I have not canvassed my team on this, but in the interests of not delaying, I do not agree that this is an error in need of rectification. This original text and use of the term 'disclosure' in this paragraph, was, I believe, actually quite intentional. As we have discussed, at length, on numerous occasions, publication is a subset of disclosure. Your edit, although technically true, only has the effect of further limiting the guidance to that particular subset of a much broader concept that is being captured here,likely further eroding the utility of the guidance. Specific subsets of disclosure are teased out in the relevant proceeding elements of the guidance (e.g. publication as a disclosure is contemplated in both ss.2 & ss 5).
Leaving this as 'disclosure' does not exclude the concept of publication in the remit of the guidance. The change to 'publication', I fear, would necessitate further discussion and I neither believe this to be necessary nor would I advocate for such change at this stage.
Warmest regards,
Alan
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