PACP - Collection Of Race-Based And Ethno-Cultural Information From Applicants - December 5, 2023

Recommendation #2: Timely Processing set by the Immigration Levels Plan

Key Facts And Figures

• Immigration, Refugees and Citizenship Canada (IRCC) currently collects gender, age, and language data through the annual Citizenship and Immigration Client Experience Survey.
• In 2022, we expanded the program's capacity to report on impacts by gender and diversity, by collecting data on accessibility/disability and racial and ethnic identity. For example, in the recent 2022 cohort of the survey, we found that approximately 91% (out of 19,587 total respondents) were willing to self-identify their racial and ethnic identity.

Key Messages

• IRCC recognizes the unjust and harmful impacts of systemic racism and, like other government departments, has taken a number of steps to address discrimination in our policies, programs and service delivery in alignment with the Department’s Anti-Racism Strategy.
• Disaggregated data is a critical part of that work, and so we are preparing to implement the Office of the Auditor General’s (OAG’s) recommendation to collect and analyze race-based (example, racialized identification such as South Asian, Black, etc.) and ethnocultural (for example, ethnic or cultural origin of a person) data to support addressing any racial disparities in processing times.
• Our plan is to establish a pilot project in collaboration with stakeholders and subject matter experts, allowing us to research and test different methodological approaches that rely on voluntary, self-reported data.
• This approach emphasizes our intent to collect and analyze data in a way that respects the principals of necessity and proportionality:
  • We should only pursue potentially privacy-intrusive activities where it is demonstrated that they are necessary to achieve the substantial purpose of identifying and addressing any racial disparities in outcomes, for example:
    • Is it clearly demonstrated that this measure is necessary to meet a specific need?
    • Is the loss of one person’s privacy proportional to the need?
    • Is there a less privacy-intrusive way of achieving the same end?
  • It is important to ensure that critical aspects of the methodological approach such as data integrity, standards, analytic approach and privacy safeguards, are tested to mitigate for the misuse of data.
• To support the pilot, IRCC will use tools and guidelines available internally to mitigate legal, ethical and privacy risks. In particular, we will ensure the Department’s newly developed tools and guidance for collection, use and analysis of disaggregated data are leveraged and applied according to programs and policies.
• Considering the sensitivity of this data, the development of a robust methodology is critical as a starting point, to allow us to isolate the factors that may influence the processing of an application.
• We recognize the collection of this data is just a starting point and how we analyze and respond to it, will actually determine how successful we are in addressing the OAG’s concerns.
• We would like to ensure we have time to engage stakeholders and subject matter experts who can help us get this work done in a meaningful way. The timelines and plan for implementing the pilot are therefore still under review.
• In addition, we are working to ensure the pilot aligns with broader efforts to standardize the collection and use of disaggregated data across IRCC and the Government of Canada more broadly, including Statistics Canada’s ongoing consultative engagement to review the concepts and data categories for visible minorities, racialized groups ahead of Census 2025.
• All clients should benefit from the improvements we make to our service delivery, and we are committed to treating our clients fairly, regardless of their race, ethnicity or nationality.

Supplementary Information

• If pressed to respond why race-based and ethnocultural identity data matters in Immigration Levels planning:
  • It is important to collect and use this data to help identify and address inequitable differences in application processing times. Race-based and ethnocultural identity data can help identify and eliminate structural racism by responsibly using the data to:
    • Uncover inequities and disproportionalities;
    • Improve timely processing of applications;
    • Inform policy and program design and service delivery;
    • Support institutional and structural changes; and
    • Ensure consistent and meaningful feedback provided on policies, programs and services.