My primary perspective on it is that the current ombudsman model is very close to an effective order-making power. At the end of a regulatory investigation, the Privacy Commissioner will discuss with an organization subject to an investigation ways to remediate whatever failings they found. Although it's often framed as a remediation that the organization has agreed to, the OPC certainly has persuasive power there, and much of what they might order, I believe, if they had that explicit power, we are already seeing in these results of investigative findings. I don't see that it's a necessary gap right now.
On April 6th, 2017. See this statement in context.