It's already happened. There has been at least one case where a respondent won the right to have a judicial review of a finding made by the Privacy Commissioner's office. It's already entering the common law realm in that sense.
I have no difficulty with it. I think there are situations, but they're going to be rare ones. There will be situations where organizations feel strongly that their position has not been well represented or there has been some injustice done to them. Keep in mind that these are only recommendations and they're not binding orders.
I was quite surprised that one organization would actually go to the Federal Court to challenge what was not a formal binding order but only recommendations. They did so, and they won the right at the Federal Court to have the application heard.
I think it creates a balancing of interests in the law, and I don't see a huge harm coming from that. It'll be rarely used.