CIMM – Chinook Development and Implementation in Decision-Making – March 24, 2022
Chinook is a Microsoft Excel-based tool developed by Immigration, Refugees and Citizenship Canada (IRCC) for temporary resident application processing to increase efficiency and to improve client service by decreasing the impacts of system and broadband latency, thus improving processing times.
Chinook displays information stored in the Global Case Management System (GCMS), IRCC’s processing system and system of record, in a more user-friendly way, allowing for increased GCMS user productivity.
Chinook is a tool designed to simplify the visual representation of a client’s information. It does not utilize artificial intelligence (AI), nor advanced analytics for decision-making, and there are no built-in decision-making algorithms.
It is always an IRCC officer, not the Chinook tool, that makes the final decision on an application. Chinook does not assess or make decisions on applications. Officers continue to review all client-submitted information to ensure informed and fair decisions. The use of Chinook does not lead to a less thorough review of applications, nor does it change the way decisions are made; it offers a consolidated view in a more user-friendly way, instead of a multiple screen layout of the application’s information.
Chinook is not a mandatory tool for IRCC officers and does not fundamentally alter the decision-making process.
Chinook is built in a modular way, allowing it to administratively support different steps in the process of assessing an application, depending on the module used. The various modules can assist IRCC with steps such as file management, indicator management, and pre- and post-decision management.
The Chinook tool is being re-platformed from Microsoft Excel to the Cloud and is currently under early development internally within IRCC. The current iterations of the Chinook tool allow some spreadsheet headings to be shifted between English and French per user language preference. Re-platforming efforts will see a fully bilingual tool. The re-platforming is expected to be completed by the end of the 2022-23 fiscal year.
The Immigration Refugee Protection Act and Regulations (IRPA/IRPR) are the basis for the decisions rendered by officers. Decisions are based on the officer review and made by the officer. Chinook does not change the way decisions are made; it is always an officer – not the Chinook spreadsheet – that makes final decisions and provides the rationale for them. Chinook supports decision-makers and IRCC staff and is not used to make or recommend decisions.
Chinook does not store any data or client information. This is a privacy-centric approach so that IRCC is not creating a new database of personal information. Officers must record all decisions in GCMS, which remains the system of record.
Experienced Chinook users within processing offices provide all necessary training and support related to Chinook, prior to other officers having access to the tool. Supplementary support is available through the use of standardized training materials, such as user manuals and recorded training videos.
In December 2020, performance of Chinook was measured through a sample study for overseas migration offices. The results determined there was an 18-30% gain in efficiency, decreasing the impacts of system and broadband latency and allowing for shorter review time per application hence increasing productivity.
IRCC’s advanced analytics and automation systems operate independently of Chinook, and they are reviewed routinely to ensure they are working as intended and align with the Government’s Directive on Automated Decision-Making.
For indicator management within the Chinook tool, keywords are used to notify officers of trends that IRCC has detected or highlight a particular factor of concern, not to sort visa applications. Keywords are also used to identify positive considerations such as applications that may require expedited processing (e.g. conferences, weddings).
Indicators and keywords are identified and submitted for entry into Chinook by IRCC officers. Indicators and keywords are not created by the Chinook tool.
The release of specific keywords connected to investigative techniques, trends, and risk profiles could encourage fraud or facilitate the commission of an offence, and are therefore not released per section 16(1)(b) of the Access to Information Act.
Statistics on the use of indicators and word flags are not tracked globally, though the information if present on individual applications would appear in notes in GCMS.
With respect to file management within the Chinook tool, the sorting of applications is based on the status of the application in the GCMS. It is not based on keywords or phrases.
In the Ocran test case chosen to address the issue of completeness of Certified Tribunal Records (CTR) in Chinook cases, the Court dismissed the application for judicial review on February 10, 2022. The Court did not rule on the CTR issue specifically, as it was not in direct dispute between the parties. The Court properly focused on the reasonableness of the officer’s decision, not on the administrative tools involved.
However, Ocran was the first Federal Court decision to mention Chinook by name in the judgment, indicating that the use of the Chinook tool itself does not lead to indefensible decisions. Nevertheless, further cases addressing the use of the tool itself may be part of future litigation that will be tested before the Court.