Minister of State Sean Sherlock has recently published “A Copyright and Innovation White Paper” its a big read at 182 pages and I have only skimmed it. At the same time he then tweeted:

 The IIA in turn posted a statement on their website which outlined my key concerns with using an  “Industry body” to collate feedback for an issue that will have widespread societal impact. Specifically:

This will allow the IIA to collate the views of its members and enable us to comprehensively represent their concerns and ideas to Government and input into this important legislation. 

So its first priority is to collate the views of its members, which is right and proper. The IIA is a society of its members that as far as I know does not purport to represent the views of those segments of the industry who are not members.

The IIA then goes on to say:

Non-members are welcome to submit their comments using this survey tool. However, comments by non-members will be passed un-collated and un-filtered to the department as it would not be in the best interests of our members to use IIA resources in working for non-members.  I believe this methodology strikes the right balance of being inclusive and facilitative whilst prioritising our member’s needs as we are charged to do. Allowing the widest stakeholder feedback is quite simply in the spirit of the community.  Stakeholders are not limited to using this tool but it is open to everyone.

They are upfront about this, the IIA is about its members.

So where is the forum for feedback for non-members of the IIA? I don’t want my feedback refracted through a third party organisation. Nor do I want to be treated as a second class citizen because I have no business being a member of the IIA. Stakeholders are not limited to this tool, but where are the other tools?

What priority is the minister likely to place on IIA feedback vs feedback from other sources? No one can tell at this point. But we can infer from his behaviour on the SOPA Ireland issue that feedback and decisions how to proceed are likely to be made behind closed doors.

Can I suggest that a more open forum for Feedback would be for the minister to set up a Facebook page to which anyone can post public commentary, an email address to which private commentary can be posted and his own survey (again trivial to setup on a site like PollDaddy).

All this feedback should be published “in the raw” including back-channel input from various industry bodies who use “other channels” to reach the minister. Lets shed a little sunlight on the process.

I would be happy to do this work for no charge in order to facilitate an open feedback process.