It could be. I think so. I haven't given much thought to whether it should be outside the Department of Justice. Maybe it should, because the Department of Justice is going to be defending most of these.
Maybe it should be someone who Parliament appoints and is responsible to Parliament. Maybe it's someone who is part of the finance department, since this is money. Maybe it's added onto a bureaucracy that's already there, such as the ombudsman's office or one of the other individuals who already has responsibility for interpreting and applying the law.