There are several ways of considering it. I envision it as a mechanism that would give complainants a means of access, whether they had previously filed a complaint with the commissioner or not. Depending on the response they received, they could follow up by resorting to the tribunal. It would be a bit like appealing the commissioner's decision.
In addition, if the commissioner failed to make the appropriate recommendations, the complainants could then seek more appropriate remedy from such a tribunal.