First of all, yes, that is exactly my position. Second, I would note that although there are a few places that don't have order-making power, particularly where some of the older laws were adopted in Europe and Canada, in most of the more modern jurisdictions, access to information has moved to an order-making model, including Britain, Australia, India, Mexico, and Indonesia. Most countries have order-making powers.
This has nothing to do with lines of reporting of this body. There is absolutely no reason that an Information Commissioner with order-making powers would not continue to report to this committee precisely in the same way as happens now. That is what happens in India, in England, and in Australia. The bodies are still accountable to Parliament in precisely the same way.
As to the concern that binding powers would elongate the decision-making process, we believe this to be unfounded. We believe, as Mr. Drapeau has pointed out, that the process has already become far too lengthy and bureaucratic, even though there are no order-making powers in the system. We also believe that it's perfectly possible to apply much stricter, much more concise time limits. It's partly a question of resources, but it's far more a question of how the appeals are processed and how the rules on processing appeals are applied. In a non-binding model, the Information Commissioner has very little control over these matters. But with a binding model, the Information Commissioner would actually have a lot more power to speed up the processing of appeals by reducing unnecessary procedural elements. It is not a judicial appeal. That is not the model that operates in Britain, Australia, or India, or those other countries. The whole idea is that it should be prompt and rapid. It is not serving that role. But a binding order-power could be done in a way that would reduce the timeline significantly. We see examples of that in different countries.