Thank you.
First, I want to say that it is an honour to participate in your study of differential outcomes in Canadian visa officer decisions.
When I look at the subtopics in this study, I can't help but think that a significant portion of the relevant data and information to these topics has only been obtained through Access to Information Act results that private individuals have shared online.
Given this, I want to focus my presentation today on transparency.
The only way that one can properly review whether there is systemic bias in Canada's immigration programs is if the relevant information is easily available to the public. I want to suggest a few ways to achieve this.
First, prior to 2016, IRCC posted quarterly processing times and approval rates for all of its programs, by visa office. The information showed what actually had occurred at a given office and was very useful. IRCC stopped doing this after 2015. The government's website currently says that they stopped doing this because IRCC wanted to post only global information. While IRCC may have a goal that all applications are processed the same regardless of visa office, I think everyone knows that this is not the case in practice. I would suggest that IRCC bring back the visa office specific quarterly updates.
Second, IRCC should publish as downloadable PDFs Access to Information Act results that pertain to internal manuals, visa office specific training guides on assessing the genuineness of a marriage, and other similar documents. Right now it is possible for the public to search the titles of previous completed requests, but then the individuals have to wait for them to be emailed, which can take several weeks. Again, I don't think most of the public knows that this is possible. The British Columbia government, meanwhile, publishes as downloadable PDFs all non-individual specific, previously disclosed freedom of information releases. This approach is a model for transparency that I believe IRCC should follow.
Third, IRCC should, in my opinion, publish detailed explanations and reports of how its artificial intelligence triaging and new processing tools work in practice. Almost everything public to date has been obtained through Access to Information results that are heavily redacted and which I don't believe present the whole picture. For example, in late 2020 it was revealed through ATIP that all visitor visa applications from China and India have gone through an AI triage since at least 2018. It is not clear how this AI triage works.
I shared an online internal IRCC document from 2018 about the triage of these applications from India and China. It stated that while AI triaged files, visa officers were not told why a file was triaged a certain way, so that officers still reviewed applications. The document then had a 2020 footnote that stated that officers are now provided with key facts about the client to reduce the time spent searching for information. The implication seems to be that the department does not want officers reading entire applications, and there needs to be more transparency about this.
IRCC presents the Chinook processing tool and to a lesser extent AI as just an Excel spreadsheet and a change in process. However, the Pollara Strategic Insight final report says that an IRCC employee, or employees, expressed “Concern that increased automation of processing will embed racially discriminatory practices in a way that will be harder to see over time.” It is not clear why an Excel spreadsheet would do that. It would be great to hear more from the person or people who said this to learn what they are seeing on the ground.
Now, their concerns and mine may not be fully accurate, but in the absence of increased transparency, concerns like this are only growing.
To conclude, in order for this committee to provide ongoing, meaningful insight and oversight into whether there are differential outcomes in decisions based on race and region, the department needs to be more transparent and publish information that reflects what is actually happening rather than what the government's or the department's goals are.
Thank you.