Evidence of meeting #78 for Canadian Heritage in the 42nd Parliament, 1st Session. (The original version is on Parliament’s site, as are the minutes.) The winning word was crime.

A recording is available from Parliament.

On the agenda

MPs speaking

Also speaking

Reuven Bulka  Congregation Machzikei Hadas, As an Individual
Michael Mostyn  Chief Executive Officer, National Office, B'nai Brith Canada
David Matas  Senior Legal Counsel, National Office, B'nai Brith Canada
Shimon Fogel  Chief Executive Officer, Centre for Israel and Jewish Affairs
Tamara Thomas  Policy Researcher and Analyst, African Canadian Legal Clinic
Sikander Hashmi  Spokesperson, Canadian Council of Imams

3:35 p.m.

Liberal

The Chair Liberal Hedy Fry

Good afternoon, everyone. I call the meeting to order.

Pursuant to Standing Order 108(2), this committee is undertaking a study of systemic racism and religious discrimination in Canada. We start with the four presenters. Each group gets 10 minutes to present. There are three groups in our first hour. When you finish with your presentation, you will be asked questions by the members. I will give you a two-minute signal when you are at eight minutes, so that you know you're going to have to wrap up, because I will cut you off at 10 minutes. I'm sorry.

Welcome, Reuven Bulka. Welcome, B'nai Brith Canada, with Michael Mostyn and David Matas. Welcome to the Centre for Israel and Jewish Affairs and Shimon Fogel, chief executive officer.

We will begin with Reuven Bulka for 10 minutes, please.

3:35 p.m.

Rabbi Reuven Bulka Congregation Machzikei Hadas, As an Individual

Thank you very much.

Unaccustomed as I am to speaking for less than 10 minutes, I'll do my best.

It's good to be here with all of you. I'm actually not representing any organization. I'm really not representing myself, either, just sharing with you the experiences I've had over the years. I'm delighted to be here at a table that really, without exaggerating, is almost like a hall of fame of human rights and activism in the spheres of making Canada into a more inclusive and better country.

Let me begin with the obvious, which is to thank you, Madam Chair, and the committee for these efforts that you're doing. We applaud them, and I will share with you—probably going into this from left field rather than going straight—a unique experience that I had somewhere around 12 years ago.

At that point in time, one of the major issues confronting the school system here in Ottawa was the question of school bullying. It came back again a bit later on, but this is an ongoing situation. To a certain extent, bullying in schools is almost like a microcosm of the bigger issue, which is taking advantage of the vulnerable, and the reality of exclusion as opposed to the embrace of inclusion.

At that point in time, we founded something called Kindness Week in Ottawa, which was going at this not from the approach of, let's say, attacking the bad stuff, but rather trying to promote the good stuff. Instead of this idea of saying you shouldn't bully, which we know is true, we wanted to go at it from a positive approach and to emphasize the things we should be doing and promoting.

This actually caught on. It's still going on now. We're coming up to the 13th year of Kindness Week in Ottawa.

A number of years ago, because of the fact that this program worked so well, we started an organization called Kind Canada Généreux, which is emphasizing on a national level the things we need to do to make Canada into a kinder place.

One of the things we're doing right now is working on a school curriculum going from kindergarten to grade 12 in all English, French, and first nation schools. It will still be a year or two or three before we'll be able to implement it, but the idea behind it is to create a climate of kindness, consideration, and embrace.

I have a bit of a problem with the word “tolerance”. I'm not sure that you've been using this word, but over the course of time, the word “tolerance” keeps on coming up. They want us to be a tolerant country. I know, and I think everybody would agree, that one of the worst things is to have a country that is intolerant, but right next to intolerance is a country that is tolerant, because tolerance is actually not much before intolerance. It's a demeaning and condescending word.

I'm much more in favour of the positive, the harmonious, the respect, the embrace, and the inclusion, not avoiding the negative—which then becomes a negative in itself— but rather to say we have to build a culture in which we appreciate everyone with their differences. The kindness approach that we're advocating in the curriculum is emphasizing the positive and giving people something to grasp on to in terms of the way they should be interacting with others.

We're all here today because we recognize the importance of this idea and we realize that there is a bully pulpit. I've used the pulpit all the time, but not as a bully; it wouldn't be kind to be a bully. However, there is a bully pulpit in terms of encouraging in all spheres all across Canada the idea of inclusivity, the idea of the harmony that comes from the embrace of everyone, and the idea of things like encouraging schools to have this type of a program and encouraging workplaces to have programs that really emphasize and build on the idea that we are who we are because everyone is able to be part of this great country. This is the idea that we're approaching at Kind Canada, and this is the idea that I would strongly suggest.

My colleagues will do a lot better than I could in terms of the legislation and the nitty-gritty of it. I am coming at it from another angle in terms of what we can do on a positive level to eliminate these problems—not by attacking them per se, but by emphasizing the greatness inherent in all of us to make Canada an even better country.

Whatever minutes I have left, I gladly cede to my colleagues.

Thank you.

3:35 p.m.

Liberal

The Chair Liberal Hedy Fry

Thank you very much. You have about four minutes left.

3:35 p.m.

Congregation Machzikei Hadas, As an Individual

3:35 p.m.

Liberal

The Chair Liberal Hedy Fry

Mr. Bulka, I want to say that I'm glad you brought up the term “tolerance”. I never used it, as minister for multiculturalism, because as physicians, “tolerance” is a term we use with pain. We tolerate something—you know, pain tolerance.

I like the word “respect”. Respect for each other means that we know that we each bring something positive to the table and that we're all worthy.

Thank you.

I will now move to B'nai Brith. I don't know who will speak, Michael or David.

3:40 p.m.

Michael Mostyn Chief Executive Officer, National Office, B'nai Brith Canada

Yes, I'll be speaking first. Thank you.

3:40 p.m.

Liberal

The Chair Liberal Hedy Fry

All right, thank you. Will you be sharing your time?

3:40 p.m.

Chief Executive Officer, National Office, B'nai Brith Canada

Michael Mostyn

We'll be splitting our time.

Thank you, Madam Chair. We thank the committee for inviting us to appear.

My colleague, David Matas, our senior legal counsel, will speak to elaborate on some of our key points. We have documentation available and can provide additional materials to support our testimony.

B'nai Brith Canada is this country's oldest national Jewish organization, founded in 1875, with the proud history of defending the human rights of Canadian Jews and all Canadians across the country. We advocate for the interests of the grassroots Jewish community in Canada and for their rights such as freedom of conscience and religion.

B'nai Brith addresses the twin challenges of anti-Semitism and hate speech, linking them to the broader threat of discrimination and human rights, a universal issue that affects all Canadians and individuals everywhere. Anti-Semitism is but a visible portion of the dangers inherent generally in prejudice and discrimination.

The committee has an opportunity to study how all Canadians can face the challenges that exist for at-risk communities, those suffering from systemic racism and religious discrimination. The committee's work and its outcome must be embraced broadly by all Canadians, and it must deal with those communities that are the targets of racism and discrimination, including Canadian Jews, who continue to be the target of anti-Semitism.

The committee's work and its outcome must not diminish or be perceived to diminish the threat to Canadians of all faith communities who face racism and religious discrimination, and it must not suggest that one form of racism or religious discrimination is more threatening or of a greater priority than any other.

The committee's work and its outcome must exercise great care in any definition of Islamophobia, if indeed any is attempted. Any definition that is vague and imprecise, that is embraced by one community but not all, or that catalyzes emotion or irrational debate on scope and meaning can by hijacked and only inflame tensions between and among faith communities in Canada and detract from the committee's objective.

My colleague, David Matas, will explore the continued threat of anti-Semitism in Canada. Contrary to the views of some, anti-Semitism is not confined to the margins of our society. Since 1982, B'nai Brith Canada has published an annual audit of anti-Semitic incidents in Canada, copies of which you have. Over a five-year period, anti-Semitism has been on the rise. Statistics Canada has reported that in 2015, the most recent year with complete figures, Jews were the most targeted group in this country for hate crimes, a serious trend that has been continuing for nine years.

While most anti-Semitic hate crimes in the 1980s and 1990s were attributable to elements of the far right, we have sadly witnessed an increasing number of anti-Jewish incidents from within the Muslim community, sometimes by those claiming to act or speak in the name of Islam. We know that this trend is of concern to many leaders in the Muslim community, just as it is within the Jewish community.

Thus, we strongly endorse the importance for your work on M-103 to be broad-based. An unbalanced emphasis on Islamophobia creates the impression that Canadian Muslims are the only victims of hate crimes. We are just as concerned with the source of hate crimes targeting Canadian Jews from within radical elements of the Muslim community. We have exposed several such incidents and are concerned that the law is not being rigorously enforced to deal with those hate crimes.

The committee has an opportunity to address this trend and consider actions to counter it through laying out the facts, advocacy education, and stressing the consequences to be faced by those who act contrary to the charter and the Criminal Code. A message to law enforcement must be this: enforce the law.

Canada cannot become a haven for anti-Muslim bigotry. B'nai Brith Canada sees anti-Semitism as but a visible portion of the dangers inherent generally in prejudice and discrimination, including that directed towards Muslim Canadians. By the same token, we must ensure that no one can hide behind the idea that any criticism of Islam represents Islamophobia, or a vague definition to this effect.

Our hope is that the committee will continue to bear in mind that Canada's most targeted religious minority in terms of hate speech and hate crimes is the Jewish community, and we have some specific recommendations that we can address later on.

3:40 p.m.

Liberal

The Chair Liberal Hedy Fry

I will go to David Matas.

I want to tell you what an honour it is to have you here as a witness.

3:40 p.m.

David Matas Senior Legal Counsel, National Office, B'nai Brith Canada

I'd like to thank you and respond in kind and say it is an honour to be here, particularly having you in the chair.

I realize that M-103 mentions only Islamophobia by name, but is not just about Islamophobia. All the same, I would suggest for the committee that Islamophobia cannot and should not be ignored, both the concept and the question of what to do about it.

Literally, “Islamophobia” means “irrational fear of Islam”. The concept acknowledges the existence of its opposite. Not every fear, for instance, of being confined in a tiny space is claustrophobia. Sometimes the fear is rational. Similarly, not every fear of Islam is Islamophobia. Sometimes that fear too is rational. Adherents to some components of Islam preach hatred and terrorism, incite hatred and terrorism, and engage in hate-motivated acts and terrorist crimes. Fear of these forms of Islam is a rational response to the threat they represent.

Anyone who is not afraid of, for instance, al Qaeda, ISIS, the Taliban in Afghanistan, Hezbollah in Lebanon, Hamas in Gaza, Islamic Jihad in Syria, the Al-Aqsa Martyrs' Brigade in the West Bank, or al Shabaab in Somalia is foolhardy. Many terrorist Islamic groups are listed under Canadian legislation as terrorist entities. We have troops in Afghanistan training and advising in the combat against the Taliban. Fear of some elements of Islam is mere prudence.

Islamophobia is misplaced because it is overbroad. However, we must not be carried away by the combat against overbreadth and go to the opposite extreme of being too narrow, of ignoring or, even worse, of standing against the fear of those elements of Islam about which there is every reason to be afraid.

Islamophobia does not appear in a vacuum. It grows out of a fear of incitement to, and acts of, hatred and terrorism coming from elements of the Islamic community. Combatting Islamophobia effectively means targeting the real threats within the Islamic community and not the innocents who have no association with the threats.

While targeting a threat of incitement and acts of hatred and terror directly and proportionately is easier said than done, often difficult decisions have to be made. It is, I acknowledge, asking too much to expect the committee to go through the various measures that governments worldwide have adopted or proposed to combat the threats and acts of hatred and terror coming from Islamic radicals. We suggest that what the committee can easily do is propose criteria with illustrated examples that can guide those directly involved in the combat against the threatened acts of hatred and terror coming from Islamic radicals. The criteria and the guidance would help those involved determine whether a particular action intended to counter a threat from Islamic radicals is indeed proportionate or Islamophobic.

The House of Commons resolution calls for the committee study to use that holistic response. A holistic response, when it comes to Islamophobia, requires a dual focus: a focus both on those victimized by Islamophobia and on the incitement of acts of hatred and terrorism that come from within elements of the Islamic community.

Thank you.

3:45 p.m.

Liberal

The Chair Liberal Hedy Fry

Thank you very much.

My goodness, everybody is really working within their 10 minutes and leaving me lots of time. That's good.

Rabbi Fogel—

3:45 p.m.

Shimon Fogel Chief Executive Officer, Centre for Israel and Jewish Affairs

I'll be the exception to the rule.

3:45 p.m.

Liberal

The Chair Liberal Hedy Fry

Okay.

3:45 p.m.

Chief Executive Officer, Centre for Israel and Jewish Affairs

Shimon Fogel

Thank you, Madam Chair.

We appreciate the opportunity to present to members of this committee on behalf of the Centre for Israel and Jewish Affairs, the advocacy agency of the Jewish Federations of Canada.

We are a national, non-partisan, non-profit organization representing more than 150,000 Jewish Canadians affiliated through local federations across the country. Like our sister organization, B'nai Brith, we are committed to working with government and all like-minded groups to ensure Canada remains a country where everyone enjoys equal opportunities and equal protections.

Canada is a tremendous country, particularly for members of minority groups. It is one of the most vibrantly diverse, inclusive, and respectful places in the world. However, hatred persists here in the margins of society. We must remain vigilant to ensure that hate does not gain a greater foothold and we must endeavour to push it ever further into the shadows.

Confronting hate is an all too familiar experience for Jewish Canadians. In report after report, Statistics Canada and police services across the country continue to confirm, as was noted just a moment ago, that Jews are the religious minority most targeted by hate-motivated crime, in both absolute numbers and on a per capita basis.

Nationally, there were 54 hate crimes targeting Jews per 100,000 individuals in 2015. While this number is relatively consistent with previous years, there was an increase in hate incidents targeting other minority communities, including the Muslim community. In fact, Muslims were the next most targeted group, with 15 incidents per 100,000 individuals.

Local numbers reinforce this. Let me give you some examples from the GTA, where the plurality of Jewish Canadians reside.

The Peel police service noted 23 incidents targeting Jews in 2016, which is a 155% increase over the nine incidents that occurred in 2015 and the highest increase in victimization of any identifiable group. Over that same period, there was a 92% reduction in hate crimes targeting Christians, from 13 to one, and a 54% reduction in those targeting Muslims, from 11 to five. Jews are around 0.2% of the population of Peel, but were targeted with 39% of all hate crimes. In the city of Toronto, the Jewish community is just 3.8% of the population, but was targeted in approximately 30% of hate crimes in 2016.

I mention these numbers not to showcase Jewish victimhood but to demonstrate the very real experience that our community has in grappling with the issues this committee is studying. At the same time, I want to note that percentages can sound alarming and misleading.

In York Region, anti-Jewish hate crimes decreased by more than 10%, while anti-Muslim hate crimes increased by more than 18% in 2016. This sounds significant until you look at the real numbers, which are a decrease from 19 to 17 incidents targeting Jews and an increase from 11 to 13 incidents targeting Muslims.

It's important that we not lose sight of the fact that on the whole, Canadians are incredibly welcoming, respectful, and accepting people and that hate crimes, though often jarring and sometimes horrifyingly tragic, are relatively infrequent occurrences. In Peel, 38,154 Criminal Code offences were reported in 2016. Of those, just 59, or 0.15%, were designated as hate-motivated. That said, one hate crime is too many.

Canada is a great place to be a minority. We believe the following constructive recommendations will help make it even better and we hope that each will be a point of consensus for this committee. I share with you four points.

Number one is improving data.

Currently, the collection and publication of hate crime and hate incident data varies widely by police department. I mentioned statistics from Peel, Toronto, and York Region, which are all readily available, but the reports from these three neighbouring jurisdictions each provide different information, so making direct comparisons is sometimes difficult. Other jurisdictions, such as Montreal, release no specific data regarding hate-motivated crime and which identifiable groups are being targeted. This practice has an impact on the national numbers compiled by Statistics Canada, leaving policy-makers, like each of you, with incomplete information.

This committee should recommend that the government establish uniform national guidelines and standards for the collection and handling of hate crime and hate incident data.

This step will help ensure that local, provincial, and national law enforcement consistently collect, catalogue, and publicize data regarding hate crimes and hate incidents. The more accurate and comprehensive the data available, the more appropriately efforts to counter hatred and bigotry in Canada can be calibrated to address the specific needs of the communities most impacted. Comprehensive empirical data is required to effectively diagnose the problems and prescribe the most appropriate solutions.

Number two is to define “hate”.

One can't effectively fight bigotry and hatred without precisely defining it. The International Holocaust Remembrance Alliance's definition of anti-Semitism was achieved through multilateral consensus endorsed by governments around the world, including Canada's, to accomplish just that. Concrete examples set clear standards for what constitutes anti-Jewish sentiment and what is legitimate critical expression. Similar definitions should be established for other forms of hate, based on careful consideration, common sense, and consensus.

The term “Islamophobia” has been defined in multiple ways, some effective and some problematic. Unfortunately, it has become a lightning rod for controversy, distracting from other important issues at hand. While some use the term “Islamophobia” to concisely describe prejudice against Muslims, others have expanded it significantly further to include opposition to political ideologies. For example, this October's Islamic Heritage Month guidebook issued by the Toronto District School Board contained a definition of Islamophobia that included, ”dislike...towards Islamic politics or culture”.

This incident exposes significant problems associated with relying on ad hoc, inadequate definitions of Islamophobia. Muslims can be protected from hate without restricting critique of ideologies, especially those that are explicitly anti-Semitic. Recent examples of anti-Semitism on display at some mosques and Muslim organizations in Montreal, Toronto, Calgary, and Vancouver have shown that extremism is a problem within parts of the Canadian Muslim community that must be addressed.

As Canadians counter hatred and protect individuals from discrimination, we must also maintain the freedom to debate and criticize ideas. Defining other forms of hate—including, but not limited to, Islamophobia—along lines similar to the IHRA definition of anti-Semitism is, we think, a good starting point. It would help law enforcement and others to identify hate incidents with greater accuracy and consistency and provide definitive guidance to Canadians about precisely where free speech turns into hate speech.

Next, when it comes to countering hate crimes, greater and more consistent enforcement of existing laws is needed. In many cases, hate crime prosecutions require the authorization of provincial Attorneys General. This can become highly politicized and can be a very difficult hurdle to overcome. Recently the Attorney General of Quebec decided not to lay charges in the case of an imam in Montreal who had called for the murder of Jews. On the charge of hate promotion, the statute of limitations had been exhausted.

In an era when statements can live on in perpetuity online, in this case on this particular mosque's YouTube channel, we believe the statute of limitations for hate promotion should be extended, and we encourage you to make that recommendation to the government.

Quebec's Attorney General also declined to pursue a second charge of genocide promotion. This decision sent a message that someone can call for the death of an entire group of people without consequence. We think that's the wrong message.

To address this situation, the federal government should establish a national training program for police and prosecutors to educate them about the dangers of hate speech and encourage them to enforce the existing Criminal Code hate speech provisions more consistently and more robustly.

Finally, federal government resources should be allocated to support the development of dedicated local police hate crime units. These units have been integrated into several police services across Canada and have constituted an unqualified success. Units specifically trained to investigate hate-motivated crime ensure that incidents are handled with particular sensitivity and understanding of the distinct nature of the crime and its impact on the victims, their families, and their communities.

Universalizing hate crime units would ensure that as many vulnerable Canadians as possible can benefit from these services that ensure the officers responding to hate incidents are the best equipped to do so.

Had this committee been conducting these hearings a year ago, I would have had an additional recommendation to share. Instead, Madam Chair, I would like to conclude with this.

I'd like to express our gratitude to members of this House for supporting Bill C-305and your colleague Chandra Arya for bringing it forward. CIJA has long advocated for these changes, which will expand penalties for hate crimes targeting infrastructure such as community centres of identifiable groups. As we speak, the bill has just passed its final vote in the House before becoming law.

Bill C-305 is a clear example, Madam Chairman, of how elected officials can work together in the spirit of consensus and common sense to make a practical difference in protecting vulnerable minorities. I'm hopeful that the committee members will similarly unite around the approach I have outlined here today.

Thank you.

3:55 p.m.

Liberal

The Chair Liberal Hedy Fry

Thank you very much.

I just wanted you to know that you went 30 seconds over 10 minutes. Even though you wanted more time....

3:55 p.m.

Chief Executive Officer, Centre for Israel and Jewish Affairs

Shimon Fogel

My rabbi gave me a few more minutes.

3:55 p.m.

Liberal

The Chair Liberal Hedy Fry

He did.

Well, thank you very much for a very thought-provoking and very comprehensive set of recommendations and discussion on this issue.

We will now begin with the questions and answers.

The questions begin with a seven-minute round. That means seven minutes for questions and answers. As I always do, I'm going to ask you to be as concise as you possibly can, or else I'll cut you off. Thank you.

We'll begin with Dan Vandal and Michael Levitt for the Liberals.

3:55 p.m.

Liberal

Dan Vandal Liberal Saint Boniface—Saint Vital, MB

Thank you.

Thank you very much, first of all, to all three groups, all four individuals, for a very thoughtful presentation. I very much appreciate it.

Most of my time will go to Michael, but I first want to say something. There has been a false impression out there that the study of M-103 is a false suggestion that a hate crime against one group is perhaps more important or more threatening than a hate crime against another group. Nothing is further from the truth.

As well, there is the notion that M-103 will limit free speech. I want to say quite clearly, so there's no confusion, that as a permanent member for two years of this committee—and I speak for every member of the committee who is here today—that we would never suggest, we would never approve, we would never vote for anything that limits free speech. That simply is not going to happen at this committee. I just wanted to make that very clear in the rest my time.

4 p.m.

Liberal

The Chair Liberal Hedy Fry

Go ahead, Michael.

4 p.m.

Liberal

Michael Levitt Liberal York Centre, ON

Thank you, gentlemen. I have the pleasure of knowing all four of you and the two organizations that are represented here, B'nai Brith and CIJA. Thank you for your advocacy and the work that you do in representing the Jewish community.

One of the focuses of this study is to make recommendations to the government on how it could collect data, contextualize hate crime reports, and conduct needs assessments for impacted communities.

It's been mentioned, but I'm going to mention it again, that according to Statistics Canada's 2015 report on hate crimes, Jewish Canadians are the most targeted religious group in Canada. According to the Toronto police's hate crimes statistical report, since 2016 anti-Semitic incidents make up the largest group of hate crimes in Toronto. Jewish constituents in my riding of York Centre have been victimized by anti-Semitic incidents, including swastikas being painted on school playgrounds. These incidents are often not considered hate crimes.

My question is this: how are hate crimes and hateful incidents that do not formally qualify as hate crimes currently quantified, and how can this data be better collected, quantified, and analyzed? Can you provide some insights? I know that all of you gentlemen did a certain amount of this work, but can you provide some insights into strategies, whether they be legal or educational, that we can use to counter this very serious issue? Can you provide some insights and perspective on that?

I think for this question I will limit it to Mr. Fogel and Mr. Mostyn, and then I'll do have a follow-up question that I want to particularly direct at Rabbi Bulka, please.

4 p.m.

Chief Executive Officer, Centre for Israel and Jewish Affairs

Shimon Fogel

Thank you for the question and for your gracious comments. I'll be very quick and concise, Madam Chair.

I think that the tools for gathering information and data already exist. As B'nai Brith noted, they've been doing this for quite a number of years. The challenge, I think, is to ensure a degree of consistency across the country so that we understand what we're talking about as apples and apples as opposed to apples and some other fruit or vegetable.

Once we get there and we can analyze the trends and where expressions of intolerance are going and how acute they are, I think then that whole coalition of law enforcement, educators, community leaders, and elected officials can come together and develop programs and plans.

I happen to be especially partial to the approach described by Rabbi Bulka. I think we are never going to eliminate hate from those who are dead set in perpetuating those kinds of awful notions. What we have to provide for society at large are the alternatives, the positive and constructive ones that enrich our society and allow us to recognize the value that each community brings to the upbuilding of Canada in the next 150 years.

4 p.m.

Liberal

The Chair Liberal Hedy Fry

You wanted Mr. Mostyn—

October 18th, 2017 / 4 p.m.

Liberal

Michael Levitt Liberal York Centre, ON

Yes, and then I have a question for Rabbi Bulka.

4 p.m.

Liberal

The Chair Liberal Hedy Fry

—however, if Rabbi Bulka wanted to say something, I would give him the opportunity.

Mr. Matas or Mr. Mostyn, which one of you wants to respond?

4 p.m.

Senior Legal Counsel, National Office, B'nai Brith Canada

David Matas

I wanted to address one particular component of your question, which was how we get statistics about something that's racial but not a crime.

Even with the best and most consistent statistics in the world, the police are presumably going to collect information that's relevant to criminality and not more general racial expression. The League for Human Rights of B'nai Brith does it. I think other communities could do that. We've heard a recommendation about consistency in data collection across police units, and it would make sense to have consistency of collection across NGOs about non-criminal racialism. The government might think about standards of consistency and ways that it could be supported.