Thank you very much.
Ahmed is indeed right that a number of provisions require further study. For example, under part 2, for section 20 of the Security of Information Act, SOIA, there is an amendment to add the language of intimidation:
Every person commits an offence who, at the direction of, for the benefit of or in association with, a foreign entity or a terrorist group, induces or attempts to induce, by intimidation, threat or violence, any person to do anything or to cause anything to be done.
However, as has been raised before for this committee today, “intimidation” is not defined in the SOIA, and this is hugely problematic. Are we using the tort definition or relying on parallel Criminal Code uses of the concept of intimidation or another definition entirely? This ambiguity could be used by this or future governments to target different kinds of protest activities that some have accused of being foreign-funded, whether they involve convoy protesters, Black Lives Matter protesters or others. We recommend that this section be deleted in its entirety or that “intimidation” be clearly defined in the act to ensure there is a civil liberties carve-out similar to the proposed carve-outs in subclause 60(2) and clause 61 of Bill C-70.
The bill also, in part 1, expands substantively CSIS powers. The expansion of CSIS powers to, as proposed, help it adapt to changing technology beyond Canada is a significant change that deserves study. Changes around surveillance and warrant procedures deserve significant study as well.
We are also concerned about the expansion of the inadmissibility provisions of the Immigration and Refugee Protection Act, IRPA, the sabotage provisions and many others. The new IRPA provision, for example, suggests that the minister may be able to find someone inadmissible if the minister deems that they are bad for Canada's “international relations”. How would this impact dissidents from dictatorships that Canada has diplomatic relationships with?
This legislation has many complex implications. Appropriate due diligence is not being exercised when it appears that all parties, with what we view as good intentions, are inadvertently rushing to make significant changes to our national security infrastructure without adequate checks and balances through longer, rigorous and informed study.
Subject to any questions, those form our submissions. Thank you.