Many of our members would certainly want to support individuals in making complaints when necessary and might have a role as an accompaniment or an advocate in helping somebody bring forward a complaint when they have consent.
We see real limitations in the bill around, first of all, that requirement for consent, because of the many barriers, some of which I mentioned: fear of deportation, fear of detention, fear of not getting status and fear of being sent back for persecution. There are so many reasons that an individual may not be able to make a complaint or may be afraid to make a complaint and who may not, for the same reasons, be willing to give consent. We absolutely need a mechanism whereby third parties like NGOs can bring forward patterns of behaviour in particular. We have specified in more detail in our brief what that would look like.
We also want to make sure that such credible organizations as the Canadian Council for Refugees could ask for or make a formal request for a specified activity review. In the legislation as tabled, that's not possible, unless we're sort of waving a red flag and getting the attention of the commission and the commission then initiates a review. We want that embedded in the legislation.