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An overview of registration and reporting requirements for university employees

Federal

• Government and Institutional Relations (GIR) is responsible for ensuring institutional compliance with federal lobbying regulations. Queen’s is required by the Commissioner of Lobbying of Canada to register and report all contacts with federal Designated Public Office Holders.

• To ensure institutional compliance is maintained, all employees or units wishing to engage in lobbying activities must involve Government and Institutional Relations prior to engaging with government officials.

• In general, all communications initiated by Queen’s, which are both oral (meetings/telephone/Zoom calls) and arranged (i.e. scheduled in any manner, including informal) with Designated Public Office Holders must be reported. As well, communications initiated by a government official must be reported if financial benefits are discussed. If in doubt, please report.

• Any portfolio that engages in lobbying activities will be required to designate a staff contact to assist with monthly reporting using the template provided by GIR. The ideal person should have sufficient knowledge of the calendars of the individuals involved, as well as a broad perspective on activities in the portfolio.

• All reports are made on behalf of the Principal, as required under the Lobbying Act.

  • In addition to the GIR staff, a number of senior administration members – including the Principal and Provost – are currently registered to lobby on behalf of Queen’s.

  • Others who regularly conduct lobbying activity may also be registered by GIR.

  • If in doubt, to ensure regulatory compliance, please check with us first or include a member of the GIR team in your government activities.

  • Non-compliance is subject to a number of penalties, including: a prohibition from lobbying, a fine of up to $200,000, and/or up to two years imprisonment.

Elections and official pre-writ periods:

• It is important that Queen’s as an institution avoids any perception of partisanship. This is especially important during/prior to the official start of an election campaign.

• The Election Modernization Act, 2018 created a formal pre-election period, during which third party groups (such as Queen’s) are subject to more stringent rules on advertising, communications, and other political-facing activities.

• While units across the university are always required to report interactions and communications with government to GIR to ensure compliance with our ongoing lobbyist reporting requirements, during the pre-election period, we also ask that you consult with GIR before undertaking any events, communications, or other interactions with federal Members of Parliament, candidates, or public outreach campaigns.

Provincial

GIR is also responsible for ensuring compliance with provincial lobbying regulations. Employees or units wishing to engage with provincial government officials must involve Government and Institutional Relations prior to engaging with government officials.

• The Integrity Commissioner of Ontario enforces the Lobbying Registration Act of 1998 in the province. In-house lobbyists at Ontario universities are not currently required to register or report activities.

  • The Ontario Lobbyist Registration Act is currently undergoing a statutory five-year review. Queen’s will continue to monitor relevant legislation and modify our approach as required, with appropriate communication to all internal stakeholders.

• Under the Broader Public Sector Accountability Act, public sector organizations (such as Queen’s) are prohibited from using public funds to engage an outside lobbyist to provide paid lobby services.

Any employee who communicates with provincial government officials should be registered by Government and Institutional Relations, to ensure regulatory compliance.

Municipal

At present, no registration or reporting of lobbying activities is required in the City of Kingston.

If any lobbying is conducted within another municipality, please consult with Government and Institutional Relations to review any reporting obligations that may exist.

Last updated: July 2021