Yes.
I would add that we have trouble understanding why there is so much reluctance to adopt an order-making power at the federal level when it seems to be working very well in all three provinces, Quebec included, not just British Columbia and Alberta.
The reason we've pointed to the British Columbia and Alberta models is that they were modeled on PIPEDA three years afterwards. They got the advantage of seeing how the federal legislation was working and improving on it in a way that Quebec didn't, because Quebec was the first one out of the gate.
I have trouble understanding the opposition to order-making powers, because I think it's clearly proven to be a complementary tool in the hands of the provincial privacy commissioners.