Naming Policy: For Client Identification Purposes

This section contains policy, procedures and guidance used by Immigration, Refugees and Citizenship Canada staff. It is posted on the Department’s website as a courtesy to stakeholders.

This policy provides guidance to officers about how to identify and record a client’s name. This policy applies to both the citizenship and immigration lines of business.

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Recording names

Accurately recording the names of all Immigration, Refugees and Citizenship Canada (IRCC) clients will

  • ensure, wherever possible, that the name is recorded in systems of record using the name that is presented on the client’s documentation
  • ensure that IRCC documents are issued with the correct name
  • foster consistency across the department on name-recording practices in order to enhance program integrity and ensure clarity for IRCC partners
  • ensure that client name records contain an auditable name “trail”

It is important to note that

  • a client’s name should be identified and recorded exactly as it is presented on the documentation provided by the client, and decision-making about a name should be based on the most reliable documentary evidence available
  • officers will not re-order or alter names as displayed on original identity documents in a system of record so as to simplify identifying a client in a name search, or so a name will appear differently on IRCC documents
  • if a scenario occurs where the client has no documentation (as is sometimes the case with overseas resettlement and asylum cases), the officer may use their discretion in identifying and recording the name

Principles

This policy aligns with Government of Canada legislation, policies and directives that guide or impact identity information management. When developing and managing programs, processes and tools that impact identity management, officers should consider the following IRCC principles:

  • IRCC is an authoritative source of identity management; however, IRCC does not “create” identities, and names are identified based on the most solid evidence of identity available
  • The identification and recording of a client’s name should be done in a consistent and transparent manner
  • The identification and recording of a client’s name should not impede travel
  • The identification and recording of a client’s name should not impede the client’s integration into Canada, and where possible, should facilitate integration
  • A single and auditable client identity continuum should exist per client
  • IRCC will remain a trusted source for client identity information
  • Identity information management improves client service and program integrity

Operational considerations and exceptions

This policy is intended to introduce a degree of uniformity across the department and thus has introduced principles intended to foster consistency in the identification and recording of names. This policy acknowledges that exceptional naming-related situations have generally been dealt with on a case-by-case basis and that in many instances, it has been up to the officer to determine how to identify and record a name without formal guidance. Instructions relating to exceptional cases will be published in operational bulletins and/or program delivery instructions. Given the nature of IRCC business, officers should seek to follow, where possible, the International Civil Aviation Organization (ICAO) guidelines contained in ICAO’s “Doc 9303” on Machine Readable Travel Documents.

For clarifications or questions related to applying this policy to exceptional naming-related situations, please contact IRCC.

Commencement and application

This policy commences on January 1, 2013.

This policy supersedes all other policies issued by IRCC on this topic before the commencement of this policy. It is a “day forward” policy in that every time a new service is being requested by an existing client or a new application is made, this policy shall apply. This policy shall not apply retroactively to cases that were addressed or initiated before its commencement.

Definitions

Establishing a name record:
The act of recording the name associated with a client.
Name:
Consists of the series of letters in Roman alphabet by which a client is identified

Exception to the naming policy

IRCC will, in the specified circumstances and where required evidence is established, change a client’s given name(s) on departmentally issued documents to a new name requested by the client. The purpose of this exception is to accommodate clients who are unable to obtain a name change on the required documents issued by the province or territory in which they reside and by their country of nationality.

The specified circumstances are the following:

  1. where a permanent resident is not able to obtain a name change on the required documents in both of the following cases:
    1. under the provincial or territorial legislationFootnote 1  where they reside
    2. from their country of nationality
      1. for reasons beyond their control (for example, war or natural disaster) or of undue hardship (for example, foreign residency or financial requirements to obtain a name change are too onerous to be met by them)
      2. for the reason that they are stateless
  2. where a protected person (including a permanent resident who has protected person status) is unable to obtain a name change on the required documents under the legislation in the province or territoryFootnote 1  where they reside
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