I think it's difficult to speak to the circumstances of the federal Privacy Commissioner.
In terms of our own experience, it would not be practical, because we have limited resources. Splitting the office would, I think, result in us being unable to fully effect our mandate under ATIPPA.
The model we have, whereby we make a recommendation that can become an order if it's not appealed to the court within 10 days, is very effective. It places the burden on the public body. It also allows us to participate in the court hearing, which is invaluable, because we get to give our own objective perspective in court. Sometimes in the case of a person who doesn't have the resources to have their own counsel, that is really the only substantive quality argument the court hears, other than the arguments that are filed on behalf of the public body.