Thank you for your question, Ms. Michaud.
In our written brief we do provide a concise red line for how we would suggest approaching the question of third party complaints. We're happy to see that third parties can, under the current draft of the bill, bring complaints with the express written consent of an individual.
However, we would like to see the bill amended to explicitly allow the filing of complaints as they relate to systemic or policy issues. This could easily happen through changes to clause 52, which currently allows the commission to refuse to deal with a complaint if it's not from an individual. That is the sort of circumstance where the commission has the power to decline jurisdiction. An easy tweak there would allow organizations to bring those complaints.
I would note additionally that third parties are critical and are only really helpful in bringing these types of complaints if they are well informed. Part of that comes from the experience of their members, such as our organization, but also part of that comes from publication of information from the commission itself.
Right now there are limitations on the types of publications that are available. Certain reports are only published in summary, as opposed to the full report. We would like to see more transparency because that can inform further third party complaints going forward.
We would also like to see, in a similar vein, the commission having more powers of redress, not only in terms of actually enforcing recommendations, but also in being able to suspend removal or have interim measures available. This would allow a complaint to go forward to inform the commission and its activities without an individual being deported in the midst of that process.