Essentially, our major recommendation is to leave section 64 as is, without changing it down to the six months provision.
Another recommendation that we always put forward is one to actually study the implications of these changes on our population. What we know right now is that the immigration department doesn't actually track mental health. We do not have statistics about how many individuals who come in front of the IRB, the IAD, and the CBSA officers actually have mental health issues, and even if those questions are asked, nobody is tracking the data.
I can speak anecdotally. We've seen a lot of those cases at our organization. We've seen a lot of those cases from the lawyers we deal with who assist on cases, but the immigration department does not have a clue—not to put it out there, but they really don't know because they don't keep track.
There's another thing we'd like to study: the implications of Bill C-10, which was passed just recently, and the mandatory minimum sentences and how those are going to impact on the number of six-month convictions, I guess, that would essentially cause individuals to spend six months in jail. At this stage, it's hard to deduce how wide the net will be cast, but because we're increasing criminal provisions on one side and really casting a net wider in the criminal justice system, we cannot make a rational judgment around how immigration is going to be impacted by it.
Another recommendation I'd like to put forth is actual training on mental health and mental illnesses for the policy-makers who are dealing with immigration cases, for the adjudicators—such as the judges—and for the CBSA officers as well. We're doing that on the correctional side and we've seen some progress with the training. We'd like to continue doing that within the immigration department.
Another thing that we'd also suggest—