There are scenarios in which they are in the same body, but expert tribunal models are used in the U.K., Australia, New Zealand and Singapore, so a variety of approaches are undertaken. Again, as we mentioned in the last meeting, there can be constitutional grounds for that. Attempting to just sort of pick out one feature and to do a comparison can be a little bit tricky, because doing that doesn't necessarily take in the full scope of understanding of the constitutional grounds upon which that framework is based. Therefore, we tend to look at it as a whole and to understand how it functions in its totality.
To answer your question in as straightforward a way as I possibly can, it depends on the jurisdiction. Many have a separation between the two bodies. Some have bodies that are unified but have separations or firewalls built into the organizations that separate investigation and adjudication.
At the moment, the Privacy Commissioner does not have that separation built into their functions. Our analysis was that it would be very difficult to establish that inside the body of the Privacy Commissioner as it stands today, in part because of its responsibility for the Privacy Act as well. In other words, the Privacy Commissioner is responsible not just for PIPEDA or in the future for CPPA but also for administering the Privacy Act. There are more challenges associated with covering that and with having this separation built into the Office of the Privacy Commissioner itself.