Evaluation of the Ministerial Reviews and Interventions Pilot Program - Management Response Action Plan
If CIC were to regularize the R&I Pilot into a permanent program, the following recommendations should be considered:
CIC should develop a policy framework, in consultation with the CBSA, which outlines the authorities for the Reviews and Interventions function, including:
- identifying what information can be gathered and from what sources;
- clarifying protocols around information sharing, with government departments and non-government; and
- establishing guidance and parameters for the conduct of interventions (i.e., when an intervention should be conducted).
CIC agrees with this recommendation. A framework will better define the parameters and governance of the R&I program, and will require consultation with RAB and the CBSA. Guidance on when an intervention should be conducted and possible sources of information will also be clarified in the Program Delivery Instructions (PDIs).
R&I Framework: CIC will develop a framework to define governance, information sharing protocols and the limitations of the R&I function.
- Research the existing governance structures and verify the feasibility of using them to establish the governance for the new R&I program.
- Define the parameters of the R&I program for interventions and investigations.
- Clarify the mandates and roles and responsibilities of CIC and CBSA within the intervention context.
- Define the Minister's authority to intervene.
- Define the limitations of the R&I function including CIC investigations
- Identify what information can be gathered from which sources.
- Accountability: OMC. Support: RAB. Completion date: Q2 2015/16.
- Information Sharing: Clarify protocols around information gathering, sharing, and disclosing.
- Accountability: OMC. Support: RAB. Completion date: Q3 2015/16.
- Document the Framework and obtain the appropriate approval (DG level).
- Clarify when to intervene by filing documents or in-person at the RPD and RAD, and update the PDI.
- Accountability: OMC. Completion date: Q3 2015/16.
- PDI Updates: Additional guidance on when to intervene and sources of information will be provided to officers in updates to the PDIs.
- Accountability: OMC. Completion date: Q2 2015/16.
CIC should work with the CBSA to ensure that the mandates of each department and respective roles and responsibilities for hybrid cases and the triage process are clearly defined, documented, and communicated to all staff.
CIC agrees with this recommendation.
A standard operating procedures (SOP) document for the triage process and how to deal with hybrid cases is in development. A joint checklist also exists to direct where files are assigned during triage.
The SOP includes instructions such as: triggers for triaging files based on the mandate of each department for reviewing/intervening in cases; document flow from claimant intake to RAD appeal; and how to handle a case if found to be hybrid after triage is completed.
The SOP for joint triage and hybrid cases will be finalized with the CBSA, with agreed definitions and an updated checklist. This document will be made available to all R&I staff in CIC and the CBSA will share the document with their staff.
- Define a hybrid case with the CBSA.
- Clarify process steps for hybrid case files between the two departments to eliminate any duplication of efforts both at the Triage stage and after the Triage stage.
- Review the current Triage Checklists and triggers and modify them as necessary.
- Accountability: OMC. Consultation: CBSA. Completion date: Q2 2015/16.
- Finalize the Joint Triage SOP, which to be approved at a Director level
- Communicate the SOP to the intervention staff at CIC and CBSA.
- Accountability: OMC. Consultation: CBSA. Completion date: Q3 2015/16.
CIC should work with the CBSA to establish the necessary instruments and processes (such as information sharing agreements) to obtain and/or exchange information that is required to conduct reviews and interventions (e.g., document analysis).
CIC agrees with this recommendation.
Agreements on shared processes and information sharing between CIC and the CBSA are required. Some issues will be addressed through the framework and triage SOP listed above. Other areas that may require more process structure include; intelligence gathering/ sharing on refugee claimant trends; sharing of information collected for immigration purposes; and delivering officer training.
Agreements on process and information sharing will be finalized (CIC/CBSA MOU, PDIs, etc.).
Instruments to share between CIC and CBSA.
- Identify the list of existing tools and processes and explore tools to be used in R&I functions of CIC and CBSA.
- Complete privacy impact assessment on each tool identified to be able to share between CIC and CBSA.
- Accountability: OMC – National agreements; Ontario Region – Regional agreements. Completion date: Q3 2015/16.
- Based on the privacy impact assessments, implement the necessary measures to address any concerns and amend information sharing agreements as required.
- Obtain the appropriate approvals on new or amended agreements.
- Accountability: OMC – National agreements; Ontario Region – Regional agreements. Completion date: Q4 2015/16.
CIC should address the gaps in training and tools, including training on RAD and CIC information systems, developing standard operating procedures, and access to additional analytical tools.
CIC agrees with this recommendation. Training on intervening at the RAD was provided to senior immigration officers in December 2014 and January 2015.
The existing training materials and tools used for intervention will be reviewed and updated as required to address gaps in training and tools.
- Identify existing training and tools within the department, which are intended for other lines of business and assess to see if they can be leveraged for R&I.
- Determine if privacy impact assessment is required.
- Accountability: OMC – Operational tools; Ontario Region - Training. Completion date: Q2 2015/16.
- Implement if they are determined to be useful.
- Incorporate the applicable tools into the R&I training package or into the PDI.
- Accountability: OMC – Operational tools; Ontario Region – Training. Completion date: Q3 2015/16.
- Clarify the roles and responsibilities between the Learning and Development Division and Ontario Region regarding the maintenance of R&I training materials and the delivery of R&I training, to be documented in a service level agreement.
- Accountability: Ontario Region. Support: LDD. Completion date: Q3 2015/16.
In order to address the R&I data issues identified through the evaluation:
- CIC should ensure that appropriate performance measures are identified for the Reviews and Interventions function and integrated in existing relevant Performance Measurement Strategies where applicable; and
- CIC should ensure that performance data related to the Reviews and Interventions function are being collected and reported in a consistent way across the department.
CIC agrees with this recommendation.
- A document with clear and transparent specifications and business rules for R&I data collection and reporting requires collaboration with R&E, OPMB, OMC, SIMB and RAB. This will ensure that CIC has consistent R&I rules which could be integrated into CIC's various reporting systems (irrespective of technology or tool being utilized).
A clear and transparent business rules/specifications document will be developed.
Accountability: OMC, OPMB, R&E, RAB. Lead: R&E. Completion date: Q1 2015/16
Current performance measures and data being collected for R&I need to be reviewed, updated and incorporated into the Refugee Reform Performance Measurement Strategy as applicable. CIC will consult with the CBSA in the review and update of performance measures.
A review of R&I performance measures will be conducted. The Refugee Reform Performance Measurement Strategy will be updated as appropriate. CIC will consult with the CBSA in the review and update of performance measures.
Accountability: OMC, OPMB, R&E, RAB. Lead: OMC. Completion date: Q4 2015/16
A Reviews and Interventions (R&I) subject area, which ensures appropriate performance monitoring, is under development by OPMB in the CIC Integrated Data Model in collaboration with the Enterprise Data Warehouse group within SIMB. Once this is in place and validated, all R&I data for CIC and the CBSA will come from this single source in a consistent way.
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