Former or Current DPOs Employed by or Providing Services to a Lobbyist

Section 12 of the Act provides that if a person is or was a DPO (whether before or after the passing of the Act), and

• is employed by or providing services to a lobbyist, and
• was engaged in lobbying communications during a relevant reporting period,

the person’s name is required to be included in a return of lobbying activities submitted by the lobbyist for that period.  The person’s name will, therefore, appear on the Register as a person who carried out lobbying activities relating to the return.  This requirement does not apply where a person asks an elected representative to communicate on their behalf in their capacity as an elected representative (e.g. to make representations to a Minister or to arrange a meeting with a public body).  In such cases the elected representative is being lobbied and should be included on the return as a DPO who has been lobbied.  If, however, an elected representative is communicating in another capacity e.g. as Chairperson of a representative body or issue-based group which is within scope, then the elected representative would need to be included in a return of lobbying activities as a person who carried out lobbying activities relating to the return.