We certainly agree that the question of culture change at CBSA is something critical. That does relate to our first and second recommendations, really, in terms of the need for the commission to be able to receive systemic complaints and for those complaints to come from third parties. That is one mechanism whereby broad issues that are arising across a number of cases and perhaps impacting the most vulnerable, who may not feel comfortable bringing a complaint.... If there's a pattern of behaviour that becomes apparent to a third party, I think that mechanism is critical.
The other way, I would say, that we could tweak Bill C-20 relates to the data collection and publication. We are certainly happy to see the inclusion of the collection of disaggregated race-based data. We do note, however, that the way in which that data proposes to be collected is going to inherently give a partial picture. Not only is it partial in terms of the demographic data, but it's just collecting data based on race. We certainly have heard at our organization and among partner organizations a lot of complaints regarding discrimination according to religious background, nationality, language and individuals with mental health issues facing disproportionate enforcement action by CBSA, so we think that there's an important element of collecting a broader demographic set of data.
Also, collecting data solely from individuals who make complaints doesn't tell us who isn't making the complaints. We miss the most vulnerable individuals, who still face barriers in bringing complaints to the commission. We would suggest that it's important that CBSA and the RCMP be empowered to collect data regarding who they interact with on a more regular basis so we have a broader picture of what that population looks like. Who is complaining and who isn't? What systemic issues are coming through third parties that give us the evidence and the facts upon which to make policy recommendations to see that change?