It's a possibility, but I wouldn't call it a risk. It's a possibility that the law routinely provides for, incidentally. There are a large number of administrative tribunals that are capable of conducting investigations and providing advice as well as having adjudicative powers. Obviously, these powers must be kept separate within the organization. The same would be true if the Office of the Privacy Commissioner of Canada had these powers without a tribunal. The decision, for example an order made by the Office of the Privacy Commissioner, must be subject to judicial review to ensure that it has been fair to business. Often, this kind of potential conflict is handled smoothly by administrative tribunals.
On October 24th, 2023. See this statement in context.