so that needs to be considered. I suspect that all that will be looked at in the context of regulations.

I will leave it there. I am willing to answer each and every question that you have.

The Deputy Chairperson (Mr Donnelly): Thank you. You said that the Bill could go further by explicitly mentioning human rights standards. What difference would that make?

Ms Kilpatrick: It would make a number of differences. One is to put in the legislation that human rights are part of the law. That is sometimes overlooked, and people assume that human rights principles were taken into account in the drafting of legislation. It reminds everyone, including those for whose benefit the legislation is drafted, that human rights are the lens through which they need to see everything. Also, public authorities, and the private actors who may be commissioned by public authorities, know that they have to be thinking about human rights. Apart from anything else, it is about keeping human rights standards at the front of people's minds. It also imports a framework of principles and jurisprudence — good, sound jurisprudence, built up over years — that can then influence how the legislation is interpreted. That is the real benefit of it.

Colin has done a lot of work on just that point.

Dr Colin Caughey (Northern Ireland Human Rights Commission): The potential slip-ups with the Bill will be in its implementation, so the greater the reference to human rights and human rights considerations, the more that that will inform the decision-making processes when the Bill becomes law. We are always in favour of more explicit references to human rights, although, obviously, the Bill has been through a compatibility assessment and the Human Rights Act 1998 will apply to the social workers who are exercising those powers. However, greater explicit references influence thought-making processes and prevent human rights abuses and infringements in the long term.

Dr Ivanka Antova (Northern Ireland Human Rights Commission): I will chime in regarding the Windsor framework. Following the UK's exit from the EU, an express reference to the Windsor framework would centre a limited but valuable additional safeguard to human rights in Northern Ireland. That would be an additional, albeit limited, safeguard against the diminution of certain rights.

Ms Kilpatrick: The reference to the Bill applying to private actors that are commissioned by local authorities is really welcome. We have worked, for example, with the families of those in nursing care. In the case of private facilities, families were often told that the Human Rights Act did not apply and that there was nothing that the Human Rights Commission could do for them. If a person is a patient and a service has been commissioned, the Human Rights Act does apply, but a lot of people do not understand that. Therefore, having that explicitly tied in is really useful, and a lot of families and people who are using services will be really reassured by the fact that it applies to everybody.

The Deputy Chairperson (Mr Donnelly): I note that you recommended:

Under section 69(6) of the Northern Ireland Act 1998, can you provide that educational assistance or financially assist to ensure that it is compliant with human rights standards? For that to happen, will it have to be referenced in the Bill?

Ms Kilpatrick: No, not in the Bill. The training should be considered to be essential. If you ask social workers and health workers to exercise additional powers, which they have not been trained to exercise, that may carry significant risks to them and others. If that involves a quite intrusive use of powers in people's personal space, there is a duty to have them well trained for their sake and that of everyone else. I would not like to go out untrained and have to exercise some of the powers that are being given to social workers, and I would certainly want to know exactly what I was being asked to do before I had to do it.

If I picked you up right, you were asking whether the commission could assist. We are always keen to help with advice on guidance or the human rights framework for a set of regulations. It is not for us to get into the weeds of a public authority's policy and training documents, but it is part of our role to guide it in the right direction and in a human rights-compliant way. Once regulations are drafted, there is a lot that we can do. Also, if we had a lot more resources, we might be able to do a lot more. Colin has been at the commission for longer than I have and has seen some of that through many different policy changes.

Dr Caughey: As the chief commissioner said, resourcing is a concern. We have worked with some public authorities to provide bespoke training, and we have a general statutory duty to promote human rights and provide education on human rights. If there was adequate resourcing, we could propose involvement to our commissioners, and we could certainly respond to any requests for advice from the Department of Health on the regulations and any of the training programmes.

Miss McAllister: Thank you very much for the presentation; it was very helpful. I have been very much looking forward to the Bill's coming before the Committee, and a couple of the points that have been raised have been very helpful. I want to focus on the serious case reviews and CCTV. There are, of course, human rights implications from the provision of CCTV, including the right to a private life, but had it not been for the CCTV cameras at Muckamore Abbey, we would not know the extent of a lot of the abuse that occurred there. I often ask people whether they would put their relatives into residential care if there was no CCTV, and, off the record, the answer is always no. How can we make CCTV mandatory within a human rights framework? I know that it is not always that easy, but how can we use human rights law to enable CCTV to be mandatory?

Ms Kilpatrick: An appropriately qualified person would need to look at all the circumstances in which you would be mandating the use of CCTV to decide whether it is necessary to protect life or protect against inhuman, degrading treatment and torture. Once you consider there to be an obligation to install CCTV to protect in that way, it will be a requirement to legislate to make that provision. That is how to look at it. If CCTV is required for the protection of life, you can insist on its being provided.

There is a whole other issue to consider, which is the use of CCTV recordings, including how that information is kept and what is done with it. If you were talking about live streaming or recording everything and having somebody watch it all back, that would raise significant concern, and we would want to get into that in more detail. However, if you are talking about having access to CCTV to go back and look at something should you need to do so, that is a different.

Miss McAllister: That is what I am talking about.

Ms Kilpatrick: You have to be very specific about that, which is why I talked about covert and overt use and the application of RIPA. It is a lot more complicated than just saying, "Surely, if there was a camera, a person would not misbehave", or, "If there had been a camera, we could have prosecuted them because we could have seen what they did". There is so much more to it than that, and I think that it is a lot more sensitive than that. It can be done lawfully, so long as you have very strict controls and are within the law with regard to accessing the footage, storing the footage and processing it etc.

I have some experience with surveillance cameras being used in policing. If you have cameras, there is a danger that the default position will be to have them running and be watching the footage the whole time, because, in people's minds, that eliminates the potential for false complaints or provides protection. However, it will also expose some of the most intrusive surveillance that you can possibly imagine, if you think of it in a care or health setting. If you try to put yourself in the position of the person who is receiving treatment or care, or their loved one who is with them, being watched with the potential that the footage will be kept and watched by somebody else, you start to plan properly for the protections. It is too easy to think that CCTV is only there for protection and is therefore an intrusion that we should put up with. So much more can be done to make sure that, while CCTV is there to protect, it is very closely controlled.

The Regulation and Quality Improvement Authority (RQIA) is expected to carry out some of the oversight, which is welcome. Someone needs to look at whether things such as the Regulation of Investigatory Powers Act apply. I hope that that will happen when the regulations come through. You may also have situations in which a person is in custody and has a police officer sitting in the room with them. CCTV in that scenario would be equivalent to covert surveillance of a police interview. Someone else might come in, such as a solicitor. There are all sorts of situations that you really need to think through in advance. There has been a knee-jerk reaction to one case in which cameras were useful because they proved something that we could not otherwise have proved. That needs to be tempered, and we need to made sure that the cameras are really achieving the purpose that we want them to achieve.

Miss McAllister: What if the cameras were there in case issues were raised? If they were in communal areas, would that negate some of the issues that you have raised? My last question about CCTV is this: are you in agreement that the regulation-making powers are the right way to go to regulate CCTV and its use rather than trying to do that in the Bill?

Ms Kilpatrick: Once you have people charged with deciding whether you want to mandate CCTV cameras in those settings, you look at the regulation, oversight and monitoring etc of their use, but you also have to think about where you put them. If you are limiting CCTV to communal areas, there are different considerations, but communal areas may still be private settings, and privacy might still be a factor. Recently, a friend of mine was one of the unfortunate people to be treated in a hallway, which was a communal area. In that case, a communal area has the potential to become a private area. If there is malign intent, harm is often caused in unexpected places. You need to be very careful about what you are trying to achieve, but you can do it; you can have coverage.

Miss McAllister: I understood that it would always be difficult, but there is reluctance to mandate it in the Bill. We are hearing a lot that it would be too complicated, but if the Department was going to do it, would it then engage with the Human Rights Commission, for example, to see how it could be done?

Ms Kilpatrick: It would be a lot more complicated for the Department and all the public authorities that were using it if they did not engage properly and did not have this all planned. That is when it gets really complicated.

Miss McAllister: Has the Department engaged?

Ms Kilpatrick: No, not yet.

Miss McAllister: We were told that the Department could not put it in the Bill for various reasons, but it sounds as though it could have done if there had been engagement on the matter.

Ms Kilpatrick: If consensus is reached and there is a political decision to legislate for that, unless there is a reason why it is unlawful or incompatible with human rights, there is no reason why you cannot put it in the Bill. The next stage is what use you make of that provision. At that stage, other laws may apply. The Act that mandates it would also need to contain safeguards, conditions and all the rest of it.

Maybe I am speaking too soon, but I do not see that as necessarily being difficult. CCTV is part of our lives and is used in many settings. We have regimes for processing the footage. The police could give a lot of advice on that, because they use body-worn video and have CCTV in custody suites.

Miss McAllister: The police want it to be mandated.

Ms Kilpatrick: Yes.

Miss McAllister: There is written correspondence to that effect. What if it is not in the Bill, but the Bill contains regulation-making powers?

Ms Kilpatrick: That is more difficult. Nearly always, something should be founded in legislation that the public can read, so that they can see the foundation of the law with which they are being asked to comply. That allows for proper democratic scrutiny. That can then give rise to regulations. We would be less comfortable with probably one of the most intrusive elements of the Bill, while not necessarily unlawful, being done by regulation and not by the Bill.

Miss McAllister: That is interesting. Alliance has done work with the police on this at the Policing Board, following Muckamore and a number of issues, and that is just not what we are hearing from the Department. I am now very concerned about its being left out. I was elected for the first time in this mandate, so if I am asking questions that seem a bit stupid, it is because legislation is still new to me. If something is not in the Bill, can it be mandated in regulations to the same extent as it can be in primary legislation? Will it have the same effect?

Ms Kilpatrick: I am not sure. My gut and my experience tell me that that would be difficult. It would certainly be open to challenge, because you are removing or restricting the fundamental right of a person to privacy, particularly in a most intimate setting, as well as the ability of people who work with them to go about their work without looking over their shoulder all the time due to the fear that somebody is watching them. If you are going to do that, it needs to be done in an open and transparent way, be subject to scrutiny and be democratically solid and done in a way that means that you can amend it openly and democratically. I am not sure whether it would be unlawful to legislate by way of regulation if there were not an underpinning power in the Act. It would certainly be problematic, and you would want to avoid such a scenario. I can be sure about that.

Miss McAllister: Thank you. That has been very helpful on the issues that I have been pursuing all along. I had questions on serious case reviews, but I am not sure whether we will have time for them. I am happy to come to them at the end or in correspondence.

Ms Kilpatrick: Absolutely. We can provide more advice on that. We will go back and look at it. It is much more a question of constitutional law. I do not want to tell you something that proves to be less than accurate.

Miss McAllister: We can engage separately on that.

Ms Kilpatrick: My experience tells me that it would be mistake.

Dr Caughey: The Examiner of Statutory Rules might be providing you with evidence on the Bill and would be able to answer specific questions.

Ms Kilpatrick: Human law principles certainly require legality in the face of any intrusion. It is much more difficult to highlight legality if it is in a regulation that is not underpinned by a democratically obvious piece of legislation.

The Deputy Chairperson (Mr Donnelly): Thank you. You have got your answer there, Nuala.

Mr Chambers: Alyson, you said at the start that the commission had concerns about CCTV. Like Nuala, I take the position that, had CCTV not been in Muckamore, that cruel regime might still be going on, and we would know nothing about it. The concern that you articulated was about the infringement of privacy as a human right. I come from the position that the protection of vulnerable people must also be a human right. Is there a hierarchy of human rights? Are some more important than others?

You also said — I thought it a bit ambiguous, if I heard you correctly — that the commission would back CCTV on a case-by-case basis. What factors would have to be in play for you to back and justify CCTV in a particular situation?

Ms Kilpatrick: I will deal with the first part, and then I will ask Colin to deal with the backing of CCTV on a case-by-case basis. I do not remember us saying it like that. Colin will be able to tell me whether I am wrong about that.

We do not have a concern with CCTV per se — absolutely not. I answered that question in the way that I did because we accept that vulnerable people must be protected, which is why we welcome the Bill. However, that does not mean that you suddenly cast aside all other protections, and vulnerable people also have a right to privacy. You say that you would not have known about Muckamore were it not for CCTV, but there were other ways of finding out about what was happening there, including better inspections, listening to some of the care workers there and listening to the patients and their loved ones who had been reporting incidents.

Mr Chambers: It would have been difficult to bring prosecutions in those circumstances.

Ms Kilpatrick: I do not disagree. All I am saying is that there are myriad ways in which you can ensure that such things do not happen and that, when they do, you can prove that they did for the purposes of prosecution. That is why I said that you could mandate CCTV in all areas as long as you are also aware of the significant intrusion into people's private lives and have a means of making sure that it is not exploited and misused.

Say my mother was in a nursing home and was subject to surveillance. I would not like it if I thought that lots of people could sit and watch her in a private setting, being subject to a medical examination or having a personal conversation with me. That is the way of thinking about it. That is all.

There is no hierarchy of rights. Sometimes, some people's rights come before those of others. However that depends on need. If a person is vulnerable, they have a need and human rights law requires you to meet that need. Sometimes that means that our rights can be put into second place. That is what we might have been hinting at when we spoke about a case-by-case approach.

Do you want to deal with that, Colin? Did we say that?

Dr Caughey: Yes, in our submission. [Laughter.]

The right to private and family life is a qualified right under the European Convention on Human Rights. Interferences with that are permissible, provided that they are pursuing certain legitimate goals or purposes, one of which is public safety. Interferences with rights can be completely justifiable, provided that they are proportionate to meeting the goal of public safety. Therefore, we discuss the use of CCTV on a case-by-case basis because there are certain scenarios in which different factors would have to be considered. For example, the provision of CCTV might prevent patients from coming forward to receive treatment because they were concerned about it. There would be a question mark over whether CCTV was assisting with public safety if it was dissuading members of the public from coming forward to receive medical treatment, particularly if that concerned intimate care and other such issues.

Mr Chambers: That is a reason to reject or oppose it, but my question is about the circumstances under which the commission would feel that it was justified? What are the factors that would convince the commission to say, "Yes, we should go for it. We will back you with having CCTV in that situation"?

Ms Kilpatrick: We come back to what I started with, which is that there are people who are better placed to decide whether that measure is necessary to protect the people whom you are talking about. It may be necessary in some care settings and not in others: while it may be proportionate in one care setting because of the particular vulnerability or the capacity of the people there, it may not be proportionate in a different setting. Provided that those people have made that assessment, it should be a positive element of protection. As long as there is a legal basis for it, which there would be if it were mandated in the Bill, and there is monitoring and regulation of its use, we would not back it as such, but we would not have a problem with it or challenge it. It is not necessarily for us to back it; when we think that there is a concern, we flag that. Provided that all those things are put in place, I do not see how the commission would have a legitimate concern.

Mr Chambers: I still think that your position on it is ambiguous.

Ms Kilpatrick: You may call it ambiguous, but I say that it is cautious and about seeing both sides. There will be different factors in different situations. It is not for us to say that it is good or bad; it is for us to say that, if the people with the responsibilities decide that it is right, we will look it and ask whether those people have complied with all their other obligations. If they have done so, human rights law will not have a problem with it.

Dr Antova: From an EU law point of view — this will probably not help with the ambiguity argument, given its complexity — European Court of Justice jurisprudence suggests that the operation of CCTV cameras and human rights protections considerations are not incompatible. Lots of people understand the necessity of protecting rights and lives. It is important to balance rights against the legitimacy and importance of the aim in pursuit of the public good that is in question. That is what we mean when we suggest that a blanket approach to the operation of CCTV cameras may not always be the optimum human rights-compliant way of thinking about them. With a case-by-case approach, you would carefully consider the rights in question and the proportionality of the use of cameras, taking into account additional considerations such as data storage.

The Court of Justice has suggested that there must be live interest in having CCTV cameras. There having been issues in the past, for example, may not always be seen as a live enough issue. I am not advocating against CCTV cameras but highlighting the fact that the Court of Justice has ruled that there must be live interest and that, if there are less obtrusive ways of safeguarding rights and people's lives, they must be explored first. As my colleague said, CCTV cameras are obtrusive.

Mr Chambers: That is a big call to make. Who would make it?

Ms Kilpatrick: The people with all the information. We do not claim to have all the information. Clinicians and directors of care settings, for example, would need to engage with the RQIA and the Department — that is why we say that doing the work upfront repays all that effort further down the line — and all get together and decide, "Is this something that we need?". Once they have decided that, they need to decide how they want to use it and how they are going to protect people's other rights. This is not a legal answer, but think of having to go into a care setting yourself with the idea that you might be recorded and that the film could be kept forever and looked at by other people. It is when you put yourself in the shoes of people who are vulnerable or who need protection that you see that they do not abandon all their other rights, so we need to protect their right to privacy for them. The call is made by the people who have all the information and know the patients and the settings that they are in.

Mr Chambers: Would the mechanism that you have just identified — all the people who have all the knowledge — be enshrined in the legislation?

Ms Kilpatrick: I do not think that it needs to be. The oversight should be in the legislation. That is about who you would want to carry out the monitoring and regulation, which is the RQIA, as I think you have said, and it will be subject to the regulations. The regulations will presumably talk about the other laws that already apply to the monitoring of personal data and the use of CCTV. As regards who makes the decision to put it in, that will depend on — again, it goes back to the case-by-case approach: we cannot give you a yes or no answer — the sort of setting that it is and who makes decisions in that setting. Who would decide on any equipment that goes into a care setting? It would not be us; it would be the people who run that care setting and are responsible for the people who are in there. Those people will be from the Department down through all those agencies that provide for those people. All that we do is look at the protections around the interferences and ensure that they are lawful. We would look to somebody else’s decision-making first and approach it after that.

Mr McGrath: I will start with a request, which is that Colin sits over the other side the next time that there is a presentation, because the number of times that you have pointed and said, "Colin is an expert", and I have thought, "What? I do not know anything about that". [Laughter.]

That perked me up a few times during the presentation.

We will end up overemphasising the CCTV element, because it, through the issues at Muckamore, really brought us to why we have the Bill. I have a brief technical question. It was raised with me that CCTV gives you, in a sense, one dimension, which is people's movement. It does not, however, always capture what they are doing, what they are saying and their interactions. Obviously, as with everything, there can be two sides to a story. Now that we have CCTV that can capture sound as well as visual footage, is there any differentiation made between them? Is CCTV with audio viewed as being more intrusive, or is it just viewed as being CCTV whether it has audio or not? Sometimes, you can see something on a screen, but, if you actually hear what is being said at the same time, it gives you a completely different interpretation.

Ms Kilpatrick: The more data that you pick up through CCTV, the more intrusive that it is, necessarily, as a matter of law. You could be hearing somebody exchanging medical information or talking about a personal relationship that has nothing to do with protecting the other person in the room. It is certainly more intrusive. Some detail from the police on how they developed their surveillance in custody cells might be quite useful, because they have addressed an awful lot of the issues, some of them through the Policing Board. You mentioned the Policing Board earlier and some of the work that it is doing with its human rights adviser.

The other important point — you just reminded me about it and it is so important that we remember it — is that it is not just about care settings. This will also apply to somebody visiting someone in their home. When I first looked at the Bill, I was not thinking of a care setting: I was thinking of somebody coming out to my house, which does not have CCTV, and forcing entry because they think that I am in danger. If you get too hung up on CCTV, or think that CCTV will prevent harm, you could get very lax with all the other measures. The CCTV may, in the Muckamore case, have caught the abuse but it did not stop it happening in the first place: it allowed it to be prosecuted, but it did not stop it. We need to remember prevention and think about what rights you give up to protect others. That is a balance — that is not for us — so long as it is within the lawful range. The more that you capture, the longer that you keep it and the more people who can see it, the more intrusive it is.

Miss McAllister: They did not know that the CCTV was on in Muckamore.

Ms Kilpatrick: The fact is that it was there. It is not as though what happened in Muckamore —

Miss McAllister: I know.

Ms Kilpatrick: — would not have happened. That is what I am saying.

Miss McAllister: It is important, though, because it is what the families always say.

Mr McGrath: Years and years ago, I worked in youth services. We had CCTV in our centre, but all that happened was that the kids worked out exactly where it did not cover, and that is where they went if they wanted to do something and not get caught. That is what it can do. It will never cover every square inch of a place. If somebody wants to do harm, they will find the place in which they can do it. It is, therefore, also about the culture and protections in the organisations, and the oversight of those, rather than just CCTV.

Ms Kilpatrick: Sometimes, you can give people false confidence if there is CCTV. I am a lawyer, and I have spent a lot of years in courtrooms. It is easy to argue over what is right in front of your eyes. It is about the context, the wee bit that you do not see on the camera, what was said and not said and what was said before. It does not always provide the answers, even for a prosecution. There is a note of caution about how effective it may be. We are certainly not saying that it is not effective; that is for others to decide. If you decide that it is, just make sure that it is regulated properly.

Mr McGrath: That is very useful. Thank you.

The Deputy Chairperson (Mr Donnelly): Thank you very much for that presentation. There will be a lot more questions and engagement. The Committee Clerk just highlighted to me the fact that PSNI representatives will be coming before the Committee in December, so we will be able to discuss the CCTV element with them then.

Ms Kilpatrick: It is certainly worth asking. I did some work with the Policing Board on body-worn cameras and custody surveillance, and I went and watched. The public protection unit is likely the one to look at. It may be worth asking the PSNI about the guidance that it introduced, if you have not seen that already, because the use of the cameras was subject to a human rights assessment. That may be helpful and short-circuit things a little bit.

The Deputy Chairperson (Mr Donnelly): Thank you.

Mr McGrath: I hope that you are not suggesting that we get arrested to try to find out how the system works. [Laughter.]

Ms Kilpatrick: Do some fieldwork.

Mr McGrath: Go undercover.

Ms Kilpatrick: We are not offering to do that for you.

Mr McGrath: Thank you.

Ms Kilpatrick: Thank you very much.