I think it should be possible. I think the commissioner should have the ability, because there are, no doubt, vexatious litigants out there and there are people who abuse the process. You would want to institute it with the appropriate checks and balances and possible judicial review, because cutting somebody off from redress under the Privacy Act is a pretty significant step given its quasi-constitutional status in Canada.
I've seen a lot of abuses of the statute, and certainly I'm sympathetic to a commissioner having to open a file and go through the whole process for something that really, at the end of the day, they know is going to go nowhere. However, I really hesitate to give anybody a tool that cuts somebody off from effective legal redress.