Our testimony over the last several meetings has been very clear, but I'm happy to recap.
We see there being significant efficiency gains by implementing a tribunal. It's absolutely and fundamentally important, in order to maintain alignment with the Constitution, to have procedural fairness and due process built into the system. Doing so via a tribunal is the most efficient and effective way to do so. We've thought very carefully about how to make sure that it does not become an additional layer of review, for example, by ensuring that the tribunal gives deference to the commissioner's findings and decisions and by ensuring that it's a final level of review and not subject to appeal.
There are many ways in which this has been designed carefully to ensure that the important objectives of procedural fairness, efficiency, effectiveness and access to justice are appropriately centred, and to ensure that, in so doing, the role of the Privacy Commissioner remains primary and cannot be subverted by a large corporation that's able to drag out court proceedings and drain the Privacy Commissioner of the resources and time needed to effectively steward consumer and Canadians' privacy through the markets.