Damian Hinds
MP for East Hampshire · Conservative · United Kingdom
“There are moments in debates like the one we have had today that are difficult to sit through and listen to, but it is the most immense privilege to be a Member of Parliament and to hear some of these testimonies.”
“Today is once again a day of heavy responsibility for all of us to decide on what we in this House call “conscience issues”. Many of the people who we represent hold strong and immutable views, and we hear from them. However, we represent many others who hold much more nuanced views and we are less likely to hear from them.”
“Members who support the Bill should not have their motives questioned, Members who oppose the Bill should not have their motives questioned, and Members who have reached a different conclusion from one they reached at an earlier stage should not have their judgment questioned either.”
“We have heard from royal colleges and other professional bodies, many of whom have a neutral stance on the principle but raise significant questions about particular aspects. We know from Ministers that there would need to be some reprioritisation of NHS resources, but we do not know the extent.”
“If there is the prospect of the Parliament Acts being used, that would increase the importance and the salience of the text as it is now. Today, it is reasonable and entirely in order for hon. Members to consider information that is available now that was not available in those previous parliamentary deliberation.”
“The Government have said, rightly, that the time taken to implement other schemes is not directly comparable, because none are as in this Bill. This is a free vote on a matter of conscience—there is no party line on either side of the Chamber. No one, I suggest, finds this issue easy.”
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“We have not just seen that growth in this country. Fraud and economic crime have been growing in countries throughout the world. There is a change in crime, and we need to respond accordingly. I welcome the change in the Bill, because it brings consistency and fairness and will enhance confidence for people using online financial services. One should never take away all responsibility from the consumer, of course, but that is a welcome move. Very briefly, there are two things I would like the Government to look at, one for the Treasury specifically and one for the wider Government. First, for the Treasury, it is not clear to me why this provision applies just to the faster payment system. It is true that the vast majority of scams happen through faster payments, but they may not in future.”
“I do welcome the measures, but while the 3% per month interest cap is very reasonable, in some parts of financial services it is difficult to break even on that cap. Ironically, the demise of the market leader of the home credit business sector makes it more urgent for us to ensure there is very good provision from credit unions and other responsible lenders in its wake. The other issue I want to comment on briefly is the provisions on authorised push payment scams and mandatory reimbursement. This gives me the opportunity to join others in the nice things they have been saying about my hon. Friend the Member for Salisbury (John Glen), the former Economic Secretary to the Treasury. I had the opportunity to work with him when I was Security Minister and he was bearing down on the awful growth in fraud.”
“We have a great example in Northern Ireland—and indeed in the Republic of Ireland—of what a much more developed credit union sector can look like, and I would like to see that in mainland Britain. The proposals in the Bill will continue that development, amending the Credit Unions Act 1979 to allow for conditional sale and hire purchasing agreements to be undertaken by credit unions, along with the marketing of insurance services. I would only encourage the Government to go further, because our credit union sector is still small in Great Britain compared to Northern Ireland and there is much more that can be done. There is also more that can be done on CDFIs, whose growth, frankly, has been disappointing. I encourage keeping an open mind on the regulatory aspects of the Bill.”
“Wise heads always remind us that in seeking to curb the parts of the high-cost lending market that we do not like, there is always a danger that we instead push some part of that customer base into the arms of a high-cost lender whose idea of a late payment penalty is a cigarette burn to the forearm, so we must get the balance right. Regulation has been a success, but ultimately what we need is an alternative, because credit does form a part of people’s lives, and that is where credit unions and others, such as community development financial institutions, come into play. We have seen development in the sector, but I would like to see a lot more.”
“The hon. Lady makes an important point. It would be wrong—I am sure she did not mean to say it, even though it is what she just said—to say there was a single cause for those things. In fact, it is about changing the entire framework. In other parts of the market, for example home credit, there is a different set of reasons again why there has been a decline. We know the sub-prime segment shapeshifts the whole time, and we have also seen the recent growth of buy now, pay later. At a time of heightened financial stress, it is inevitable that new risks and new vulnerabilities manifest.”
“I very much welcome Sir Robert’s comprehensive work, including the recommendation on expedited payments. I have corresponded with the Minister on this on behalf of my constituents, and I am grateful to him for his reply and for expressing his understanding of the time sensitivity. I join others in urging him to look not only carefully but urgently at the case for expedited payments to people who will receive moneys through the compensation scheme anyway, given the passage of time and given how much these people have suffered through no fault of their own. They have been let down by the system.”
“The Bill makes sure their incentives are aligned because they have to take proportionate steps to stop fraudulent content appearing in front of customers, but we need to look at how we can sharpen that up to make sure everybody’s incentives are absolutely as one. This is an incredibly important Bill. It has been a long time coming and I congratulate everybody, starting with my right hon. and learned Friend the Member for Kenilworth and Southam (Sir Jeremy Wright), my hon. Friend the Member for Croydon South (Chris Philp) and others who have been closely involved in creating it. I wish my hon. Friend the Minister the best of luck.”
“I hope that in DCMS my hon. Friends will look to create a future threats unit that seeks to do that. Thirdly, we need to make sure everybody’s incentives are aligned on fraud. At present, the banks reimburse people who are defrauded and I hope that rate of reimbursement will shortly be increasing. They are not the only ones involved in the chain that leads to people being defrauded and often they are not the primary part of that chain. It is only right and fair, as well as economically efficient, to make sure the other parts of the chain that are involved share in that responsibility.”
“First, there is a lot of fraudulent content beyond categories 1 and 2A as defined in the Online Safety Bill, so we are going to have to find ways—proportionate ways—to make sure that that fraudulent content is suppressed when it appears elsewhere, but without putting great burdens on the operators of all manner of community websites, village newsletters and so on. That is where the DCMS online advertising programme has an incredibly important part to play. The second thing is about the huge variety of channels and products. Telecommunications are obviously important, alongside online content, but even within online, as the so-called metaverse develops further, with the internet of things and the massive potential for defrauding people through deep fakes and so on, we need to be one step ahead of these technologies.”
“The second was to bring fraudulent advertising into scope, which is particularly important for categories of fraud such as investment fraud and e-commerce. The third big change was to make fraud a priority offence in the Bill, meaning that it is the responsibility of the platforms not just to remove that content when they are made aware of it, but to make strenuous efforts to try to stop it appearing in front of their users in the first place. Those are three big changes that I greatly welcome. There are three further things I think the Government will need to do on fraud.”
“So they create these fake personas to plant ideas and then other people, seeing those messages and personas, unwittingly pick them up and pass them on themselves. It is incredibly important that we tackle that for the health of our democracy and our society. The other point I want to mention briefly relates to fraud and the SNP amendments in the following group, but also Government new clause 14 in this group. I strongly support what the Government have done, during the shaping of the Bill, on fraud; there have been three key changes on fraud. The first was to bring user-generated content fraud into the scope of the Bill. That is very important for a particularly wicked form of fraud known as romance fraud.”
“Sometimes the aim is to big up their own country, or to undermine faith in a democracy like ours, or the effectiveness of free societies. Probably the biggest category of information operations is when there is not a particular line to push at all, but rather the disinformer is seeking to sow division or deepen division in our society, often by telling people things that they already believe, but more loudly and more aggressively to try to make them dislike some other group in society more. The purpose, ultimately, is to destabilise a free and open society such as ours and that has a cancerous effect. We talk sometimes of disinformation being spread by foreign states. Actually, it is not spread by foreign states; it is seeded by foreign states and then spread usually by people here.”
“Although our focus on interference with the democratic process is naturally heightened coming up to big democratic events, it is actually a 365-day-a-year activity. There are multiple reasons and multiple modes for foreign states to engage in that activity. In fact, in many ways, the word “disinformation” is a bit unsatisfactory because a much wider set of things comes under the heading of information operations. That can range from simple untruths to trying to sow many different versions of an event, particularly a foreign policy or wartime event, to confuse the audience, who are left thinking, “Oh well, whatever story I’m being told by the BBC, my newspaper, or whatever it is, they are all much of a muchness.” Those states are competing for truth, even though in reality, of course, there is one truth.”
“Disinformation is a core part of state threat activity and it is one of the most disturbing, because it can be done at huge volume and at very low cost, and it can be quite hard to detect. When someone has learned how to change the way people think, that makes that part of their weaponry look incredibly valuable to them. We often talk about this in the context of elections. I think we are actually pretty good—when I say “we”, I mean our country, some other countries and even the platforms themselves—at addressing disinformation in the context of the elections themselves: the process of voting, eligibility to vote and so on. However, first, that is often not the purpose of disinformation at election time and, secondly, most disinformation occurs outside election times.”
“Friend said about algorithmic promotion, because if we address that, alongside what the Government have rightly done on ID verification options and user empowerment, we would address some of the core wiring and underpinnings at an even more elemental level of online harm. I want to talk about two subjects briefly. One is fraud, and the other is disinformation. Opposition amendment 20 refers to disinformation, but that amendment is not necessary because of the amendments that the Government are bringing to the National Security Bill to address state-sponsored disinformation. I refer the House in particular to Government amendment 9 to that Bill. That in turn amends this Bill—it is the link, or so-called bridge, between the two.”
“May I join others in welcoming my hon. Friend the Member for Folkestone and Hythe (Damian Collins) to his place on the Front Bench? He brings a considerable amount of expertise. I also, although it is a shame he is not here to hear me say nice things about him, pay tribute, as others have, to my hon. Friend the Member for Croydon South (Chris Philp). I had the opportunity to work with him, his wonderful team of officials and wonderful officials at the Home Office on some aspects of this Bill, and it was a great pleasure to do so. As we saw again today, his passion for this subject is matched only by his grasp of its fine detail. I particularly echo what my hon.”
“Q Mr Hall, thank you for being with us this morning. Coming back to STPIMs, you spoke with the shadow Minister a little bit about effectiveness but I want to ask for your thoughts about necessity. From your experience with the counter-terrorism regime, how do these sorts of devices get deployed and why? On transparency, I know there are sometimes concerns that these things may be used in large numbers. Will you say a word about how many TPIMs have typically been in operation at any one time? Jonathan Hall: I cannot remember the total number of TPIMs. I think it is around 30, but I may be misremembering and that may also include—”
“That is over a number of years, of course. Jonathan Hall: Yes. The maximum I remember in any year is up to six; at the moment it is down to about two. The authorities ran quite a successful campaign, using TPIMs against members or former members of al-Muhajiroun. Those have tended to drop off, and we are now looking at a very small clutch—I think it is only two now.”
“One of the key measures for the really serious people is moving them from their home location. They find it much harder to operate if they are outside their home location: they do not have the people around that they know, and they find it a more hostile operating environment. There will also be some people whose threat really comes from the propagation of terrorist propaganda, so the measure might be directed towards their use of electronic devices and the internet.”
“Q In terms of their usefulness in the suite of what is available in order to counter these threats in the terrorism field, which obviously is your primary area of expertise, can you say why one might elect to use a TPIM? Jonathan Hall: First of all, where there is good intelligence that an individual is up to no good but it is impossible to prosecute them. There may be secret sources of intelligence—information coming from allies or from electronic means that could not be disclosed—that mean that the agencies know perfectly well that someone is a real risk. Having had the opportunity to read the intelligence, I know that there certainly are cases where people are very dangerous and are engaging in attack planning but could not be prosecuted. These measures allow a huge amount of control.”
“I have certainly seen cases in which it has been debatable whether the measures have been too strong, particularly in relation to electronic devices, and whether enough attention is being given to allowing people to live a useful life without presenting a threat to the wider public.”
“Q Given that there is obviously a lower burden of proof—there is no court case—and given the numbers of TPIMs that we have spoken about, are you satisfied that the proportionality is satisfactory? Jonathan Hall: Up to a point. I have expressed my disappointment that because legal aid is not now available as of right for all TPIM subjects, there is a cohort of TPIM subjects who are not getting court reviews. In the absence of the court having the opportunity to test the proportionality, it is particularly important that the Home Office official who chairs the TPIM review group’s meetings is really testing, and I also feel that I have to play that sort of role myself.”
“I will add one thought: I put “crime” in my acronym deliberately. If you take the activities of something like the North Korean Lazarus group, which was responsible for the WannaCry ransomware attack on our national health service, it is operating in order to obtain foreign exchange to pay for the North Korean nuclear programme and North Korean intelligence activity. In March, the group took more than $0.5 billion-worth of Ethereum currency from an exchange. This is large-scale larceny on behalf of a state. My hope is that the powers in the Bill will help the police and agencies to deal with state-based criminal activity. I know that there are aggravated offences powers as well, which will help the police.”
“Q Sir David, you have a long sweep of history to look back at, with GCHQ and your role as the first security and intelligence co-ordinator, and now in academia. Sir Alex was speaking earlier about some of the long-term trends and the blurring of boundaries. I think you used the phrase “the digital revolution”. I wondered if you might say a word about what you think are the biggest growing or evolving threats right now. Professor Sir David Omand : From my experience, I would point to the consequences of the digitisation of every conceivable kind of information. That is proceeding apace. We have digital cities. Our infrastructure is now wholly dependent on IT. In my recent book, I coined an acronym, CESSPIT—crime, espionage, sabotage and subversion perverting internet technology—and that perversion is going on as we speak.”
“I had a long chat with the Government about this, and the thing that convinced me that this was an appropriate response was, first, the foreign powers condition—to be clear, that is about people acting on behalf of a foreign power—and, secondly, essentially the use of deception to achieve your aim. It seems to me that if someone is working on behalf of a foreign power, using deception, to distort our political process, we have a pretty clear basis for taking action. That, I think, is as it should be.”
“This is the world we are in, these are the harms we face and I think that this Bill is a good start in helping the agencies to address some of those harms. Sir Alex Younger: On this issue, you are right to focus on the possibility of interference in our democratic process and the potential unintended consequences of what we are talking about here. Of course, one person’s interference is another person’s legitimate intervention. Perish the thought that it should be the Government’s responsibility to say what is true and what is not. That is the difference between us and our opponents. I can understand the scale of the problem; I have seen it.”
“Q How do you see information operations working? How might foreign states seek to interfere in our democratic processes and public life? Professor Sir David Omand : If you recall the statement made almost exactly two years ago in the House by Dominic Raab, he said that the Government had concluded that it was “almost certain” that “Russian actors” had “sought to interfere” in our election in 2019; and we had the evidence from the American elections and the French presidential election in 2017. All the techniques were deployed. I do not know whether any members of the Committee have been watching the TV series showing on Channel 4, which is as good a primer as any on how such techniques can be used to pervert our political discourse as well as actually harm individuals.”
“Professor Sir David Omand : I recommend the use of the OECD’s triplet of “misinformation”, which is wrong, but innocently so, and should be corrected; “disinformation”, which is deliberately and maliciously wrong; and “malinformation”, which is information that is true but was never intended to enter the public domain, such as the personal emails of Members of Parliament. Sir Alex Younger: Please hold that thought, because I spent years trying to work out whose side Vladimir Putin was on, as he was propagating all sorts of contradictory causes, and then I just realised that he wants an argument—he wants distrust and discord. I have not been to the OECD on the subject, but I entirely support that.”
“Q I realise that we have a tiny amount of time left. It is the curse of these things that we have to finish exactly on time, because we are just getting into this very interesting and important topic. You mentioned the US elections in 2016. Do you think the word “disinformation” really covers what we are talking about? Sometimes, the most invidious and harmful activity is not necessarily saying something that is untrue; it is just winding people up to hate other people more than they did before, and to distrust the system, society and democracy more than they did before. I do not mean to lead the witness, Sir David.”
“What we know about scale is that many more countries than those we talk about are doing it. I understand that in the last Indian election, accounts attributable to every single mainstream political party were taken down by Facebook during that campaign. It has emerged as an almost mainstream campaigning tactic.”
“Q Mr Miller, to come back to information ops, what do we know about scale of state-enacted or state-sponsored information operations specifically? Carl Miller: One suggestion that I was going to make today was that we have nothing like a comprehensive picture. This is often extremely sporadic project-based research, and it is usually platform-specific, even though we know that, in all likelihood, that is not how the campaigns work—they will work across tonnes of platforms all at once. We will see only certain kinds of campaigns. We are broadly better at seeing broad-based campaigns addressing quite large slices of a population, but again, if we were to put ourselves in the mind of an influence operator, there would be much more targeted campaigns directed towards—if you will—higher-value targets as well.”
“Q Sorry, but are you talking about domestic actors—domestic political parties in their engagement in domestic politics—rather than foreign state involvement? Carl Miller: Yes. One of the reasons that I am hesitating is that, for researchers like me, clear and guaranteed attribution—outside the platforms—is unbelievably difficult, and I do not want to overstate. I can tell you that there are dozens upon dozens upon dozens of incidences, scenarios and narratives that we regard—reading the tea leaves of machine-learning patterns as we do—as suspicious. With the open data that is available to me, I cannot definitively link that back to a state. However, Twitter and Facebook, for example, have both disclosed dozens of campaigns that were—at least in part—likely targeting the UK, and linked them back to what they believe to be state actors.”
“With the companies that I mention—the ones selling large amounts of digital manipulation—I cannot believe that they do any kind of “know your customer” activity. I do not think that they have any idea who is employing them.”
“I will also point out one reality about how these work. One of the difficulties in seeing how the Bill—I am sorry if I have misunderstood this—might apply is its requirement that the actors involved have to be conscious that they are working on behalf of a foreign power. Quite often, my suspicion is that you would have a state agency with various kinds of links with online actors, and there might be a whole chain, from a PR company to another more specialist digital consultant to a much spammier consultant, and that person might be the person reaching in and actually gathering together various kinds of functionalities, capabilities or services to do overtly illegitimate and malign forms of manipulation online. It might be very difficult; they might never know that a state is at the other end of the trail.”
“Q When we talk specifically about foreign-interference information operations in countries such as the UK, we tend to focus on elections times, big democratic events, referendums and so on, but is there any reason to believe that something of a moderately comparable scale does not go on the rest of the time? Carl Miller: No, there is not. In fact, I am sure it does, and that is one of the big trends we are seeing. We ran an effort over COP26, and we saw that there were certainly various kinds of organised attempts to manipulate big global thematic conversations about climate action, for instance. Given the barriers of entry into this world, I also do not think that it will be national elections; it might be quite small and local events that see some level of manipulation happening, too.”
“One of the truisms is that it is a bit of a scattergun approach at the moment, where lots of things have been tried and they are attempting to evaluate them, and they do not really know which ones are succeeding and which are not. I am not quite sure if that is true or not. The actual nitty-gritty of the techniques and technologies involved is probably the shadowiest part of this whole area. If the Bill were to be effective, something we need in parallel to it would be almost a digital influence version of the national risk register, where we have state support to pull apart and lay out where we think the genuine threats are and the genuine bodies of capability and technology that have been built to do this kind of stuff. It is very difficult for researchers in the open to do this by ourselves.”
“Q You talked earlier about what we might call the falsehood versus division distinction, and we had a good conversation about this with a previous panel of witnesses. This question is for you both: will you say something about how the use of those techniques varies between states, and what trends we are seeing? Carl Miller: I cannot create a profile for how each state would approach information operations, to be honest. I do think that there is quite a high degree of heterogeneity among the actors involved. You have all kinds of different intelligence agencies, and military-based and political PR comms-based actors.”
“Some of the stuff that you saw around “Wolf Warrior” or that the Global Times —its state international newspaper—puts out is very ineffective. What China is incredibly effective at is not really that disinformation or misinformation public communications picture, but identifying individuals of influence within academia, business or wherever, and building up close relations with them. They are invariably people of influence, who in turn use their own networks to say, “Well, look, I’d be careful of all this talk about China. They are the biggest-growing economy on Earth, we really need to trade with them and we shouldn’t do anything to upset them at any point.” In so far as I have seen, that is where the Chinese influence picture has been focused.”
“Q Mr Armstrong, with your China speciality, can you say anything about how that country’s approach to information ops has changed or is changing? Sam Armstrong: Yes. China initially began—there is some really interesting stuff that has only happened in the UK in this space. We had a university that for a very long time rather openly advertised itself as providing services and specialist media training to officers of the Chinese propaganda Ministry, among others—various branches of the Chinese state—right here in London, metres away from the BBC. You also have the Confucius centre picture, which is important. Where China has actually done very poorly is in its direct Government-to-Government disinformation.”
“Q You mentioned a moment ago that we know of no examples of successful interference in elections. Can you unpack what you mean by “successful”? Do you mean changing the outcome? Louise Edwards: The intelligence community have not notified us of any successful attempts to interfere in UK elections. As I mentioned, the Electoral Commission is not a national security body—we do not have intelligence functions—so when it comes those matters, we receive the information rather than creating it or analysing exactly what it means.”
“Q I realise that this is not your end of the business, but I do not think anybody would claim that there has been no small “s” successful interference in the democratic process in the sense of—I do not know if you heard our earlier session—winding people up, making them think they have less in common than they really do with others in society, and all those sorts of things. I do not want to put words in your mouth, but I think what you mean is actually changing the outcome of an electoral process. Is that right? Louise Edwards: That is my understanding of what the intelligence community mean when they tell us that, yes.”
“They are a little bit of text that goes on a message online and says, “This was produced by this person, on behalf of this person, paid for by this person,” so you can see that it is a political advertisement. It is that level of detail and transparency that now needs to be applied.”
“There is also another side to it: how do you define regulated political campaigning and the spending that has to be reported? Back in 2018, we did some work with voters looking at what they thought about online campaigning specifically. One thing we found was that quite often voters did not realise that something they saw online was actually trying to influence their vote, because it was not immediately obvious on the face of the piece of literature that that was what was happening. In terms of how things might change or develop in the future, there was a bit of thinking done about this in the Elections Act 2022, which introduced what we call “digital imprints”.”
“When it comes to elections, as I am sure you know, there is a period in the run-up to elections called the regulated period. Any spending on campaigning that happens during that period—obviously, it gets more intense the closer you get to polling day—also has to be reported to us and gets published so that people can see it. However, you are right that that is only one side of the nature of influencing or of the wider concept of political campaigning in the UK. There are some really interesting questions there around whether it is sustainable to look only at detailed spending in the run-up to an election, when you might well argue that political campaigning these days is year-round rather than in the run-up to particular polls.”
“How do our institutions and our legislative approach need to change to keep up? Louise Edwards: That is a very interesting question—how long do I have? The political finance side of the regime—I will unpack what I mean by that in a moment—is very much focused on the concept of regular and routine transparency that is enhanced significantly around an electoral event—an election, essentially. When we talk about the political finance regime, we are talking about a defined set of actors: registered political parties, third-party campaigners, candidates or other members of political parties, and those who have specific responsibilities under law, including regular donation-reporting obligations. For example, political parties have to tell us about their substantial donations on a quarterly basis, and we then publish all that information.”
“Q I have questions about a couple of things that you have been talking about. I suppose that money coming into the political system depends on our definition of “political system”. A lot of the activity we are talking about probably involves a lot of money in one way or another, but it never actually penetrates the boundaries of what we call our political system. We talk in other contexts about regulating political advertising—meaning adverts placed by political parties that are registered under the Political Parties, Elections and Referendums Act 2000—but in reality, political parties’ advertising is a very small fraction of the total online influencing that goes on in the run-up to elections. What is your expert assessment of how the whole political arena is changing?”
“Q To be clear, to which actors does the digital imprint requirement apply? Louise Edwards: It applies to anybody who is putting out regulated political material, so it would be political parties, third-party campaigners and candidates. The regime is fairly comprehensive, although not entirely comprehensive. I realise I am going slightly outside the scope of this Bill, but there is opportunity to make it more comprehensive and to really make it clear to voters every time they see a little bit of campaign material online who is paying for it. So it is those established actors who are—”
“It is because of the potential—never mind 5G and so on, but rather in things like smart cities—for data to be siphoned off covertly and so forth. It is possible. There are stats to show, if you had compromised the International Atomic Energy Agency in Vienna and you went in there, how much you could photocopy versus how much you could steal electronically. There is now the possibility and, in some cases, the practice of comprehensive strategic compromise of huge, important datasets and sensitive strategic knowledge across all sorts of sectors by a combination of mostly digital but sometimes human-enhanced means. Until now, as you say, Mr Hinds, we have not really had a legislative framework for it. This Bill does provide a no doubt improvable such foundation.”
“Q Professor Martin, one of the core aims of this legislation is to bring our counter-espionage capability up to date with the modern world. You spoke a little earlier about data theft in the context of the US Government and police. Will you briefly say something about how technology has changed states’ espionage capabilities and how we need to respond? Professor Ciaran Martin: Why is so-called data sovereignty such an issue? There are all sorts of reasons in economics, but one of them is that the location of the storage of data is really important. Data centres are massive strategic assets and a vulnerability for any sort of country, and you can see that combined effort. Why did we have such a big debate about the role of Chinese technology in UK infrastructure?”
“Of course, clients want to be open with their lawyers when they are seeking advice, and we think this scheme would inhibit that openness. Of course, very often, the reason why they want to be open with their lawyers is that they want to know how to comply with the law, rather than breach it. That is why an exemption is needed in any such scheme.”