CIMM – Question Period Note - Use of AI in Decision-Making at IRCC – November 29, 2022

Date: August 25, 2022
Classification: unclassified
Department: IRCC

Issue:

Concerns about IRCC’s use of artificial intelligence in decision-making on client applications

Proposed Response:

• IRCC uses advanced data analytics systems to help officers identify routine applications for streamlined processing, as well as to sort and triage applications to officers based on their level of complexity.
• These systems are not used to refuse applications or deny entry to Canada.
• IRCC officers remain central to immigration processing.
• Our use of advanced analytics automates some processing steps for routine applications. By leveraging technology, IRCC is able to realize processing efficiencies and have officers focus on more complex or sensitive applications.

Contact:
Philip Somogyvari, Director General, Strategic Policy and Planning
Tel. No. 613-437-7454 (office); 613-697-6653 (mobile)

Approved By:
Marian Campbell Jarvis, Senior Assistant Deputy Minister, Strategic and Program Policy

Background

IRCC Use Of Advanced Analytics

• IRCC is using a number of innovative approaches to manage high application volumes, improve service delivery and enhance the client experience.
• To help ensure that our clients get the travel documents they need to enjoy their stay in Canada and to support Canada’s economy, we are using digital tools to create processing efficiencies where appropriate.
• IRCC’s use of advanced analytics can be divided into the following broad categories:
  • Automating positive eligibility determinations
  • Distributing applications between officers based on the characteristics of the application
  • Identifying applications that may require additional verification
  • Workload distribution
  • Creating “annotations” that summarize basic information on each client to reduce officer searches in our Global Case Management System
  • Triaging client emails to enable faster replies, and responding to client enquiries by providing publicly available information
  • Assessing biometrics

Key Projects

• In 2018, IRCC launched two projects using computer analytics to help officers triage online temporary resident visa applications from China and India. The projects’ goal was to help officers to identify applications that are routine and straightforward for faster processing and to triage files that are more complex for a more thorough review.
• A further advanced data analytics project was launched in spring 2021 for in-Canada family class spousal and common-law applications. This project aimed to speed up processing by triaging applications and automating certain positive eligibility determinations. All applications for which eligibility cannot be approved by the model receive an individualized assessment by officers in accordance with standard practice.
• In January 2022, the China and India advanced analytics models were updated, and a new model was introduced for Temporary Resident Visa applications from all other countries. All three of these advanced analytics models function in the same way to automate some eligibility approvals for straightforward applications; they never refuse applications or recommend refusing applications.
• Where advanced analytics is used to support decision-making, IRCC does not use complex algorithmic systems that make decisions in unknowable or unexplainable ways. All rules applied by these systems can be clearly explained.
• IRCC does fully automate approval decisions for some electronic Travel Authorizations (eTAs) and routine passport renewal applications.
• Since December 2020, IRCC has also been using automated triaging tools to help the department respond to client emails. These tools triage client emails using text recognition, in order to properly tag and group emails to facilitate faster responses. While some of these email triage tools employ more complex ‘black-box’ algorithms, they are not used to render decisions or to provide recommendations on client applications. As previously mentioned, IRCC does not use black-box algorithms to support decision-making, and does not have plans to explore this moving forward.
• IRCC is currently developing models to help triage and automate certain positive eligibility determinations in the Privately Sponsored Refugee program. The department will be consulting with key stakeholders regarding the development of these models to ensure responsible use of this technology.
• Protecting the safety and security of Canadians remains a priority. In all cases, IRCC officers continue to screen for security and criminality.
• Advanced data analytics systems are not used to refuse applications, and they do not recommend refusals on applications. All final decisions to refuse an application are made by an officer after thorough review.
• Media coverage has incorrectly suggested that IRCC’s ‘Chinook’ tool employs advanced analytics or artificial intelligence to automate decisions. Chinook is a stand-alone tool that extracts information from applications and displays it in a clear format that is more user-friendly for officers. Chinook does not make or recommend decisions on applications.

Ensuring Responsible Use Of Data-Driven Technologies

• While IRCC has not established any absolute bars on the circumstances in which advanced analytics, automation or artificial intelligence can be used, we have employed a cautious approach. The department has developed detailed guidance, including a Policy Playbook on Automated Decision Support, to help consider how these technologies can be used responsibly, effectively and efficiently. IRCC has also established an internal governance framework to ensure that new decision support tools go through a rigorous review and approval process. A broad-based committee of senior executives acts as the key oversight body in this governance framework.
• IRCC is always working to be a leader in the responsible use of data-driven technologies and has developed internal policy guidance to align with the Treasury Board Directive on Automated Decision-Making, as well as other key legal and privacy requirements. IRCC was one of the first departments to publish Algorithmic Impact Assessments (AIAs) in accordance with the Treasury Board Directive.
• Protecting individuals’ personal information continues to be a priority for IRCC as the Department tests new and innovative approaches. The use of personal information for analytics-based processing is in accordance with the Immigration and Refugee Protection Act and the Privacy Act. Its use is consistent with the purpose for which it was initially collected.
• The rules used by advanced data analytics models to support decision-making are reviewed by experienced officers, legal, policy, data science, privacy experts, and senior decision-makers to ensure they are responsible, logical, understandable and aligned with the eligibility criteria outlined in the Immigration and Refugee Protection Act and Regulations.
• Regular monitoring and quality assurance measures also help to make sure that these models continue to perform as intended and that any unforeseen negative impacts can be identified early and mitigated.