I wonder if the contract with the firm is setup so that the information they gather is public, if anyone can find the application in the back of the drawer in the basement if you show up in person and request the form from the admin who is only there 2 hours a week.
For something to be insider trading, one of the people involved has to have breached their fiduciary responsibilities. Low-level employees typically don't have any fiduciary responsibilities to their company, so the firm that collects information from them is under no obligation to make it public.
I'm not a lawyer, but this definition can't possibly be correct, can it? If you're a janitor and you come across a piece of paper or a conversation between bigwigs discussing a merger and sell it to a trader, the trader and the janitor can surely both be sent up the river for insider trading, right?