Thank you for the question. Again, it's an important one.
Alberta and British Columbia, to take two examples, don't have the ability to levy administrative monetary penalties. Quebec, in fact, does, but it has an internal model that operates as a tribunal within the CAI. Those are very important differences in the way the processes function. While there may not be the need for a tribunal in some instances, if the desire of Parliament is to put in place a strong regulator with strong enforcement powers, that's what triggers the need to have procedural fairness and impartiality of process baked into the process. It really comes down to a choice about the policy objective Parliament is trying to achieve. If it's to imbue a strong regulator with enforcement powers—one with the ability to levy administrative and monetary penalties up to $10 million, as contemplated in the bill—it needs to have that concordant procedural fairness aspect to it.
As well, Alberta and British Columbia do not have the ability to enter into compliance agreements, whereas CPPA contemplates a range of tools available to the commissioner to bring cases to ground through mediation, arbitration or negotiation directly with the complainant and the company in question, in order to develop a robust compliance agreement that includes behavioural or process changes as well as penalties—contemplating damages for those who've suffered from the contravention of the act. This is a very powerful set of tools we're putting before the commissioner. Providing that also means providing a clear mechanism for recourse and ensuring impartiality and due process are respected throughout that process.