Internal Audit of Operation Syrian Refugees Identification and Processing

[REDACTED] appears where sensitive information has been removed in accordance with the principles of the Access to Information Act and the Privacy Act.

Internal Audit & Accountability Branch
1 June 2017

I. Background

Introduction

  1. In 2015, the ongoing conflict situation in Syria constituted one of the world’s largest refugee crises. Over 4,000,000 Syrian refugees had fled to the neighbouring countries of Lebanon, Jordan, Turkey, Iraq and Egypt.
  2. In September 2015, Immigration, Refugees and Citizenship Canada (IRCC) officials were working to resettle 10,000 Syrian refugees to Canada by September 2016. While planning was underway to meet this goal, the Government of Canada announced in November 2015 a commitment to resettle 25,000 Syrian refugees as permanent residents.
  3. The resettlement initiative, known as Operation Syrian Refugees (OSR), was led by IRCC in collaboration with 15 federal government departments and agencies; international partners such as the United Nations High Commissioner for Refugees (UNHCR), the International Organization of Migration (IOM) and the Government of Turkey; provinces, territories, and municipalities; and private sector and non-governmental organizations.
  4. The process of resettling the first 25,000 Syrian refugees had five phases:
    1. Phase 1 – Identifying Syrian refugees to come to Canada;
    2. Phase 2 – Processing Syrian refugees overseas;
    3. Phase 3 – Transportation to Canada;
    4. Phase 4 – Welcoming in Canada; and
    5. Phase 5 – Settlement and community integration.
  5. The Government of Canada achieved its objective as 26,172 Syrian refugees arrived in Canada by February 29, 2016. This included 14,995 Government Assisted Refugees (GAR), 8,953 Privately Sponsored Refugees (PSR), and 2,224 Blended Visa Office-Referred (BVOR) Refugees.

Operating environment

  1. OSR was a large-scale operation that was expected to be fulfilled under tight timelines. The Federal Emergency Response Plan (FERP) was invoked by IRCC to manage the operation. The FERP has established processes and procedures to support an integrated Government of Canada response to an emergency or crisis situation. IRCC officials made use of the services and assets of the Government Operations Centre at Public Safety Canada, and led OSR efforts through the National Coordination Centre located in Ottawa, Ontario.
  2. Temporary infrastructure was established to support the operation in Canada and overseas in Amman, Jordan; Ankara, Turkey; and Beirut, Lebanon. IRCC permanent and short-term staff moved into temporary roles to meet the goal of this effort. Notwithstanding the operational pressures and tight timelines, IRCC officials were expected to process applications in compliance with the Immigration Refugee Protection Act (IRPA) and related policies and procedures.

Eligibility and admissibility

  1. As part of OSR, a Syrian refugee that applied to come to Canada had to have been referred by either the UNHCR or the Government of Turkey; or, have been privately sponsored by a sponsorship group. The Syrians that fled the conflict situation were considered to be prima facie refugees. As such, a Syrian that was located outside of Syria was considered a refugee unless proven otherwise. For the purposes of OSR, immigration officers considered two key factors: the applicant must have been a Syrian citizen living outside of Syria; and the applicant must not have had a durable solution for resettlement in a country other than Canada (for example, the applicant was neither a refugee in another country nor a citizen of another country where he/she could permanently reside).
  2. Syrian refugees that applied to come to Canada had to complete an immigration application form before being assessed by an immigration officer. In the cases of families, one family member was identified as the Principal Applicant (PA) and the remaining family members were identified as dependents on the application form.
  3. Syrian refugees were processed and admitted to Canada under three distinct programs:
    • Government-Assisted Refugees (GAR). For OSR, these applicants were referred to Canada by the UNHCR or the Government of Turkey. The Government of Canada provided resettlement and income support through its Resettlement Assistance Program (RAP) for up to one year after their arrival date, and resettlement services for the first weeks in Canada after which refugees can access settlement services.
    • Privately Sponsored Refugees (PSR). These applicants were supported by a sponsorship group. The sponsor provided financial support for up to one year after arrival. PSRs are eligible to access settlement services.
    • Blended Visa Office-Referred (BVOR). These applicants were referred to Canada by the UNHCR or the Government of Turkey, and identified by immigration officers to participate in this program. Income support was shared between the Government of Canada and the private sponsors, each providing a portion of financial support for six months up to one year after the refugee arrival date. With the exception of income support, BVORs are not eligible for RAP, but they are eligible for settlement services.
  4. If an applicant met all refugee eligibility criteria to resettle to Canada during the immigration interview, the applicant would then be assessed for admissibility. Admissibility procedures included a medical examination, criminal and biometric screening, and security screening. Once all eligibility and admissibility procedures were completed and results were recorded, an IRCC officer would have the information required to render a final decision. If an applicant was deemed eligible to resettle to Canada, and passed all admissibility screening procedures, the application could be approved by an IRCC immigration officer. Alternatively, an applicant who was deemed ineligible or inadmissible would be refused.

Description of the Syrian refugee population

  1. The Syrian refugee population that arrived in Canada during the time period reviewed was 26,172. The majority of Syrian refugees that arrived in Canada were Government-Assisted Refugees (see Exhibit 1).
Exhibit 1 - Number of Syrian refugees who arrived in Canada from November 4, 2015 to February 29, 2016 by immigration category
Number of Syrian refugees who arrived in Canada from November 4, 2015 to February 29, 2016 by immigration category. Described below
Exhibit 1 - Number of Syrian refugees who arrived in Canada from November 4, 2015 to February 29, 2016 by immigration category
Government-Assisted Refugees 14,995
Privately Sponsored Refugees 8,953
Blended Visa Office-Referred Refugees 2,224

II. Audit objective, scope and methodology

Audit objective and scope

  1. The audit objective was to assess whether processes were established and followed by IRCC for OSR to identify and process Syrian refugees.
  2. The scope covered the time period from November 4, 2015 to February 29, 2016 and included an examination of the procedures used to identify potential GARs; the processing of GAR, PSR and BVOR applications; and quality control activities conducted related to processing refugee applications.
  3. The examination focused on applications processed in the main OSR centres: Amman, Jordan; Ankara, Turkey; and Beirut, Lebanon. In addition, a small number of cases from other processing centres, such as Cairo, Egypt were included for parts of the examination where applicable.
  4. The IRCC Internal Audit and Accountability Branch worked in collaboration with the Canada Border Services Agency Internal Audit and Evaluation Directorate to validate certain information related to the audit testing of security screening of refugee files.
  5. The audit did not assess the processes in place to identify Privately Sponsored Refugees (PSR). The identification of these refugee applicants was conducted in Canada and the PSR files were sent to the processing centres in the three main OSR centres for immigration officers to assess eligibility and admissibility. The audit comments on IRCC administration and management of the processing of Operation Syrian Refugees applications and does not comment on any other organization that was involved in, or that supported the operation.

Methodology

  1. The following audit procedures were performed:
    • Review and analysis of documentation, such as IRCC’s standard operating procedures related to refugee processing, OSR-specific documents related to the identification and processing of Syrian refugees, and internally conducted quality control and assurance reviews.
    • Interviews were conducted with staff and management at IRCC headquarters in Ottawa and with a representative from the UNHCR. IRCC headquarters coordinated interview question responses from staff overseas who worked on OSR.
    • A walkthrough of the IRCC Global Case Management System (GCMS) was conducted with visa officers to understand the procedures used for OSR.
    • A sampling strategy was developed to determine the number of files to be reviewed as part of the audit. The sampling strategy consisted of multiple samples to assess processing compliance with IRPA:
    • 100 files, based on the principal applicant, to assess compliance with eligibility and admissibility.
    • 45 files to assess the triage criteria used for identification of GARs.
    • 7,481 files to assess the accuracy and completeness of the security screening information in the GCMS. Security data was validated by comparing the GCMS data to the case management system maintained by CBSA.
    • File review within the GCMS to determine if key processing steps were implemented in compliance with IRPA.
  2. The audit observations, conclusions and recommendations are based on the work performed.

Statement of Conformance

  1. 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.

III. Audit findings and recommendations

Phase One: Identification of Syrian refugees to come to Canada

  1. Criteria: It was expected that processes for the identification of Syrian Government-Assisted Refugees were established and followed.
  2. Conclusion: IRCC officials established processes and procedures for immigration officers related to Government-Assisted Refugees that supported decision-making on applications submitted as part of Operation Syrian Refugees. Triage criteria were developed and provided to stakeholders to guide the selection and referral of resettlement candidates to come to Canada.

Overseas identification processes

  1. IRCC officials worked in consultation with international partners to identify potential Syrian GAR resettlement candidates and established triage criteria for them to consider in referring potential refugees to apply to come to Canada as part of OSR. The triage criteria supported partner organization decision-making to ensure that the objective to resettle 25,000 Syrian refugees would be met, and done in a manner that aided the most vulnerable populations while protecting the security of Canadians.
  2. The UNHCR referred GARs from its registration lists in Amman, Jordan and Beirut, Lebanon. The UNHCR had a list of several thousand potential GAR applicants that had been submitted prior to November 4, 2015. This inventory of potential resettlement candidates was used to identify potential applicants to resettle to Canada as part of OSR. After the official launch of OSR, the UNHCR streamlined their referral process in order to meet the increasing demands of the objective to settle 25,000 refugees to Canada as quickly as possible. UNHCR officials made use of SMS text messaging on mobile phones to reach more than 60,000 refugees for potential referral to come to Canada. The identification and referral of Syrian refugees located in Turkey was performed by Turkish government officials.
  3. A sample of 45 Syrian refugee application files was reviewed to assess compliance with the overall OSR objective. The applicants were found to be in compliance with the triage criteria. Based on the work performed, the implementation of the triage criteria was appropriately considered by immigration officers when making decisions on applications.

Phase Two: Overseas processing of Syrian refugee applications

  1. Criteria: It was expected that Syrian refugee applications were processed in compliance with the eligibility and admissibility requirements of the Immigration and Refugee Protection Act (IRPA), regulations, and program instructions.
  2. Conclusion: Overall, Syrian refugee applications were processed in compliance with the Immigration and Refugee Protection Act, regulations and program instructions. Medical and criminality screening was completed for all applications and biometrics data collection followed operational requirements. Security screening measures were completed in all cases. [Redacted]

Introduction

  1. As stated earlier in this report, applicants that wanted to resettle to Canada had to be referred by a partner organization or private sponsor and then assessed for eligibility and admissibility. This section of the report reviews the processes and procedures that were in place to support these decisions made by immigration officers.

Eligibility

  1. Immigration officers interviewed all Principal Applicants and their dependents in order to assess their eligibility and admissibility to come to Canada. [Redacted]
  2. [Redacted]
  3. If the applicant was found to be ineligible to come to Canada, they would be refused, or in some cases, a final decision on an application was deferred if additional information from the applicant was required. For applicants that were eligible to come to Canada, they had to then pass admissibility requirements.
  4. To verify whether approved procedures to assess applicant eligibility had been implemented as required, a sample of 100 applications was examined. In all cases the eligibility decision was completed prior to the IRCC immigration officer’s final overall approval or refusal decision on a refugee application. This was essential so that the final decision-making officer would know that an applicant had met the necessary eligibility criteria when rendering a final decision on an application. [Redacted]
  5. [Redacted]

Admissibility

  1. When an applicant was deemed to be eligible to come to Canada, and the applicant had passed the immigration interview, an immigration officer then had to assess whether the applicant was admissible to come to Canada. The steps involved in this process included a medical examination, criminal and biometric screening, and security screening. Applicants could be denied entry to Canada if any of the admissibility criteria were not met.
Medical
  1. Applicants and their dependents had to pass an immigration medical examination to be accepted for resettlement to Canada. The medical examination was to be conducted by an IRCC approved physician and included screening for contagious diseases prior to arrival in Canada. We reviewed a sample of 100 applicant files as part of the audit and for all cases, the medical examination was completed, all applicants passed, and the examination was completed prior to final approval in accordance with established procedures.
Criminality and biometrics
  1. Criminality assessments were important because applicants could have been denied entry to Canada if they had previously been convicted of crimes or committed acts that would render them inadmissible. During OSR, the criminality assessment was completed as part of the interview and immigration officers were to obtain and clarify information on past criminal issues through questioning. Immigration officers assessed the credibility of the applicant throughout the interview process.
  2. As part of the overall screening process, the collection of biometric data from Syrian refugees was mandatory. Immigration officers, with the assistance of International Organization on Migration (IOM) officials, collected biometric information at the time of the interview, which included fingerprints and a digital photo for applicants between the ages of 14 and 79 years inclusive. The biometric data was verified against existing Canadian and United States biometric databases and results were considered by officers when making admissibility decisions based on criminality.
  3. A sample of 100 applicant files were examined to determine whether procedures to assess criminality were completed as required and if biometrics data was collected. In all cases, criminality decisions were completed prior to final approval of the application in accordance with established procedures. [Redacted]. In all cases, the mandatory collection of biometric data was conducted in accordance with established procedures.
Security screening
  1. A security assessment was required for refugees who were 18 years of age or older to determine their admissibility to come to Canada. During OSR, the screening procedures were adjusted from the standard procedures and differed depending on whether the applicant was a GAR, PSR or BVOR, and the time period during which the applicant was processed.
  2. All applicants who were processed before December 4, 2015 were subject to standard security screening procedures. [Redacted]. As part of the immigration interviews, security partner officials were present at the operations centres to answer questions, discuss complex cases and participate in interviews as required. If deemed necessary, the interviewing officer had the option to refer the applicant for additional security screening with federal government security partners. This additional security screening, which was sent to security partners electronically through GCMS, involved either a record check or a comprehensive check. After December 4, 2015 all GARs and BVORs who were 18 years of age and older automatically required further security screening in addition to the standard security process.
  3. The total population of approved applicants with record checks and comprehensive security checks in GCMS (7,481) was examined as part of the audit. This data was compared to security information recorded in CBSA databases to ensure accuracy and consistency between the two data systems. [Redacted].
  4. [Redacted]
  5. Recommendation 1 [Redacted]

Quality control activities and training

  1. Quality control activities were carried out overseas by IRCC officers during OSR to review the consistency and reliability of refugee application processing. These activities included training for immigration officers working as part of OSR, guidance materials provided to officers to conduct interviews, informal peer review of applications processed by colleagues, working collaboratively with security partners at processing centres, and conducting periodic internal quality reviews.
  2. Once OSR was announced, IRCC senior management needed to quickly mobilize immigration officers from across the visa processing network. IRCC senior management drew from its inventory of immigration officers, including the use of retired public servants for temporary assignment.
  3. As many officers were on temporary assignments with limited experience in interviewing and assessing Syrian refugee applicants, all immigration officers were required to complete mandatory training and were to be provided with information relevant to the potential caseload. [Redacted]
  4. In addition, a number of quality control activities were conducted throughout OSR at the Beirut, Lebanon processing centre. These included a review of security screening decisions and verification of the biometric data process. [Redacted].

OSR Lessons Learned

  1. In June 2016, IRCC senior management undertook an after-action review which included other government departments and non-government departments involved in OSR. The purpose was to identify best practices and areas for improvement from OSR and to capture these lessons learned for future operations. In addition, a rapid impact evaluation on OSR also identified opportunities for improvement.
  2. The observations from this audit are also intended to contribute to the lessons learned for future operations. [Redacted]
  3. Recommendation 2 [Redacted]

IV. Conclusion

  1. IRCC officials established processes and procedures for immigration officers that supported decision-making of applications submitted as part of Operation Syrian Refugees. Triage criteria were developed and provided to stakeholders to guide the selection and referral of resettlement candidates to come to Canada.
  2. Syrian refugee applications were processed in compliance with the Immigration and Refugee Protection Act, regulations and program instructions with some exceptions. Eligibility screening was completed for all files [Redacted].
  3. Admissibility screening was undertaken. Medical and criminality screening was completed for all applications and biometrics data collection followed operational requirements. Security screening measures were completed in all cases. However, there were some cases where discrepancies as per the established operating procedures were identified.
  4. Officer training practices and quality control activities specific to Operation Syrian Refugees were implemented [Redacted].
  5. [Redacted].

Appendix A – Management response to recommendations

Recommendation 1

[Redacted]

Management Response

[Redacted]

Recommendation 2

[Redacted]

Management Response

[Redacted]

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