I will try to be brief.
The goal of these provisions should provide quick and effective remedies for citizens. In no other jurisdiction that I know of is there a tribunal such as that proposed in this legislation. In all other privacy jurisdictions, the original decision-maker, including with the power to make orders and set fines, is the data protection authority that is the equivalent of the Office of the Privacy Commissioner.
I hear concerns about the difficulty for the OPC to work with different roles. That is not a problem in other jurisdictions. It is well known in law that it is possible for an administrative tribunal to have investigative, advisory and adjudicative functions. This needs to be managed and it can be managed. There is no problem there.
I think the tribunal will create delays and will simply be duplicative of the expert work of the Office of the Privacy Commissioner. Again, there is no precedent internationally for this.