To underscore the point about investigations, developing this concept of an investigative body was a good first step in PIPEDA in 2001. But in my mind, it was a bit artificial, and the whole process of investigating and preventing fraud could be streamlined much more if you took the B.C. approach. It would provide for better opportunities to fight the good fight against the bad guy.
On January 30th, 2007. See this statement in context.