Public Safety committee  To be perfectly frank, I have to tell you that we haven't given that a lot of thought, so I can't provide a detailed answer. However, I think expertise and open-mindedness would be good qualities for members to have, and having members from cultural communities would be a tremendous asset.

Public Safety committee  If I understand what you're asking, I would say that the bill is an excellent step in that direction. Giving third parties the ability to make complaints amounts to giving cultural communities a point of access for reporting problems they've had. Third parties may submit complaints individually, but when a complaint is reported over and over again to organizations like ours, our members talk about it and usually it's pretty easy to pinpoint a particular problem, whether in a certain office or location.

Public Safety committee  Take someone whose refugee protection claim was denied. CBSA has an obligation to remove them from Canada as soon as possible. Submitting a complaint could signal that the file needs to be updated, prompting the officer to conclude that the file is ready and the person needs to be removed from the country.

Public Safety committee  From what we see in the field, I don't think it would be efficient. I don't think our association has a global point of view about that, but in the field it's hard to complain about a co-worker, and it's going to be even harder, we think, to see it from a different point of view.

Public Safety committee  Could you tell us which article you're referring to? I'm sorry.

Public Safety committee  We would definitely encourage it. I'm sorry, I'm not sure where it is in the project, but we definitely encourage that there is a judicial review possible, because it is more than important. The agency has a lot of discretion. Bill S-8 also gave them even more power. We don't have access to judicial review, so we think a judicial review is really important to be able to catch the cases that fall through the cracks.

Public Safety committee  Our association is definitely concerned about that. It's too easy to dismiss a complaint regarding an officer's conduct on the pretext that the complaint has less to do with the officer's conduct and more to do with the policy in place. According to the language in the bill, the new commission must refuse a complaint, simplifying the situation.

Public Safety committee  Yes, we see that in the decisions that are made. I'll give you a straightforward example involving an officer. He decided to arrest someone even before their deferral date, on the grounds that he had suspicions. His supervisor simply told us that he agreed with the officer's decision.

Public Safety committee  This would have helped in certain situations where it's blatantly obvious that the person doesn't understand exactly what's going on or how to follow the process. By allowing agencies to help, it would make things easier for the new commission and allow for quicker responses. The agency has extremely wide discretionary powers.

Public Safety committee  Unfortunately, we didn't have time to submit anything in writing to the committee. We can put something together and sent it in later. As mentioned in the document we sent you, we think that the definitions contained in Bill C‑20 are really too vague to have probative value and for the new commission to have greater power of investigation.

Public Safety committee  I completely agree. We think it should also include policies the agency adopts. Individuals and entities need to have that opportunity.

Public Safety committee  By permitting third party complaints, it will answer article 28 and permit the commission to do its own reviews. When we, who have experience in the field, have complaints from many claimants, at that point, we could also raise that issue to the agency or to the commission. We already try to do it in the field.

Public Safety committee  I'm going to let my colleague speak for the association, and then I'll answer the questions.

Citizenship and Immigration committee  Sorry, I'm going to take over. Yes, we think it should be delivered as soon as possible. Another way of doing it is by having a point at IRCC where a claimant could go right away because—

Citizenship and Immigration committee  Yes. There will be less pressure on the Canada Border Services Agency and on the Immigration and Refugee Board of Canada. We also think there will be a better distribution of the workload, and, most importantly, better capacity to support the people arriving.