Thanks, Mr. Chair.
Having been an officer in a company who was designated to receive whistle-blower complaints before, I want to point out how difficult this would make it for the person who is receiving the complaints. This would allow, for example, a person to walk up to somebody at a Christmas party and make a complaint and to then have that person declare that the discussion was a valid complaint.
You really need a standard form in writing to be received to know when you're supposed to start investigating or not. If you take out “in a form [reasonably] acceptable to the Commissioner”, you know.... The way to handle it is to look at the form and, if we're not happy with the form, to make suggestions about how the form could be made more simple. It's not to completely remove these words and mean that a verbal discussion with somebody somewhere becomes a complaint.
I would just say from experience that this will not work, and it would make things much more difficult.
Thanks, Mr. Chair.