THE STANDING SENATE COMMITTEE ON SOCIAL AFFAIRS, SCIENCE AND TECHNOLOGY
EVIDENCE
OTTAWA, Thursday, May 18, 2023
The Standing Senate Committee on Social Affairs, Science and Technology met with videoconference this day at 11:31 a.m. [ET] for the consideration of the subject matter of those elements contained in Divisions 8, 13, 14, 15, 16, 17, 18, 19, 25, 27, 28, 29, 35 and 38 of Part 4 of Bill C-47, An Act to implement certain provisions of the budget tabled in Parliament on March 28, 2023; and, in camera, for the consideration of a draft agenda (future business).
Senator Ratna Omidvar (Chair) in the chair.
[English]
The Chair: I would like to begin by welcoming all members of the committee, our witnesses and members of the public who are watching our proceedings. My name is Ratna Omidvar from Ontario, and I am the chair of this committee.
I would like to begin by introducing our members to the witnesses and to the public, starting with our deputy chair.
Senator Cordy: I’m Jane Cordy, a senator from Nova Scotia.
Senator Bernard: Wanda Thomas Bernard. I’m also from Nova Scotia.
Senator Osler: Gigi Osler from Manitoba.
Senator Burey: Sharon Burey, a senator from Ontario.
Senator Kutcher: Stan Kutcher, Nova Scotia.
Senator McPhedran: Senator McPhedran from Manitoba.
[Translation]
Senator Petitclerc: Chantal Petitclerc, senatorial division of Grandville, Quebec.
[English]
Senator Seidman: Judith Seidman, Montreal, Quebec.
[Translation]
Senator Miville-Dechêne: Julie Miville-Dechêne, senatorial division of Inkerman, Quebec.
[English]
Senator Dasko: Donna Dasko, a senator from Ontario.
The Chair: Thank you, colleagues.
We will be going in camera at 1:15 p.m. in order to discuss draft observations. Therefore, our time with our panels must be slightly constrained. I’m giving you a heads up in terms of how we plan to make sure we hear from witnesses and give you time — not enough, always — to ask questions and answers and then wrap this part of the study up.
Our first panel is focusing on Division 18, which deals with amendments to the College of Immigration and Citizenship Consultants Act. Today we welcome, from the College of Immigration and Citizenship Consultants, John Murray, President and Chief Executive Officer and Michael Huynh, Director, Professional Conduct, and from the Canadian Association of Professional Immigration Consultants, Mr. Dory Jade, Chief Executive Officer.
Thank you for being with us today. Each organization — there are two in front of us — will have five minutes for opening statements.
We will begin with Mr. John Murray.
John W. Murray, President and Chief Executive Officer, College of Immigration and Citizenship Consultants: Thank you, Madam Chair, and good morning, honourable senators.
My name is John Murray. I’m the Chief Executive Officer and Registrar of the College of Immigration and Citizenship Consultants. I acknowledge that I am presenting to you today on the unceded, unsurrendered territory of the Anishinaabe Algonquin Nation. I am joined by my colleague Michael Huynh, Director of Professional Conduct at the college.
Thank you for this opportunity to appear before you to discuss the college and the important amendments to our governing legislation proposed in Division 18 of Bill C-47. I also look forward to answering your questions.
The College of Immigration and Citizenship Consultants was established under the College of Immigration and Citizenship Consultants Act, a division of the Budget Implementation Act, 2019. This act was passed by Parliament and received Royal Assent in June 2019, but it was not proclaimed in force until December 2020.
Pursuant to a ministerial order, the college opened its doors officially in November 2021 when the Immigration Consultants of Canada Regulatory Council was continued as the college.
The college act established the new college as an arm’s-length body from government and gave it the mandate to license and regulate immigration and citizenship consultants in the public interest. The college was established as a key part of government efforts to strengthen oversight, fight fraud and uphold the integrity of Canada’s immigration system. The college act establishes a comprehensive regulatory framework to enable Canada’s immigration and citizenship consulting profession to overcome the issues raised in the June 2017 report of the House of Commons Standing Committee on Citizenship and Immigration and with the intention of placing the college on an equal footing with other long-standing professional regulators in Canada.
As set out in the college act, the purpose of the college is to regulate immigration and citizenship consultants in the public interest and protect the public by:
. . . establishing and administering qualification standards, standards of practice and continuing education requirements for licensees . . . ensuring compliance with the code of professional conduct . . . and undertaking public awareness activities.
To meet this mandate, the college maintains a publicly accessible register of regulated professionals and establishes and administers prerequisite education, entry-to-practice and other licensing requirements. I note that in this regard, the college has recently launched a new graduate diploma program, which all new licensees are required to complete. It is offered in English at Queen’s University through the Faculty of Law and in French at the Faculty of Law of the Université de Montréal.
The college enforces the code of professional conduct through a rigorous complaints and discipline process, and educates the public through awareness campaigns aimed at prospective newcomers to Canada and other stakeholders.
The college act also grants the college the power to bring court injunctions against unlicensed practitioners in appropriate cases. These statutory powers are important to the success of the college. However, there are a number of amendments necessary to ensure the better protection of the public interest and efficient and effective college operations. Many of these necessary amendments are in the bill before us today.
These amendments include adding new powers that were missed or amendments that are necessary to clarify provisions in the original legislation. These include amendments clarifying that the college may provide training and development programs for licensees; allowing the college to enforce disciplinary orders through the courts; protecting college directors, officers and employees from liabilities for actions taken in good faith; clarifying elements of the discipline process and the penalties that may be imposed; allowing the college to assume custody of a licensee’s business in certain circumstances to ensure client interests are protected, including by identifying another licensee to take on active matters or by returning client documents and funds; allowing the college to enter into formal information-sharing agreements with other agencies and governments; and expanding the college board’s ability to make bylaws to regulate in certain areas.
While these proposed amendments accomplish a lot, I note that the college is still a relatively young organization. Over time, we anticipate that there will be more work to do. For example, we are currently working with Immigration, Refugees and Citizenship Canada on solutions to other legislative challenges facing the college, including some related to the federal Access to Information Act and Privacy Act.
Canada continues to be a preferred destination for talented immigrants from around the world —
The Chair: We will have to hopefully get to the rest of your statement through question and answers or if a senator is willing to cede their time.
Dory Jade, Chief Executive Officer, Canadian Association of Professional Immigration Consultants: Good morning, everyone, Madam Chair and senators.
It is my pleasure to come before you today to discuss the concerns related to the amendments of the College of Immigration and Citizenship Consultants Act under Bill C-47. The Canadian Association of Professional Immigration Consultants, or CAPIC, is the professional association of licensed Canadian immigration consultants, which has in its membership, RCICs, or Regulated Canadian Immigration Consultants; Regulated International Student Immigration Advisors, or RISIAs, and immigration lawyers.
For many years, CAPIC has been the driving force behind self-regulation of this industry under federal statute, unlike some other probably competitive authorized representative groups who have been promoting for no regulation at all. We have been pushing for stronger rules which set the parameters for competent and ethical practice for the regulator.
The first concern is that Bill C-47 proposes to expand the college’s mandate under section 4 (a.1), establishing and providing training and development program for licensees. CAPIC believes that adding more to the mandate of the regulator at this stage would probably cause conflict of interest, as the regulator becomes the developer and the accreditor of the program.
This proposed amendment would impact the college’s ability of continuing to protect the public. The resources of the college are limited and do require way more resources in order to implement the section 4 (a.1) amendment.
Those courses have already been given prior, I would remind the committee — 19 years ago — by the previous regulator and has led to the regulator being dissolved, in part, by that particular process. Subsequently, ICCRC, which is the evolution — the college is now the evolution of that regulator — did not have what is called a CPD provider in its mandate, and Bill C-47 left out such a mandate intentionally.
The next point is section 17, which will permit the college to apply for a court order without notice. We believe that, in an environment where natural justice should be respected, notice should be given to licensees when a court order is filed. Giving notice to the person is part of their fundamental rights.
Enshrining bylaws into regulations might lead to some issues where the Governor-in-Council power would be delegated to the college, and this is a point that we believe should be assessed as a self-regulated profession, removing one layer from the government of supervision.
The college is seeking access to the premise of licensees. However, in our case, a very large number of licensees practice from home, and property is not well identified or defined in the act, which means they are entitled to access dwelling because of the location of the licensees.
Thank you for your time. I am pleased to take your questions.
The Chair: We will now go to questions from senators. Colleagues, I am shortening the time for each question and answer so that everyone gets a shot and we adjourn in time. You will have three minutes for your question and the witnesses’ answers. Therefore, witnesses, please also keep your answers succinct. You can always respond to us in writing if your time runs out. The same goes for senators. We can pose questions in writing and get responses in writing.
Senators, please also identify to whom you are asking the question. The first question goes to the deputy chair of the committee.
Senator Cordy: I’m going to ask a few questions within it, mainly to Mr. Murray, who was cut off. It’s related to compliance.
Thank you very much for the document you sent. It was very helpful to read through that.
How do you ensure compliance by consultants? I know you send yearly reports to the department, but what do you do to ensure compliance is there? Do you check individually, or is it the paperwork they send, that kind of thing? How do you deal with it from a logistics perspective?
You spoke about something just as you were finishing up. It was the existence of unauthorized practitioners and that it still remains a gap. I think both of you spoke about that. You know they’re there, but they are continuing to practise. Mr. Jade just spoke about the access to the premises, but if it is a dwelling, then it makes it more challenging.
What tools do you need in order to be able to stop unauthorized practitioners? That would be a challenge for those who are coming into the country believing what an unlicensed or, perhaps, unethical practitioner would do.
Mr. Murray: Thank you, senator. The college has in place an evolving suite of regulatory tools that it uses to license individual immigration consultants and international student immigration advisers, and monitor their activities throughout the time of licence. These include all of the tools that you would expect from a professional regulator, such as stringent pre‑licensing education requirements; a stringent entry-to-practice examination, which all new licensees must complete; and mandatory and continuing education requirements, which must be completed annually. Licensees report on completion of those, and we audit those reports when we receive them. There is a very detailed annual renewal process that each licensee must complete in order to keep their licence current.
That is an evolving process. As I mentioned, we are a relatively new organization. Every year, though, we dig deeper through that process into licensee business operations and activities to make sure that they’re complying with our bylaws and regulations, many of which are not yet final. We are waiting for the government to promulgate a full suite of regulations under the college act, and also to ensure compliance with our new code of professional conduct, which was developed and promulgated as a regulation in June 2022.
The unauthorized practitioner issue is enormous, and it is one that every country that is a destination of choice for immigrants around the world faces. There are three key tools in the act for addressing the unauthorized practitioner issue. The first is the injunction power that is given to us to bring injunctions against unauthorized practitioners through Canadian courts. Those of you who have legal training will know that an injunction power sounds good, but it’s a very blunt instrument, and it requires substantial evidence. Like all litigation proceedings, it’s uncertain and expensive. That is a power that we expect to be able to use mostly for domestic unauthorized practitioners, because the difficulties in enforcing injunctions from Canadian courts really vary upon the jurisdiction in which you’re trying to enforce them.
It’s no secret that the majority of unauthorized practitioners who choose to prey on prospective immigrants to Canada are located offshore, mostly in the countries where those prospective immigrants come from, such as India, China and the Philippines.
In that regard, the college and the council before it conducted rigorous public information and awareness campaigns, mostly digitally focused, because that’s the best way we have found to reach individuals in those source countries, to advise them of the availability of licensed consultants.
The Chair: Thank you, Mr. Murray. I apologize, but we have to keep to the time.
Mr. Murray: Certainly.
The Chair: The next question is Senator Seidman’s, and she has graciously ceded her time to me. My question is to you as well, Mr. Murray. I remember well the study of the bill — I think it was C-97 — that called your college into life. Some of my questions relate to the questions I asked then.
There are two distinct groups of stakeholders here. In my view, one is more important than the other, and that is the immigrant. Then there are the immigration consultants.
I would like to know to what extent your college has been successful in grandmothering — as you had promised at that time — unlicensed practitioners to become licensed practitioners, and what is the ratio of licensed versus unlicensed in Canada?
Mr. Murray: Unfortunately, the ratio of licensed to unlicensed practitioners in Canada is a number that is not readily available. We have worked together with Immigration, Refugees and Citizenship Canada to try to come up with a number, but the short answer is, “how long is a piece of string?” There are a great number of —
The Chair: How many members are currently licensed?
Mr. Murray: We have approximately 13,000 licensed immigration consultants and international student advisers now.
The Chair: Thank you. Can you comment on the complaints trend? Is it going up, down or remaining steady?
Mr. Murray: I’m going to defer to my colleague, Michael Huynh.
Michael Huynh, Director, Professional Conduct, College of Immigration and Citizenship Consultants: Thank you for that question. The rate per licensee has been on a downward trend. We’re currently at about 5%, or 5 complaints per 100 licensees. Just to put that in perspective, the Law Society of Ontario would be somewhere around 8% on an annual basis. The College of Physicians and Surgeons of Ontario is about 9%.
When we first opened as a previous regulator, we were at about 10%, or 10 complaints per 100 licensees, and we’re now down to 5. While that may seem like a good-news story, I would like to put in an important caveat that complaints against professionals is not a good indicator of the overall conduct of that profession.
The Chair: How long does it typically take you to resolve a complaint?
Mr. Huynh: It depends on the nature of the complaint.
The Chair: Mr. Murray, I think this question is for you. There is a new section in the division, and you spoke to it — section 56 — which protects directors of your college from damages and liability. How does that serve the customer, which is, in this case, the immigrant applicant?
Mr. Murray: A general indemnity provision for directors, officers and employees of a self-regulatory organization is a very common provision that you would find in provincial legislation respecting provincial professional regulators in every province.
The Chair: Thank you, Mr. Murray. Once again I have to cut you off, but I have to be fair to my colleagues.
Senator Osler: Thank you to the witnesses for your testimony today. I’m going to follow up on some comments that Mr. Jade made in regard to conflicts of interest for the college. Has the college identified any real or perceived conflicts of interest and, if so, how will you mitigate them? Do you anticipate that additional resources will be needed in order to fulfill your roles as a regulator and, in Mr. Jade’s words, a program developer?
Mr. Jade: Regarding the first part of the question, the point is simple. The act was not including the fact that the college should be developing and establishing, in particular, education and training. That’s why we have Queen’s Law and l’Université de Montréal. The issue here is that, in our opinion, this requires a tremendous amount of resources — financial and human — that the college requires right now in order to work on the four other parts — A, B, C — of section 4 before getting there, if need be.
The reason we believe it’s a conflict or may raise issues of conflict in the future is simply because the education is accredited by the college. If the college is accrediting a provider, how would the college be accrediting, developing, delivering and auditing themselves? This is our main concern.
Senator Osler: Thank you, Mr. Jade. I would appreciate hearing from the college as well.
Mr. Murray: Thank you, senator. The mandate of the college is to create standards and regulate the profession in the public interest. Since the inception of the Immigration Consultants of Canada Regulatory Council, the organization has developed and offered educational programs to its licensees.
We currently offer a Practice Management Education program that comprises nine courses, which is mandatory for all new licensees becoming licensed by the college. Also, two years ago, we developed an upgrade program called the Specialization Program for licensees who choose to practise before the tribunals of the Immigration and Refugee Board of Canada. That was in direct response to criticisms in the 2017 report by the House of Commons Committee on Citizenship and Immigration that licensees of what was then the Immigration Consultants of Canada Regulatory Council, or ICCRC, were not able to effectively represent clients in that area.
We have been in the education business for over 10 years now. Our current policy is that when we offer education courses to our licensees, we either do it at no cost — like the Practice Management Education program — or on a cost-recovery basis. So we’re not in this to make money. We’re in this to improve the standards of education.
When the act was first introduced into Parliament, we questioned why education programs hadn’t been in there and weren’t specifically called out in the mandate section, and we were told —
The Chair: Thank you, Mr. Murray.
[Translation]
Senator Miville-Dechêne: I’ll continue in the same vein as Senator Omidvar. What percentage of complaints — or how many in absolute numbers — are justified among those you receive? Are they made public in order to warn consumers?
Mr. Huynh: Thank you for the question. The percentage changes each year, but the answer to whether the complaint has merit is published on our website at the time our disciplinary committee —
Senator Miville-Dechêne: Give me an idea of the last year. What is the percentage of substantiated complaints compared to all complaints?
Mr. Huynh: This year, we published 60 decisions on our website. I don’t know if I can give a percentage, because these complaints were received in different years. I’m sorry, but I can’t give you an exact percentage.
Senator Miville-Dechêne: Could you send it to us in writing?
Mr. Huynh: Certainly.
Senator Miville-Dechêne: The other question is more general. It says here, in the explanation of the change to clause 18, that we’re going to strengthen the complaints system to prevent fraudulent or unethical representations.
So that means it’s a problem. We’ve talked about it. What exactly will be done to avoid misleading the consumer, the immigrant?
[English]
Mr. Huynh: The changes in the complaints process as part of these amendments provide the opportunity for the college to enforce a number of decisions that the discipline committee renders. I think that was an important power that was missing in the previous version of this act. It allows for us to ensure that any order released by the disciplinary committee is actually enforced. Therefore, those licensees who face those disciplinary proceedings know that they will have to comply with the order or otherwise face further consequences beyond just, for example, revocation of their licence, which is the worst we can do up to this point.
Also highlighted is that there are some changes in the complaints process that allow us to be a lot more efficient. That efficiency is actually quite important because our department does receive a number of complaints, some of which are not founded as, Madam Senator, you had mentioned previously. What it allows for us to do is ensure that those who are founded get the attention they deserve. Some of the additional powers and amendments added in this act allow us to better screen these complaints and ensure that we can handle those that are more serious with the appropriate resources.
[Translation]
Senator Miville-Dechêne: Thank you.
Senator Petitclerc: I will also ask my question in French. As you mentioned, clause 18 would grant several new powers. One of these new powers, as I understand it, will allow the College of Immigration and Citizenship Consultants to go onto the private property of a current permit holder to seize documents or items.
Mr. Jade — and Mr. Murray — I’d like to know this: What will be the impact of these new powers and how will this protect the consultants’ clients? So my question is twofold.
Mr. Jade: Thank you, senator. All the other professional orders have the power to access property related to a professional’s work. We agree on that.
However, the only gap that exists has to do with the definition of property. Often, with telecommuting now the norm, the vast majority of consultants work from home. Ownership is therefore not well defined. What does “work-related property” mean, when the law is currently very vague? I’ll give you a comparison that doesn’t reflect reality 100%, but will give you an idea: It’s a bit like a warrant that authorizes the police to seize everything. It’s criminal. It’s on a whole other level in our society.
Civilly or criminally, you have to define what property is. However, this gives a lot of support to customers: In case a consultant puts them in a difficult situation, they will be protected by this part. I don’t know if Michael wants to add anything.
Mr. Huynh: I think we’re on the same page on the issue of mandates and the power needed to seize properties, but first we need to ask whether it’s necessary in the case of section 17.3. Should the College of Immigration and Citizenship Consultants have the power to enter the property —
[English]
The Chair: I’m sorry, Mr. Huynh, but I need to be strict on the time. We must move on.
Senator Dasko: Mr. Murray, you launched into a discussion of your awareness campaigns earlier. I’d like to pursue that topic.
You’re a new organization, so you haven’t been in business for a long time — just over a year and a half — but you said you were launching some awareness campaigns. Can you just describe what those campaigns are, who they are targeted at and what is the goal of the campaign; what specifically are you trying to convey to your target audiences? That would tell me a lot about what the issues are.
Mr. Murray: Sure. Thank you, senator. Each year, the college, and the council before it, conducts significant targeted public awareness campaigns through digital and other media, mostly to advise prospective immigrants and other stakeholders of the services and qualifications of licensed consultants and the dangers of engaging with unlicensed practitioners. As I said, these are digital campaigns. They’re conducted in up to eight languages, based on the statistics we receive from IRCC on the principal source countries of immigrants. We also focus on members of those communities that are within Canada and have media outlets that speak to those groups.
We also carry out general public awareness campaigns for other stakeholders, including parliamentarians. In fact, we have an online session next week to provide updated information about the college, to which you and your staff have all received invitations. We’ll be having another one in February.
We also participate with IRCC and other government agencies, including CBSA and the RCMP, in the annual Fraud Prevention Month initiatives, during which, with our messaging, we focus on immigration fraud.
Our messages are to drive prospective immigrants to consult our publicly available register, which lists licensed consultants and provides a secure email contact to those consultants; warning of the dangers of using unlicensed consultants; and then there is general information on how to work with a consultant. What are the kinds of questions you should be asking? What are the sorts of fees that consultants might offer in connection with provision of their services?
Senator Dasko: So it’s targeted to ethnic communities in Canada as opposed to immigrants or potential immigrants in other countries?
Mr. Murray: No — and abroad.
Senator Bernard: My question is for Mr. Murray as well.
I’m wondering about the population of consultants since the establishment of the college. Have you seen an increase, a decrease or has it remained the same?
Mr. Murray: The population has grown significantly over the last five years. You’ll recall that the college is a continuation of the previous regulator, the ICCRC. It’s a new organization but with a borrowed history.
The population about five years ago had just broken 10,000. Now we’re up to 13,000, so it is growing quite significantly. We have noticed through our surveys of students and others that the interest is primarily driven by the government’s announcements of increased immigration targets, so it’s keeping pace with government policy.
Senator Bernard: Are there non-licensed consultants operating in this space?
Mr. Murray: Yes, there are.
Senator Bernard: Will these amendments address that issue?
Mr. Murray: They will assist greatly in addressing unlicensed consultants, both in Canada and abroad.
One of the major amendments that we hope to achieve in this session is the ability to enter into information-sharing agreements with government and other agencies, both at home and abroad. In the context of offshore unlicensed practitioners, we need to cooperate with foreign governments. Many of those, as well as provincial Canadian governments and government agencies, have restrictions on who they can talk to and share information with. Our advice is that obtaining the information-sharing agreement powers that are in this series of amendments will greatly assist us in making contact and building relationships with those.
Senator Bernard: What’s in place to protect potential immigrants from those non-licensed consultants?
Mr. Murray: The government, IRCC, Global Affairs Canada, the Canada Border Services Agency and the RCMP are all able to enforce the offence sections in the college act, which make it a quasi-criminal offence to hold yourself out as a licensee when you’re not.
We don’t have that power. That can only be exercised by those other agencies. They do exercise it, not as often as we would like, but they do exercise it.
Senator Bernard: Thank you.
The Chair: Wonder of wonders, we have roughly 10 minutes left. I will go back to Senator Dasko’s unanswered question, when I had to cut you off, Mr. Murray. Can you recall the question?
Mr. Murray: No. Would you repeat it, please?
Senator Dasko: That’s fine.
Please finish describing the awareness campaigns that you have and whether you’re able to do campaigns in other countries and who those are targeted at. I think you described the message already.
Mr. Murray: Yes. The messaging is geared towards directing prospective immigrants to our public register so they can identify and perhaps engage a licensed consultant to assist them.
In terms of outreach to other countries, we have built relationships with Canadian visa offices in India. We’re talking with officials in other countries. We met recently with Australia and New Zealand, for example, to discuss how we can share information about unauthorized practitioners — because they have many of the same issues as we do — and how we can work on more comprehensive messaging that we can put out and have a broader reach through their organizations as well.
As I say, it’s early days. We’re moving ahead as quickly as we can. Again, the ability to enter into information-sharing agreements will not only help address unauthorized practitioners, it will help us reach prospective immigrants in offshore jurisdictions.
Senator Dasko: The consultants in other countries, they’re not licensed by Canada, are they?
Mr. Murray: They are not, no.
Senator Dasko: In fact, they’re all operating freely in those other countries. I would think that would be a real challenge because prospective immigrants may be taken advantage of in those countries.
Mr. Murray: It’s interesting, because many countries that are principal sources of immigrants to Canada see those immigrants as almost a domestic resource, so they’re anxious to ensure they’re not taken advantage of. They’re anxious to work with us and others to address fraudulent consultants in those jurisdictions which, again, is our target as well.
Senator Dasko: Thank you.
Senator McPhedran: Thank you for being here with us today.
I want to take a slightly different approach with my question, and that is to ask about the people who are deleteriously affected by improper, fraudulent and exploitative conduct like those that your college is addressing. What is there for them?
How, if at all, does the college address documenting the harms, looking for a remedy for the harms, using the information to better inform your own processes within your jurisdiction?
Mr. Huynh: Even through the complaints process that we receive from existing consumers who have had issues, we have two modalities: We have a dispute-resolution process where we try to work and have the process informed. We take the concerns, as well as the information received from complainants, and try to use that in a way that addresses some of the issues that they’ve experienced, in some cases providing restitution to those individuals.
In other cases, sometimes if it’s more dire, we do publish the decision. That decision provides that individual the opportunity to use that as a basis, for example, to resubmit an application on the basis of the negligence of their consultant.
The other aspect to highlight, as you mentioned, is the information that we receive about complaints does inform our education and our training to ensure that those types of mistakes or errors don’t also happen.
There’s also a forward feedback process where we try to use that to ensure that those types of issues that come in through our complaints process don’t happen again.
Senator McPhedran: I have one follow-up question.
Am I understanding correctly that, generally speaking, the decisions are not public? Second, is there any way for people trying to determine if they’re working with a legitimate, trustworthy agent to check to see whether there’s been any kind of a concern or procedure around that particular agent?
Mr. Huynh: The decisions of our disciplinary committee are published on our website. The public can access that to determine if either the licensee they are currently working with, or one they intend to work with, has faced disciplinary proceedings or is in the process of going through the disciplinary process.
Not every complaint results in a finding of misconduct. There are situations with minor complaints where we find it far more efficient and better for all parties involved that we resolve it through a non-adversarial process.
Senator Burey: Good morning. Thank you for being here and thank you for this very important work.
I’m following up on Senator Dasko’s question on awareness. How are you measuring the effectiveness of these awareness initiatives?
Mr. Murray: Thank you. Yes, as most of our initiatives are digital, we do track — I’m old enough that I don’t know the terminology — the hits they obtain.
We also track traffic on our public register which, as I said, is the focus of most of our public awareness, getting prospective newcomers to go on the register, identify a consultant who does what they think they need, speaks their language and is located in an area that is convenient to them. We track that.
We do see spikes in traffic on the register when a campaign is launched and shortly thereafter. That’s how we can tell that it is working, or if it’s working.
Senator Burey: Thank you.
The Chair: I have two final questions, both of Mr. Murray. Do you believe that your licensed immigration consultants are qualified enough to represent immigrants at tribunals and court hearings? These are life-changing moments that will wipe out the future of an individual, or reclaim it.
Mr. Murray: The short answer is, yes, I do. We have significantly revamped both the prerequisite education for new consultants and developed our Specialization Program to focus on immigration consultants who elect to represent clients before tribunals.
Those programs have been very well received. We’re confident that they have significantly upgraded, in the case of prerequisite education, new consultants and, in the case of the Specialization Program, existing consultants who choose to do that work.
I should add that, as of July 1, any licensed consultant who has not completed the Specialization Program or the new prerequisite education program — so the graduate diploma program offered through Queen’s and l’Université de Montréal — will be prohibited from representing clients before tribunals, so that is another significant advance.
The Chair: Thank you. In the last minute of this meeting, let me pose a question to you about immigration consultants outside of our jurisdiction.
I was recently in the Punjab. Immigration consulting is the growth business in the Punjab. I met with our consul general. There’s a lot of work they are undertaking on educating the public to deal with either licensed immigration consultants, or directly with the Government of Canada. Frankly, that is, I believe, the preferred route, but there it is.
Have you considered setting up a sister organization with the appropriate authorities in hubs of immigration in India, particularly in the Punjab?
Mr. Murray: Michael, do you want to talk about our relationship with the Punjab?
Mr. Huynh: I can quickly update.
We understand, as John mentioned, there is an interest in foreign jurisdictions to protect their foreign nationals, some of whom decide to immigrate, some decide to migrate. There is an opportunity for collaboration with certain states. I appreciate not every state will follow through with the enforcement.
With a sister organization, the challenge is always going to be what is our enforcement jurisdiction in those countries? I do think the information sharing is a very useful tool that’s entrenched in the proposed amendments.
We do need to be able to share information, not only with some foreign jurisdictions, but as well as IRCC and other federal and provincial bodies that also have the ability to make decisions on, for example, the number of temporary residents who come in through those countries.
The Chair: Thank you, Mr. Huynh.
Witnesses, thank you so much for your presence and for the answers to all our questions. I’m sure there would be more questions, if we had the time, but you have strengthened our understanding of the matter before us.
Senators, we now move on to our second panel on Division 19, which deals with the amendment to the Citizenship Act. I note that Mr. Abramovich, who is with us today appearing on behalf of the Canadian Immigration Lawyers Association, has also prepared remarks on Division 18. We can continue the line of previous questioning with him.
We welcome Mr. Abramovich, who is a member representing the Canadian Immigration Lawyers Association; and Daniel Bernhard, Chief Executive Officer with the Institute for Canadian Citizenship.
I now invite each of you to provide brief opening remarks, followed by questions from our members.
Lev Abramovich, Member, Canadian Immigration Lawyers Association: Honourable senators, I’m appearing today on behalf of the Canadian Immigration Lawyers Association. We were specifically asked to comment on amendments to the College of Immigration and Citizenship Consultants Act. I’ll primarily keep my comments to Division 18.
Prior to addressing the amendments, I would like to provide some background with respect to the consultancy body, which I believe is important in order to understand this new regime and what the college is ultimately responsible for.
The industry itself began to emerge in the 1970s out of a legislative vacuum, and that vacuum has resulted in unlicensed practice before the Refugee Protection Division as well as Immigration, Refugees and Citizenship Canada. It has historically been plagued by low practice standards, negligence and outright fraud.
Legislative efforts resulted in the introduction of a regulatory body in 2003. Unfortunately, that changed little. In fact, the introduction of the official term “consultant” in the immigration context has further resulted in the proliferation of ghost consultants, as most members of the public were not able to discern whether the person advertising services was licensed or not. This problem continues to be very real. The ghost consultancy class continues to dominate this industry, in my submission.
In fact, a recent report from the Ho Chi Minh City visa office noted that while only 5% of applicants declared paid representatives, at interviews 47% admitted to hiring an agent. This is a real problem, and I’m not sure the college is quick to deal with it or can deal with it.
This is the third self-regulation attempt after two previous failures that resulted in undermining our immigration system as well as public trust, and this attempt is, in my view, on the back of lobbying efforts that overrode concerns expressed by the immigration bar.
The position before you is that additional regulatory powers are necessary in order to avoid past failures. In my view, this is a gross oversimplification. Nothing prevented previous bodies from disciplining members or eliminating perverse incentives, such as fee-sharing arrangements with non-licensees, which resulted in the abuse of foreign students. In addition, there were problematic recruitment schemes that abused foreign workers that were not dealt with and continue to be alive and well, unfortunately. Nothing prevented the previous regulators from raising the practice standards.
There are currently around 13,000 consultants. Around 4,500 were grandfathered from the previous Wild West regime, without much training.
I have personally recently filed a complaint against the consultant, and I have yet to get an acknowledgement. A colleague of mine informed me that she has been waiting for over a year to get an acknowledgement of his complaint despite numerous foul-ups. When it comes to complaints, what you see is a fraction of the reality on the ground, as most immigrants are not aware of how poorly their application was handled and sometimes are provided with bogus excuses with respect to their refusal.
At the same time, as noted before by this committee, refugee law in particular can be a matter of life and death. I’m currently prosecuting a claim in the Federal Court with respect to negligence. The standard is incredibly high, and my client has potentially lost the opportunity to immigrate to Canada, and he may have to stay in the Gulag that Putin has created in Russia, even though he does not support the Gulag.
With respect to the amendments, I will briefly note that the stakes are very high, and there’s significant political liability attached to this new regime. In my view, we must note this liability because it may not necessarily create incentives that are in the public good.
With respect to section 56, which creates immunity for damages with respect to current and former directors, employees and officers, this concept is typically grounded and applied to judicial administrative decision makers and is grounded in an attempt to protect independence, impartiality and to facilitate the proper and efficient administration of justice.
It is unclear why such immunity would be extended at this stage, given what we have seen before. Such immunity, in my view, must be earned. It may, in fact, have the opposite effect, given what we’ve seen before.
Finally, while Mr. Bernhard will address amendments to section 28.4 of the Citizenship Act, which deals with what we describe as AI decision-making, I note that the implementation of AI technology poses serious issues with respect to transparency and accountability. Both are hallmarks of a well‑functioning democracy.
In my view, our society faces numerous challenges, and transparency and accountability are very important when it comes to AI introduction.
Those are my opening remarks. Thank you.
The Chair: Thank you, Mr. Abramovich. Mr. Bernhard, please go ahead on Division 19.
[Translation]
Daniel Bernhard, Chief Executive Officer, Institute for Canadian Citizenship: Madam Chair, members of the committee, thank you for inviting me to testify today on the changes proposed by Bill C-47.
I will make my presentation in English, but will be happy to answer your questions in French afterwards.
[English]
The Institute for Canadian Citizenship is an independent charity that facilitates and encourages newcomers to become citizens, not just in their passports, but in their hearts and habits. We operate in every province and territory. Our work is an act of service, not just to immigrants but to all Canada, because when newcomers believe that “this is my place” and that “these are my people,” they contribute their full talent and energy to our shared success. With the best of the world on our team and contributing to their fullest potential, I believe Canada can be unstoppable.
Our main program is the Canoo access pass, which currently gives over 150,000 newcomers one year of free access to over 1,400 of Canada’s best culture and nature attractions. For context, through Canoo, we now serve more people than all other IRCC-funded settlement services combined, and I’m proud to say that we do so for less than 0.1% of the cost.
Today, I would like to discuss clause 305 of the bill, which contains a provision that would add, as Mr. Abramovich said, the following text to the Citizenship Act:
. . . an electronic system, including an automated system, may be used to process an application, proceed with an examination or make a decision or determination under this Act.
To be clear, this would allow IRCC to fully delegate the adjudication of citizenship applications to a computer, seemingly without human intervention of any kind.
We do support modernizing the citizenship program to expedite processing. We host over 60 enhanced citizenship ceremonies annually, and many new citizens tell us they’ve waited over two years to take the oath. Processing times, however, are thankfully improving, and it is our opinion that a move to full automation will be costly and highly error-prone. It will result in even more litigation than IRCC is already facing and will restore a layer of human intervention, only this time it will be by a judge.
It’s important to remember that automated decision systems seldom leave behind logs of their reasoning that can be scrutinized by a judge upon appeal. Not even Google can explain how its AI reaches decisions. In fact, in April, Google CEO Sundar Pichai told “60 Minutes” that:
There is an aspect of [AI] which we call . . . a “black box.” . . . You don’t fully understand. And you can’t quite tell why it said this, or why it got [something] wrong. . . .
The fact is, AI and automated decision systems are not the right tool for this job. Those tools cannot give would-be Canadian citizens the fair, reasonable and transparent treatment they deserve.
With processing times already declining, we see no need for this change.
This measure requires far more careful and nuanced consideration, so I encourage you to have it removed from the bill so that you can more fulsomely debate it in both houses as part of a stand-alone update to the Citizenship Act. Since I do not believe this particular provision has not been debated on the House floor and was not discussed at the House of Commons Finance Committee’s review of Bill C-47, it therefore falls upon the Senate to provide much-needed sober second thought.
After all, the real problem regarding Canadian citizenship is not the lack of mechanized decision making in the application process but the precipitous decline in the share of permanent residents who are seeking citizenship at all. In 2001, three quarters of permanent residents became citizens within 10 years. By 2021, that number was just 45%. That is a 40% relative decline in just 20 years.
If we’re looking to innovate around citizenship, we suggest focusing on creating pathways to citizenship that restore the desirability of becoming Canadian in the first place. To that end, we submitted a forward-thinking proposal to IRCC last year that would give citizenship candidates the option to skip a written test in favour of an experiential curriculum via our Canoo access pass, which we believe would satisfy the requirement to show “adequate knowledge of Canada” under the act. We think that could be done within the existing legislation. We are eager to road test it and other ideas in collaboration with IRCC as a trusted and experienced innovation partner, with direct ties to hundreds of thousands of would-be citizens and a strong record of cultivating a spirit of belonging upon which citizenship and our future depend.
Thank you very much.
The Chair: Thank you, Mr. Bernhard. Our first question will go to the deputy chair of the committee. As it was in the previous panel, colleagues, you will have three minutes each, including the question and the answers.
Senator Cordy: The questions I had planned to ask are now out the window, because I was interested in something you both commented on, which is the use of AI or computers. Mr. Bernhard, you spoke about there being no logic for the reason — you can’t look it up and say what the reasons were that the clerk noted when they were going to accept or decline the citizenship or the bringing someone into the country. Mr. Abramovich, you spoke about the same thing, which is the challenge of accountability with the introduction of AI.
Yesterday, this question was asked by a number of senators to the witnesses from the government, who said, “Well, don’t worry. It’s just a matter of saying which part of the department we will send these particular applications to.”
I wonder if you could both comment — which will use my whole time, I know, but I think it’s really important — on a little bit more detail on what we should do.
Mr. Abramovich: My primary job is to litigate at the Federal Court. That’s what I do. When AI was introduced in the processing context, it was introduced secretly. We didn’t really understand how it worked, and it was highly problematic from a procedural fairness standpoint, because we didn’t know how to structure applications, how they were being reviewed and so on.
When it comes to the Citizenship Act, there is no doubt that is going to be ultimately adopted with respect to IRPA and other acts. We want accountability in terms of stakeholder consultation, transparency with respect to programming and to understand why the system has been introduced. It is maybe not that problematic in the context of the Citizenship Act, but once you bring it into IRPA, you’re facing a whole different game that we need to be prepared to openly talk about.
Mr. Bernhard: I would just add that this seems like a solution in search of a problem, to some extent. The delays in processing times have been severe, especially over the pandemic, but they are going down, like I said, and processing volumes have increased by something like 200% in recent months. Applicants are now speeding through the system at a much better pace.
To the extent that we’re looking for ways to expedite the citizenship process, there are other ideas that we have, like pre‑qualification for certain things in the way you prequalify for a mortgage because you need it very fast at the very end.
There are ways for us to speed this up that don’t require us to delegate the authority of the Government of Canada to these machines about which even the smartest and most sophisticated companies in the world say they don’t know how they work and how they come to their decisions.
If that’s the standard we are looking to, we have reason to believe that none of our public servants, no matter how esteemed, or their contractors would be likely to do better.
The Chair: I have a question for each of our witnesses.
Mr. Abramovich, you noted that providing the directors of the college with protection and liability is a bit too soon for a college and a regulator still in the process of maturing. Mr. Murray’s response to that was that such liability protection is usual and standard.
What is your response to his response to my question?
Mr. Abramovich: It is perhaps usual and standard, but not for bodies with such a catastrophic record. Let’s be clear: This might be a new college, but it is a continuation of a regime that has been absolutely disastrously managed.
The last time the body was dissolved, there were about 1,500 complaints. Now, the college is telling us that the complaints are going down and the standards are being raised. Let’s give this a few years and then perhaps adopt it. It’s standard for judicial and administrative bodies. This is neither of those, in my submission.
This may be appropriate once we have a track record. Right now, in my view, this would create a perverse incentive. We need more accountability, not less.
The Chair: Mr. Bernhard, you’ve noted that processing times are dropping. That’s good to hear. Finally, we hear some good news. My question is about citizenship uptick.
You noted a precipitous decline in citizenship uptick. Do you believe this machine-assisted application process will have any impact on citizenship uptake?
Mr. Bernhard: I don’t think it will have any positive impact on citizenship uptake. To the degree that it has any impact, it will likely be negative in terms of rendering the process of dealing with the Government of Canada even less personal and even less savoury.
The Chair: What is your reading of Division 19 in terms of what a citizenship judge now has the authority to do? Is it possible or not possible for the judge now to decide to provide citizenship through a click on your computer?
Mr. Bernhard: This is a change that was already provided in regulations previously. That was posted a couple of months ago and raised quite a bit of uproar in the media, and that it would allow you to skip the Oath of Citizenship and simply click “Yes, I accept.”
It seems that this bill brings some changes to the Citizenship Act that might defend against anyone saying those types of regulations are improper by allowing the minister to designate that certain forms can be electronic and certain payments can be electronic and whatever.
I don’t believe that the attestation is a good idea, but the other parts are relatively innocuous.
The Chair: Hopefully, someone else will pick up this line of questioning.
Mr. Bernhard: Thank you, senator.
Senator Osler: I have two questions, one for each of the witnesses. Thank you both for your testimony today.
Mr. Abramovich, this committee has heard of issues with offshore immigration consultants. In your testimony, you had mentioned that in Ho Chi Minh City, off the record, 47% of people admitted to using an immigration consultant. Does the association have any recommendations in regard to these offshore immigration consultants and how to better protect people wanting to come to Canada?
And Mr. Bernhard, we’ve heard through Mr. Abramovich concerns regarding oversight and accountability of the College of Immigration and Citizenship Consultants. Does the institute have an opinion or thoughts on how to better provide oversight and accountability to the college?
Mr. Abramovich: With respect to offshore consultants, there are no easy solutions. The Canadian Bar Association, which provided a number of submissions to the committee prior to the introduction of the college, basically recommended that consultants be supervised for now. The only authorized representatives would, therefore, be lawyers, and we’re going to eliminate the consultant class due to severe issues — mind you, this is not a competitive advantage type of thing — and that would just automatically tell everyone who is hiring a consultant that they’re not hiring a lawful representative.
What I propose is that we actually put some research behind prosecuting, first and foremost, the people who are in Canada. The RCMP needs to be involved; CBSA needs to be involved. We maybe use civil forfeiture laws, because there is a lot of fraud happening here on our soil. Once we start tackling the problem here in greater depth, perhaps we can show the immigrants that, ultimately, the people they’re working with are not licensed. This will spread awareness through creating legal precedence, publicity and so on.
In my view, it is extremely tough to tackle practitioners who are abroad. You’re not going to bring an injunction in India. It’s going to cost you $50,000 or $100,000, and it will not be enforceable.
Mr. Bernhard: There are many opportunities to make the official process simpler so that a consultant might not be required. The fact that so many people believe that they need to draw on outside advice in order to have a chance of making it through the immigration system speaks to the complexity of the process.
There are over a hundred pathways to permanent residence in Canada, and which one you pick is very consequential. If we can provide that support, education and simplification through the official process, then I think the need for unscrupulous consultants will decline.
[Translation]
Senator Mégie: Mr. Bernhard, we’ve talked about the possibility of fraud, but until now, immigration applicants have been receiving paper forms. These forms take a long time to be processed by the authorities, and applicants are often sent a reply telling them that the form has expired. Applicants must then fill it in again. When they fill it in, it’s the same questions, except for the form number.
Would filling in the forms online get around this problem, or could it make things worse? You can change everything with a click, really. What do you think?
Mr. Bernhard: In general, I support technological changes to modernize application processes. Electronic forms are very efficient. If we keep the verification processes for all documents and certificates, we won’t compromise the integrity of the system. Now we’re talking about something else: electronic adjudication. That’s something else entirely. So, it’s all very well to submit documents online, and I fully support that, but I hope there will be a human being reading them and making the decision, at the end of the day.
Senator Mégie: Many candidates are not comfortable with electronics. It’s not a question of age — though sometimes it is — but some know nothing about electronics. How will they apply? We can’t ask someone else to write it for them — or maybe we can, I don’t know. Have we thought of a way to help these people? If not, they’ll be pushed aside and that would be unfair and unjust to them.
Have we thought of that?
[English]
Mr. Abramovich: It is an issue. You can ask for an exemption with respect to certain types of applications, to apply on paper. The process doesn’t work well, but it is available.
[Translation]
Senator Miville-Dechêne: Mr. Abramovich, if clause 19 passes, there will be collection and use of biometric information, personal information of clients. These clients may have recourse to a lawyer. As part of your work, you advise and support immigration lawyers. How will you advise them on respecting professional secrecy and file confidentiality when collecting personal information?
[English]
Mr. Abramovich: Thank you, senator. At any point when somebody submits an immigration application, personal information is collected, including biometric information. Applicants understand that. So far, IRCC has done a reasonable job of protecting that information.
The world, unfortunately, is a place that faces many challenges in terms of security, but so far, the system has worked well. Basically, in order to submit an application, you must disclose personal information. There is no way around it.
Obviously, there are security commissions that also look into things like this, but so far from my experience, the system works reasonably well. There have been a couple of glitches with IRCC sending personal information out by mistake, but on the whole, they have done pretty well at protecting it.
Senator Miville-Dechêne: You would say there are exceptions.
Mr. Abramovich: There are exceptions. We’ve heard about the Afghan program and how disastrous that played out. We heard about permanent residency cards being mailed to the wrong address. We’ve heard about a few issues.
The system on the whole is talking about AI, but it is quite archaic in many ways. It could use modernization in other ways. On the whole, for the number of applications that they receive, I give them credit for handling personal information with care.
The Chair: It’s good to hear some good news there.
Senator Bernard: My question is for both witnesses. Thank you for being here. You’ve both talked about AI. You’ve both indicated that you don’t think this is the direction the government should be going in at this time.
The question of bias came up with a panel we had yesterday, bias in AI, especially against racialized people and other vulnerable populations.
I would appreciate it if you would both comment specifically on the issue of bias and the use of AI in this work, and if you have recommendations that you would propose to us. Thank you.
Mr. Abramovich: I can share. I can briefly address the issue of bias. It is a real issue. Bias is created when you dehumanize a system and where there is very little interaction between applicant and officer, and the officer is looking at statistics.
There are a few offices that are particularly problematic. Accra, Ghana is, in my view, the worst when it comes to bias. Student visa acceptance rates are very low. We routinely litigate them in Federal Court. Many applicants, unfortunately, don’t have the funds to litigate.
Let’s go back 30 or 40 years ago. When an officer meets with an applicant, he can really understand his story and why he’s coming to Canada, in this case, what student program he would be taking and so on. When you remove that human interaction, just look at the statistics. You introduce AI tools. Bias can be entrenched. That’s a real problem. That’s a concern, because I don’t know how you necessarily program bias out if all you’re doing is looking at algorithms and statistics. Statistics don’t always tell the whole story.
Mr. Bernhard: Artificial intelligence is a misnomer. It’s not really intelligent. It’s more like pattern matching. What they’ll do is say, “Okay, here are all the people that we’ve accepted. Here are all the people who have been rejected.” What do the ones who are accepted have in common? What do the ones who are rejected have in common?
In an employment context, they have found that this ends up just reinforcing — if you hired all men, for example, in your shop, then the AI would identify men as being suitable candidates because that’s what the humans did before.
Again, I would just say what is this for? In the citizenship context especially, application times are going down. As Mr. Abramovich said, personalization is the key. This is often people’s first interaction with Canada. We want to make sure that it is a positive one. If the situation is already improving, I am not sure why we need to introduce such a contentious measure.
[Translation]
Senator Petitclerc: Ideally, my question would be about clause 18. Mr. Abramovich, with clause 18, we’re generally trying to find measures to ensure that there will be no fraud and that we’ll have increasingly rigorous standards for consultants. Is this where we should be putting our energies? Shouldn’t we be ensuring that application processes are more efficient, simple and accessible for candidates, so that we need fewer consultants? I’m not saying that’s the goal. Does that make sense?
[English]
Mr. Abramovich: Senator, I agree with everything you’ve said. You’re absolutely right. The more complex the system is, the more difficult it is to navigate, the more difficult it is for an employer to hire a foreign worker or for somebody to transition from, let’s say, being on a postgraduate work permit to permanent residency, and the more likely fraud is going to be introduced. Our system right now is far too technocratic. It is far too complex. It is far too inhumane, frankly, where you have to navigate various portals that are working quite poorly and so on.
Quite often, it comes down to employer participation. Employers are often disincentivized because of the complexity and the time-consuming nature of them supporting an employee.
I agree with you a 100%. If you simplified it, then you would absolutely reduce a great deal of fraud. You wouldn’t need as many consultants or lawyers. You shouldn’t need a lawyer to navigate something like an employer portal, for example.
[Translation]
Senator Petitclerc: Mr. Bernhard, do you have a comment on this matter?
Mr. Bernhard: I agree with both of you that simplification is the best option.
Senator Petitclerc: Thank you.
[English]
The Chair: I have two final, short questions before we go in camera, the first to Mr. Bernhard. Did I hear you say that citizenship applicants use immigration consultants? Please tell me that is not true. That is the simplest application you can put in.
Mr. Bernhard: Mr. Abramovich can say better than I whether his clients will ask for lawyers to prepare citizenship applications, but I believe people get assistance with them. I have a relative, an in-law, who recently became a citizen and, through his employer, had assistance to do it, much like people get assistance to file their taxes, even when their taxes are fairly straightforward.
The Chair: Mr. Abramovich, in this brave new world that Canada is embracing of mechanized decision making — artificial pattern matching as you call it, Mr. Bernhard — is Canada ahead of the pack in terms of the jurisdictions where we always compare ourselves too — Australia, New Zealand — or are we following their lead? If so, what lessons can we learn from their experience?
Mr. Abramovich: I’ll briefly address your first question.
The citizenship application process is relatively simple. I find that very few clients utilize lawyers or consultants for it. They will bring a lawyer consultant when possibly there are issues with respect to credibility and so on.
With respect to being ahead or behind, I’m not sure I am fully qualified to answer that. I will say, from my clients’ experiences, a lot of people are frustrated by the lack of transparency; by the fact that they often have to hire a lawyer to basically sue the government to get the decision; by requests that are with respect to documents that were provided years ago; by confusion over how long it will take for you to get permanent residency. If you were in Accra, Ghana, it will take three years. If you’re in Austria, it will take four months.
Many immigrants, in my view, are now coming not best equipped for success. They’re coming, if you will, with a bit of a chip on their shoulder. Does Canada really want me? Why am I navigating this maze? I think very little discussion is devoted to that, to the human aspect of immigration. It’s not all numbers, job offers and this sort of technocratic matrix that people navigate and we say the economy is going to be successful based on that.
Those are my remarks on that.
The Chair: It is, indeed, nation building, I believe. That’s what we should be focusing on.
Mr. Abramovich and Mr. Bernhard, thank you so much for your participation in our study of these measures. Thank you for sharing your perspectives with us.
Colleagues, we will now go in camera.
(The committee continued in camera.)