I just want to highlight the problem with a complaint-driven process in an environment when it's largely a black box to most individual users...about the availability of a complaint process as well as what the proper guidelines are. The concern, I would argue, from an individual's perspective, knowing that there's an ongoing record, is the prospect of being red flagged as someone who has launched a complaint. The risk inherent in sticking yourself out and saying you're going to launch a complaint is that even if it's well-founded, what are the repercussions longer term?
There's a reason in access to information requests. We ensure that there's anonymity for the requester so that there isn't that ability to identify. Any system where there is oversight that is at least in some way reliant upon complaints—and we've already heard about why a complaint-driven process raises some challenges—has to ensure that there is anonymity for the person launching the complaint because without that, I suspect most people will say the risk of repercussions longer term outweighs any benefits they might get from filing the complaint in the first place.