I'm sorry I haven't brought with me ExCom 44, which I would have read in that regard. But I have quoted it before, saying that detention is permissible; that it's possible to include a detention phase at the beginning of the process in order to exactly meet those concerns that you are referring to.
I would have liked to read it because there are safeguards anyway in that detention that would have called for a review mechanism, for instance, which is very important. So, yes, it's as you say, but Bill C-31 doesn't really comprehensively adhere to the safeguards and review mechanism that are contained in ExCom 44 or international standards at large.