I would agree, definitely, that that would have to be a change that would go along with giving order-making powers. For example, in Alberta it's very possible to go to Queen's Bench and say that a privacy commission decision was crazy and have it overturned.
If you want to separate the two functions, like you do with the Competition Bureau, with the commissioner saying “This is a bad practice”, and then the competition tribunal deciding if it really is offside, that is a lot of superstructure to add for privacy. It might be necessary on big cases. Maybe we are heading there, but I'm not sure yet.