I'm not an administrative lawyer and I couldn't get into the details, but in most other jurisdictions there is a power to say, for example, “Stop doing that. Stop collecting that information.” That, as we argue, typically provides the incentive to comply at an earlier stage in the process.
The role of penalties in this area of law is a tricky one, because, to a large extent, the penalties that are imposed or the penalties that are perceived by a non-compliant organization are not necessarily financial. As I said before, they are as a result of lack of reputation and bad publicity.
There are plenty of models in Canada and there are plenty of models in B.C. and Alberta—and you will receive information about those pieces of legislation as well—where there are quite precise order-making powers concerning cease-and-desist and other functions like that. Those can assist the entire investigation and ombudsman function.