Well, no, you need the implementation of the 23 recommendations, plus the comprehensive review body.
The International Civil Liberties Monitoring Group, like Amnesty International, proposes something stronger than what O'Connor proposed. We felt they needed a comprehensive oversight review body that could look at any of the agencies that might be involved in joint operations.
As it is right now, these various review bodies are directed at one agency. You have the many new joint operations, the INSETs, the integrated approach, which includes not only federal.... Judge O'Connor found there were 24 federal agencies that are directly or indirectly involved in security and intelligence, but now with these integrated teams they are working with city police forces and provincial police forces as well. So when mistakes are made and you have three review agencies with different powers and they must focus on the one agency, how do they really get the truth out of what was an integrated operation? That's the problem.
At the very minimum, you need what Judge O'Connor proposed with this comprehensive committee that would oversee the general security field and receive the complaints. He points out that the complaints must go to that committee. When something happens to him or her, the citizen doesn't know whether it was done by the RCMP, CSIS, the OPP, or the Canada Border Services Agency. They would give the complaint to this comprehensive oversight body, and that new body, which would be set up with the powers of subpoena and so on, would say it should go to the RCMP and so on.
The other important thing is that this review body must not only have the right to deal with complaints, but it must also have the right to initiate audits when there appears to be a systemic problem within that agency. SIRC has that power, but the CPC does not. When Judge Antonio Lamer, who was the commissioner of the Communications Security Establishment, left his job, he also said he didn't have the powers to do his job. More recently, I think his replacement has said the same in his annual report.
You need a comprehensive, overarching review agency that has the powers to receive complaints and audit to cover the whole field. The reason that Judge O'Connor was so successful in getting to the bottom of the Arar case is that he could look everywhere. He had the full powers of subpoena, and he could deal with things in camera. He got the answers. But none of the existing review bodies have those powers.
O'Connor proposes that we have that structure, with the three agencies plus a committee over it. But that is the minimum. You could even go further if you want a more efficient type of body.