Thank you for the question. I certainly am prepared to acknowledge that there are multiple perspectives and viewpoints that could be taken on this point. However, I think an informed reading of the proposed bill that's been put before this committee for consideration would make it very clear that there are no impacts on the partnership or joint investigation work.
The role of the tribunal that's been put forward is circumscribed to very limited activities and is really designed to ensure that there is procedural fairness and that there is impartiality in the system, which, as the committee would well understand, is a constitutional guarantee. As Ms. Angus just pointed out, even the Alberta system has a separation between the investigatory and adjudicative functions built into the system. For that reason, it's critical to ensure that as the Privacy Commissioner moves from having an ombuds function towards being an actual regulator with teeth—let's call it for lack of a better term—there is an element of procedural fairness and impartiality built into that system.
Failing that, there is an extremely high likelihood of overturning these decisions based on constitutional grounds or constitutional challenge or based on a lack of impartiality on the part of the OPC. For that reason, actually instituting the tribunal is an important mechanism by which to reinforce and strengthen the OPC's ability. If we imagine a scenario in which there is no tribunal, it's very likely that any finding of the OPC or any action of the OPC, including the levying of an administrative monetary penalty, for example, could be overturned on constitutional grounds, and that would send us back to a situation of having a toothless regulator, which I think is broadly understood to be the state of affairs that we're trying to move away from.