Yes, I know you will.
After having worked for three and a half years as a clerk, as I told the chair, I went to London for four years, under the Chrétien, Martin, and Harper governments.
I'm not an expert in immigration, but I have looked at the system in various ways at different times, and my insights may help the committee.
I would recommend to the committee that you focus on three things. The first is the need to identify the objectives of the policy. You can't get at an effective system without understanding and unpacking the multiple objectives of the policy. The second is to take a risk management approach. You can't have zero risk in this business, so you have to try to manage the risk. The third is that the benefits of the policy or program overwhelm the cost, and you should know that there will be both to anything the government does—both benefits and costs.
On the objectives, there are many possible objectives to a temporary visa program. They include keeping out the sick, excluding and restricting access to criminals and terrorists, ensuring the people do not overstay their visitor welcome, avoiding the back door to immigration or refugee claim, or just raising revenue. Several countries use it to just raise revenue. Each of these would entail a different strategy or program to address it. Keep in mind, there are multiple objectives and they require multiple instruments.
On the risk management point, you'd think about stochastic events and the probabilistic events. You have to be prepared to accept that there will not be zero risk to meeting these objectives. You have to assess what the risks to meeting your objectives are and you have to decide if mitigation of these risk strategies may work or not. You have to be prepared to accept some failures. This is tough for politicians, I know. It's tough for everybody.
If your overwhelming objective is to limit the time in country, then exit controls look attractive. But they don't actually help you in worrying about the claims to refugee status. If you're worrying about refugee status, then the restriction of entry is preferred.
In all cases, you will exclude some people you do not want to exclude. There will be false negatives. And some people will get through the system, the filter that you have, and you would have preferred to exclude them. These are false positives. That means that you will inadvertently exclude some of the students Dr. Hamdullahpur wants to admit, or some of the tourists I'm sure Mr. Goldstein wants to admit. You will probably and probabilistically let through some of the people that the chiefs of police would like to keep out.
The fact that constituents bother MPs with complaints about the time taken or about rejections is not evidence of a failure of the system. If the system worked and kept out the right people, you would still have your constituents knocking on your door. You have to interpret what the signal is when your constituents complain to you.
On the cost and benefits, there are inevitable costs of some of the solutions. You have to assess whether it's worth it or not.
If you will permit me a brief comment on administration, visa officers exercise significant discretion and authority. There's a demand to have an appeal process, and it may be warranted. But these decisions are not life-threatening or of dramatic significance. There is ultimately appeal before the Federal Court of Canada, under section 18, I believe.
However, the solution is more probably in providing the visa officers with administratively clear instructions and good training on how to administer their discretion and how to deliver the program. In that context, research will help in providing indicia of future performance and indications of what works and what does not. Relying on evidence to design a system is highly desirable. Evidence is not always used in policy development, and it should be in this case. Evaluation has been and will be helpful here. I know the committee has looked at the evaluations of the program.
Finally, in administration, I want to note that when I was head of mission in London, I was enormously impressed with the dedication and commitment of the staff, both locally engaged—this is one of the untold stories of Canada, that we have these foreign nationals who work for us, who do a brilliant and wonderful job—as well as the Canada-based staff who administer the system.
Let me just open a parenthesis on the question of the time taken, and Professor Hamdullahpur has made this point. Sometimes a decision, any decision, is better than waiting for the right decision. So if the objective is 14 days taken, sometimes it's better to get a decision you don't like that comes out quickly and removes uncertainty. Sometimes people prefer that to being held in limbo for 60 days or a year.
CIC has objectives that are stated as:
CIC has two main priorities in this area. First, we are committed to facilitating the travel of legitimate visitors to Canada, while at the same time protecting the health, safety, and security of Canadians.
These need not be inconsistent, but the instruments used to meet these multiple objectives must be tailored for purpose and based on evidence.
In conclusion, it is essential that you be clear, deliberate, and transparent about the objectives of your visa policy. It is necessary to take a risk management approach to your programs to address these objectives, and you should take account explicitly of the costs of your initiatives and minimize them to the extent valuable.
Mr. Chair, I hope my remarks will be useful to the committee.
I am now ready to answer your questions.