Internal Audit of the Immigration Program at the Canadian High Commission in New Delhi, India

Internal Audit & Accountability Branch
June 2016

Table of Contents

Executive Summary

Background

Canada is represented in India by a High Commissioner located in New Delhi and Consul Generals at three other offices in India (Mumbai, Bengaluru and Chandigarh). The Immigration Program at the High Commission of Canada in New Delhi is managed by an Immigration Program Manager who is also the South Asia Area Director. The Canadian consulates in Bengaluru and Chandigarh also provide immigration program services. The Chandigarh visa office was opened in the fall of 2004 and the Bengaluru visa office was opened in September 2014.

The New Delhi visa office also provides services to the Kingdom of Bhutan, the Federal Democratic Republic of Nepal, the Islamic Republic of Pakistan, and the Islamic Republic of Afghanistan. The New Delhi visa office is comprised of the following: 21 Canada-Based Officers (including the Program Manager; two Canada Border Services Agency officers; a Regional Medical Officer and 96 Locally-Engaged Staff. The visa office delivers the full suite of Immigration, Refugees and Citizenship Canada programs.

As Area Director for South Asia, the Program Manager is responsible for the performance management of the Program Managers at these locations, among other duties.

Audit Objective and Scope

The audit objective was to assess the management control processes and activities in place to support the delivery of the immigration program at the High Commission of Canada in New Delhi. Specifically, the audit focused on the following elements:

  • Governance, clarity of roles and responsibilities and promotion of values and ethics;
  • Risk management and quality assurance practices to support program delivery; and
  • Internal controls over program administration and operational activities.

The original terms of reference for this internal audit included a scope period from October 1, 2013 to September 30, 2014. Controlled document / forms management testing was performed during the audit site visit to New Delhi, India in February 2015. New information was taken into account for a second site visit in February 2016.

The audit did not include an assessment of the visa office cost recovery function, as this work was performed by the Immigration, Refugees and Citizenship Canada Internal Control Compliance team during their site visit to New Delhi in February 2015.

Conclusion

The management control framework in place to support the delivery of the immigration program at the Canadian High Commission in New Delhi is in place and working as intended. Visa office program staff roles and responsibilities were defined and communicated and resources were planned to support program delivery. Values and ethics expectations were documented and promoted. Staff had taken mandatory training and signed the Code of Conduct in fall 2015. Risk management and quality assurance practices supported immigration program delivery and internal controls over program administration and operational activities were working as intended.

Two areas for improvement were noted. The first relates to enhancing in-year reporting and annual reporting on fraud and related verifications and activities. The second relates to rotating staff in and out of the Risk Assessment Unit to enhance program integrity knowledge at the mission.

Management has accepted the audit findings and developed an action plan to address the recommendations.

Background

Introduction

Canada is represented in India by a High Commissioner located in New Delhi and Consul Generals at three other offices in India (Mumbai, Bengaluru and Chandigarh). The Immigration Program at the High Commission of Canada in New Delhi is managed by an Immigration Program Manager (IPM) who is also the South Asia Area Director. The Canadian consulates in Bengaluru and Chandigarh also provide immigration program services. The Chandigarh visa office was opened in the fall of 2004 and the Bengaluru visa office was opened in September 2014.

As South Asia Area Director, the IPM is responsible for overall coordination, including the performance management of the IPMs at the following locations:

  • Bengaluru, India;
  • Chandigarh, India;
  • Colombo, Sri Lanka;
  • Islamabad, Pakistan; and
  • New Delhi, India.

The New Delhi visa office also provides services to the Kingdom of Bhutan, the Federal Democratic Republic of Nepal, the Islamic Republic of Pakistan, and the Islamic Republic of Afghanistan. The New Delhi visa office is comprised of the following: 21 Canada-Based Officers (including the IPM); two Canada Border Services Agency officers; a Regional Medical Officer and 96 Locally-Engaged Staff. The visa office delivers the full suite of Immigration, Refugees and Citizenship Canada (IRCC) programs.

The Canadian visa offices in India receive applications from 11 Visa Application Centers (VACs) - 10 in the various states and regions within India and one located in Kathmandu, Nepal. Applicants submit their temporary resident application at the nearest VAC. These applications are delivered daily to the relevant Canadian visa office for processing. An increasing number of temporary resident applications are received through the E-Application channel.

Operating environment

The operating environment for application processing is difficult and complex, given the relatively high perception of fraud and corruption in the region based on the Transparency International Corruption Perception Index. With increasing temporary resident demands to travel to Canada, increasing permanent resident levels, and no incremental resources for the opening of the office in Bengaluru, the visa office is operating at full capacity. In addition, immigration officials who work in New Delhi live in a city that has the worst air pollution of any major city in the world. Finally, the Information Technology platform and infrastructure has negatively impacted the speed of the Global Case Management System (GCMS) – the information technology system used to process applications.

From November 2015 to March 2016 the three visa offices supported the Government of Canada’s efforts related to the Syrian Refugee Project. During this time period eight Canada-based officers and one Locally-Engaged Staff member performed temporary duty assignments to support refugee application processing, a total of 50 weeks of staff time. This had an impact on the immigration program at all three visa offices in terms of staff morale and workload pressures.

Immigration program staff conducts their work in accordance with the Immigration and Refugee Protection Act, other relevant Acts of Parliament, departmental guidance, policies and procedures as well as a suite of well documented and regularly updated internal administrative controls that have been put in place to support application processing.

Audit Objective, Scope and Methodology

Audit objective and scope

The audit objective was to assess the management control processes and activities in place to support the delivery of the immigration program at the High Commission of Canada in New Delhi. Specifically, the audit focused on the following elements:

  • Governance, clarity of roles and responsibilities and promotion of values and ethics;
  • Risk management and quality assurance practices to support program delivery; and
  • Internal controls over program administration and operational activities.

The original terms of reference for this internal audit included a scope period from October 1, 2013 to September 30, 2014. Controlled document / forms management testing was performed during the audit site visit to New Delhi, India in February 2015. New information was taken into account for a second site visit in February 2016.

The audit did not include an assessment of the visa office cost recovery function, as this work was performed by the IRCC Internal Control Compliance team during their site visit to New Delhi in February 2015.

Methodology

The following audit procedures were performed to assess the audit criteria:

  • Interviews were conducted with functional authorities at IRCC Headquarters in Ottawa and with New Delhi, Chandigarh and Bengaluru visa office staff;
  • Documentation reviews were performed;
  • File reviews of 90 applications to assess processing compliance with the Immigration and Refugee Protection Act;
  • File reviews, reconciliations and inventory count of controlled documents;
  • Reviews of documents such as performance management reports, quality assurance reports, verification reports, and business continuity plans; and
  • A walkthrough of the visa office was performed to observe the overall processes in place.

Two audit site visits were conducted: February 2 to 12, 2015 and February 14 to 19, 2016. The second site visit was required in order to complete the work that had not been performed during the previous site visit. The audit observations, conclusions and recommendations are based on the work performed.

Statement of Conformance

The audit is in conformance with the Internal Auditing Standards for the Government of Canada as supported by the results of the quality assurance and improvement program.

Audit Findings and Recommendations

Governance framework

Criteria. It was expected that roles, responsibilities and accountabilities for the immigration program were clearly defined and communicated; resources were planned and managed to support program delivery; and, public service values and ethics were documented and promoted.

Conclusion. A clear, well understood governance structure is in place to manage the immigration program. Visa office program staff roles and responsibilities were defined and communicated and resources were planned to support program delivery. Public service values and ethics were documented and promoted by the High Commissioner, the IPM and officers in the section. Staff who work in the immigration section performs an annual sign-off related to the Code of Conduct and has taken the mandatory Global Affairs Canada (GAC) values and ethics training.

Roles and responsibilities

The High Commission of Canada in New Delhi is the largest mission overseas and Canada-Based visa officers have responsibilities related to overall mission management. For example, the IPM and Deputy IPM are members of the Committee on Mission Management and a First Secretary is on the High Commission’s training committee. Representatives from the Immigration Section sit on almost all mission committees, in various capacities.

The IPM is responsible for the overall management of Canada’s immigration footprint in India. This is done by working in close coordination with the Deputy IPM, the Immigration section Management team, and with the IPMs in Bengaluru and Chandigarh. Weekly telephone conference calls are held to discuss issues of importance and include balancing workloads as required.

The Deputy IPM plays a key role in managing program delivery in Delhi and with integrated workload distribution. There are dedicated resources to fulfill the main processing roles, administrative roles and support functions. Roles and responsibilities are clearly identified in formal documentation, such as organization charts, official departmental planning documents and individual performance agreements. Furthermore, New Delhi has established standard operating procedures and manuals that support visa office staff understanding of the application processing and decision-making processes.

Resource management

The IPM fulfills the resource management requirements by submitting relevant planning documentation to the Director General, International Region at IRCC Headquarters in Ottawa. These planning documents take into consideration peak processing periods and identify the number of temporary duty officers and emergency Locally-Engaged Staff required and their estimated costs, in addition to travel plans, anticipated expenditures, outreach and plans for workload sharing.

Temporary resident application processing is distributed across the three visa offices in India as required particularly during peak application processing time periods. The New Delhi visa officers are also supported in workload sharing initiatives by immigration officers located in Warsaw, Poland and Colombo, Sri Lanka, among other locations.

Performance management

Program performance related to annual targets and processing times is managed using centralized data provided by IRCC Headquarters as well as local data and information generated at the mission. All processing unit managers use dashboards and management tools that are based on data extracted from GCMS. These dashboards track decisions by officers, files in process, and processing times. The Permanent Resident Unit managers also maintain key data and performance information to manage staff workloads in meeting annual processing targets (levels).

The Registry Unit Manager maintains data on key processes. This information is used to manage the registry workload that supports visa application processing. In addition, the Risk Assessment Unit (formerly called the Anti-Fraud Unit until April 1, 2016) manager develops a weekly report that tracks the number of cases referred, pending cases, the results of document and other verifications and the number of field investigations conducted. The Client Service Unit manager tracks volumes of enquires received, compliance with service standards and tracks Member of Parliament enquiries separately.

The data and information is used to manage staff workloads and balance resource requirements across the main application processing units. It is also used by the managers to report to the Deputy IPM and IPM on the delivery of the immigration program at the New Delhi visa office.

Public sector values and ethics

Every year the High Commissioner communicates the importance of values and ethics and respecting the Code of Conduct. In the fall 2015 all employees, except those who were on long-term leave, signed-off with their managers that they read and understood the Code of Conduct and that they completed the mandatory GAC values and ethics training.

In addition to the above noted communications, immigration program officers work with the GAC Deputy Management Consular Officer (Human Resources) to ensure that values and ethics scenarios are included as part of questions presented to candidates during Locally-Engaged position staffing processes. Finally, officers and program assistants indicated that there was an emphasis on values and ethics in the workplace which was reinforced by the IPM. For example, values and ethics was a key component of the visa office staff retreat in February 2016.

Risk management and quality assurance

Criteria. It was expected that risk management practices and quality assurance measures were integrated into program operations to support program integrity.

Conclusion. The immigration program delivery model used in India is focused on a whole of country approach – including the assessment of risks and mitigation strategies to support program integrity. The New Delhi immigration officers work in collaboration with the Risk Assessment Unit to develop strategies to ensure applications are processed considering key risk factors. A number of quality assurance reviews have been performed to maintain program integrity and strengthen the delivery of the immigration program. Two areas for improvement were noted related to enhancing Anti-Fraud reporting, as well as staff rotations.

Risk identification and anti-fraud

The IPM ensures that annual program risk assessment documentation is submitted to IRCC Headquarters on time. The documentation presents the visa office’s operating environment, key risks and planned approaches to deliver on targets (levels) and processing time expectations.

The New Delhi visa office Risk Assessment Unit has been in place since 2006. The Unit is managed by a Canada Border Services Agency (CBSA) officer that reports to the IPM and is comprised of four Locally-Engaged Staff. Among other things, the Unit conducts telephone verifications, field investigations, document verifications and various other types of examinations to verify information provided by applicants.

The Risk Assessment Unit developed standard operating procedures and tools, which have been regularly updated since it was formed to support immigration program delivery. These tools have supported good practices in the areas of document and information verification, education and training of existing and new Canada-Based Officers and temporary duty officers, and better sources of data to support application processing.

One of these tools is the watch list. Risk Assessment Unit employees capture information related to previous verifications and past fraudulent cases and enter an alert into GCMS. If a [REDACTED]. This is a key preventative internal control designed to reduce the risk that applications are approved for applicants that provide inaccurate or erroneous information.

Another practice of the Risk Assessment Unit is training current and new officers on fraud risks and how these risks should be taken into account when processing applications. The “Delhi Academy” is the comprehensive training package to assist current, new and temporary officers processing applications on issues specific to the New Delhi visa office. It includes numerous modules including an introduction to the Risk Assessment Unit’s work.

Over the past few years the work of the unit has been focused on individual cases or on coordinated fraud cases and a number of investigative reports have been produced. While this has led to the New Delhi visa office having information on ways applicants submit applications with fraudulent information or documents, it has meant that in-year trends and issues reports and annual reports on fraud have not been produced as was the practice in the past. Up until 2014 the unit had produced an annual report that highlighted trends and issues related to anti-fraud work. There is an opportunity for the unit to develop improved reporting on trends and issues to all officers working in the visa office – including re-introducing the annual report. This is important given the change-over of Canada-Based Officers every year and the number of temporary duty officers that work at the New Delhi visa office.

Most of the Locally-Engaged Staff in the Risk Assessment Unit have worked there since its inception. While the employees each have approximately nine years experience in this area, there is an opportunity for the program to rotate employees in and out of the unit to further strengthen program integrity. The knowledge transfer would be valuable for the temporary and permanent resident teams. Furthermore, employees with recent application processing experience could bring a different perspective to the work performed in the Risk Assessment Unit.

Recommendation 1. The IPM and the operations management team should work with the Risk Assessment Unit Manager to strengthen reporting on issues and trends and to re-introduce annual reporting on anti-fraud related activities to ensure that visa officers have up to date information on the results of the unit’s investigations.

Recommendation 2. The IPM should rotate Locally-Engaged Staff in and out of the Risk Assessment Unit with Locally-Engaged Staff of other units within the visa office to cross-train employees and strengthen program integrity across all units.

Quality Assurance

The visa office management team has performed a number of quality assurance reviews over program delivery and administration. The New Delhi visa office has also been included in broader IRCC Headquarters led quality assurance reviews across the visa network.

Quality assurance exercises have been performed across all units within the program to provide better information to clients applying to the various programs, to improve application processing, to improve support to program delivery, and to improve verifications on medical reviews. From 2013 to present, examples of areas reviewed include:

  • Temporary resident intra-company transfers;
  • Specific aspects of temporary resident processing;
  • Appeals;
  • Registry operations; and
  • Medical program documentation.
Emergency management and business continuity

The development and implementation of emergency management and business continuity plans is led by GAC officials. As a part of annual updates to the plan, the IPM provides information on various emergency scenarios related to keeping the immigration program operating in times of crisis or disaster. In addition, Canada-Based Officers have important roles and responsibilities related to the High Commission’s Incident Command Structure (ICS); for example, the IPM is the Operations Chief.

The High Commission emergency plan and ICS was tested as part of table-top exercises in 2014 and 2015. In April 2015, the ICS was enacted in response to the earthquakes that occurred in Nepal. As a result, the High Commission business continuity plan - including the visa office’s emergency management documentation - was updated in early 2016 based on lessons learned from the Nepal earthquake, and a GAC-led simulation exercise conducted in February 2016. This included the updating of Critical Function Sheets for the visa office by the IPM.

Internal controls over program administration and operational activities

Criteria. It was expected that an internal control framework over administrative and operational activities for the immigration program would be in place. Specifically:

  • System and workplace access controls were in place and working as intended;
  • Applications were processed in accordance with legislation, policies and procedures;
  • Internal controls were in place to safeguard the handling of controlled documents; and
  • Internal controls were in place to ensure administrative activities were conducted in compliance with applicable policies and procedures.

Conclusion. Internal controls were in place over program administration and operational activities and were working as intended. Workplace access controls were in place and controlled documents were protected and managed in accordance with departmental policies and procedures. Finally, application processing was conducted in accordance with legislative requirements.

System and workplace access controls

The visa office occupies space on all floors of the High Commission. The physical constraints of the building do not allow for the segregation by secure pass code from other sections, except in two key locations. The offices where controlled documents are maintained and printed are secured with pass code access provided only to those that require access. In addition, the registry, which is the main application distribution centre located on a different floor of the High Commission is locked up after regular mission business hours.

In terms of system access controls, it was noted that access to the Controlled Key Forms Inventory Tracking System (CKFITS) – the information system used to record and submit controlled document inventories - was compliant. There was an opportunity for improvement related to GCMS system access controls. This related to the number of user accounts that were active relative to the number of employees that were working in the visa office. Since only IRCC Headquarters officials have authority to deactivate GCMS accounts, the GCMS Manager requested IRCC Headquarters to deactivate accounts for departing Locally-Engaged Staff and to remove New Delhi as a position on active GCMS accounts for Canada-Based Officers leaving the mission for another office.

Finally, concerns were raised related to GCMS performance and the impact it has on application processing. The GAC and Shared Services Canada infrastructure has struggled to cope with the GCMS demands placed upon it. Visa office officials estimated that the system’s speed made application processing approximately 30 percent less efficient than if it were working at the speed at which it operates in Canada, i.e. outside the GAC / Shared Services Canada platform. System performance data provided by program management supported this estimate for all three visa offices.

Program application processing

Guidance and tools

The New Delhi visa office has approved standard operating procedure manuals that are updated regularly to ensure consistency with departmental policies and guidelines. In addition, there are a number of tools provided to officers to support application processing. These tools aid officers and support staff with specific file review elements and include access to government websites to verify documents and tools to assist in determining whether documents are official and legitimate.

A sample of 90 application files was examined. All files within the sample were processed in accordance with legislative requirements and departmental guidance.

Remote printing

The remote printing of visas is a means to provide Canada’s network of missions with the flexibility to further facilitate a whole-of-government approach to achieving mission objectives while ensuring the integrity of the immigration program. In the case of New Delhi, this has allowed for the processing of cases by other Canadian visa offices around the world. For instance, the vast majority of Express Entry immigration files are processed in Canada. As a result, the New Delhi visa office performs more and more remote printing for approved applications from other offices related to Indian nationals. The number of remote visas printed has increased from 2,933 in 2014 to 8,700 in 2015. This number is expected to increase as workloads continue to shift across the entire Canadian visa network to support increasing Temporary Resident demand in India and higher Family Class targets in New Delhi.

Internal controls over controlled documents

Counterfoils and seals are controlled documents that are issued as a visa in a traveler’s passport or single journey travel document. The New Delhi Forms Control Officer works in accordance with the IRCC Forms Management Manual and has developed a local procedures manual that builds in additional controls to safeguard the use and management of visa seals and counterfoils. For example, when visas are cancelled but already placed in an individual’s passport, officers stamp the visa with the appropriate reason for why it was cancelled (i.e. cancelled without prejudice), take a photocopy of the cancelled visa, and place the photocopy in the forms control log book. This is a good practice that provides a full accounting of management and use of all seal and counterfoil inventories at the mission.

The Forms Control Officer submits approved controlled forms management documents to IRCC Headquarters via CKFITS. A reconciliation of the inventories of controlled forms to usage was performed. The balances in the inventories reconciled with controlled forms used during the time period reviewed.

Administration

All visa office staff (not on extended leave) had performance objectives, training plans and performance appraisals on file. The general training provided to Locally-Engaged Staff who work in the immigration section is based on the High Commission training program developed annually by the mission training committee. Visa office specific training focuses on immigration program delivery, job related activities and cross-training on different occupational roles.

The New Delhi visa office’s formal training program (“Delhi Academy”) is provided to all Canada-Based Officers coming to work in New Delhi, Bengaluru and Chandigarh. All new officers are trained on anti-fraud and risk management techniques to review and process applications, among other modules.

Temporary duty officers that come to one of the three missions in India are provided a condensed version of the Delhi Academy.

A review of employee security clearances found that not all Locally-Engaged Staff clearances were valid at the time of the site visit in February 2016. Two employees working in the immigration section had clearances that had expired. The mission was aware of this issue at the time and had taken steps to ensure that the clearances were being updated. While responsibility for providing and renewing Locally-Engaged Staff security clearances rests with GAC, and responsibility for Canada-Based Officer clearances with IRCC Corporate Security, the Delhi visa office developed a tracking tool in February 2016 to ensure that all active staff has valid clearances. This good practice will be shared across the entire Canadian visa network. Subsequent to the audit site visit, the IPM indicated that one Canada-Based Officer’s security clearance had expired and was in the process of being updated.

Conclusion

The management control framework in place to support the delivery of the immigration program at the Canadian High Commission in New Delhi is in place and working as intended. Visa office program staff roles and responsibilities were defined and communicated and resources were planned to support program delivery. Values and ethics expectations were documented and promoted. Staff had taken mandatory training and signed the Code of Conduct in fall 2015. Risk management and quality assurance practices supported immigration program delivery and internal controls over program administration and operational activities were working as intended.

Two areas for improvement were noted. The first relates to enhancing in-year reporting and annual reporting on fraud and related verifications and activities. The second relates to rotating staff in and out of the Risk Assessment Unit to enhance program integrity knowledge at the mission.

Management has accepted the audit findings and developed an action plan to address the recommendations.

Appendix A – Management Response and Action Plan

Recommendation 1

The IPM and the operations management team should work with the Risk Assessment Unit Manager to strengthen reporting on issues and trends and to re-introduce annual reporting on anti-fraud related activities to ensure that visa officers have up to date information on the results of the unit’s investigations.

Management Response

Management accepts this recommendation.

Since April 1, 2016, in light of the recent Management Framework signed between IRCC and CBSA, the “Anti-Fraud Unit” has been renamed the ”Risk Assessment Unit” (RAU). By clarifying each department’s role, this change also reinforces the importance of sharing up-to-date information on risks and fraud trends with visa officers. The New Delhi management team agrees with the recommendation. The team will enhance ad-hoc and quarterly reporting by the end of September 2016, and will enhance annual reporting by the end of March 2017.

Management action plan items to address this recommendation will be completed by March 2017.

OPI: Assistant Deputy Minister, Operations
Due Date: March 31, 2017

Recommendation 2

The IPM should rotate Locally-Engaged Staff in and out of the Risk Assessment Unit with Locally-Engaged Staff of other units within the visa office to cross-train employees and strengthen program integrity across all units.

Management Response

Management accepts this recommendation.

The New Delhi management team will complete Risk Assessment Unit staff rotation and cross-training by the end of December 2016.

Management action plan items to address this recommendation will be completed by December 2016.

OPI: Assistant Deputy Minister, Operations
Due Date: December 31, 2016

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