Thank you very much again for the question.
I'll begin and then perhaps ask Ms. Angus to add in as well.
I believe that over the last couple of meetings we've highlighted a number of other jurisdictions. In fact, I'd like to back up for a second and start by pointing out that it really depends on the specific question that we're asking. If we're asking a question about whether other jurisdictions separate the investigative and adjudicative functions, the answer to that is almost universally yes.
Whether we're looking at the U.K. or Ireland, as we gave examples of last time, or Australia or New Zealand or Singapore, almost all have a system or a mechanism in place to separate the investigative and adjudicative functions—in other words, avoiding a scenario in which you'd create a judge, jury and executioner all in one office.
In Ireland, as we mentioned previously, the privacy regulator is not able to levy penalties directly. You can seek those from a court or a public body. They actually have the highest level of fines levied under the GDPR, the general data protection regulation of the European Union. In New Zealand, costs and damages may be awarded, but they have to go to a human rights tribunal to seek those. Singapore also has a separation. I could go on and on. France also has a two-tier separation system.
It's very common, not just in Canada but also internationally, to have some degree of separation between a body that conducts an investigation and develops findings and a body that makes a final determination about a penalty, for example.