Our brief highlights a number of technical issues that the Canadian Bar Association's immigration law section believes could help. We've put those under the larger umbrella of program improvements that could be made. I think that's what the Government of Canada would like to achieve.
Some of our recommendations are around communication. They sound simple and they sound practical. Maybe it's trite, but in terms of updating clients on delayed applications, it's that issue of how “in process” really means nothing. They include perhaps making a more robust system of where processing status is actually at, with accountability for processing times that are published, and also requesting additional information before refusing applications. As we move to a more automated system, it's about not losing the human element and not forgetting that peoples' lives are affected by the system.
The example of that is express entry, with that sort of one-touch approach that was talked about. It wasn't an official policy, but if peoples' job offers didn't have specific language in the job offers according to the ministerial instructions, they were bounced. I had highly educated people come to me after failing three times in express entry. Simply, there could have been a request for the proper documentation before refusing.
Also in our suggestions is increasing transparency on decision making by giving better written reasons. A suggestion made was to attach the GCMS printout to the rationale for the decision. That isn't really hard to do, and that would make it no longer necessary to do an access to information request to get the reasons in order to understand whether this was just not a viable application or whether it should be appealed or redone.
Those are some suggestions.