It's an interesting question.
My challenge was that I wanted to use a standard that wasn't attributable to one legal system or another. I had the big challenge of not wanting to take a common law standard or a civil law standard. What I researched were the different standards, and then I tried to draw concepts out of them to make a standard that wasn't specific to either system. That's where I got the idea of sufficient information to provide a basis that's reasonable and credible. Those are some of the components of all the standards.
If I were doing it in Canada, knowing the standards that are applicable in Canada, I'd probably use the search warrant standard of reasonable grounds to believe. Certainly, the criminal standard is not appropriate for sanctions, because you're not employing the kinds of measures that you are criminally.
I agree with you; I don't think the JR standard of reasonableness alone is sufficient. I think it's something in between. I think the search warrant standard is probably pretty good.
Also, I like what I came up with, but as I said, that was very much to mix the two legal systems. I think that's very important.
On the protections side, you just have to provide that remedy and the basics. You have to notify them and you have to give them reasons so they know what the case is against them. That's all pretty straightforward to do in the situations you're talking about. Then you have to give them, if they choose to pursue it, a means of accessing some kind of review—ombudsperson, JR, or whatever it may be. That should be up front in the legislation. It gives it credibility.