bout de papier, Vol. 30, No. 4 (2019), pp. 11–14
The hopeful traveller looks over the pile of documents collected as per the checklist: financial, employment and civil documents; passport, proof of prior travel; hotel bookings, flight tickets and a letter of explanation. And of course, the visa application form, summarizing all this information and more. So much paper, scanned and uploaded. The hopeful traveller clicks submit. And then, he waits…
…At the other end of this transaction a visa officer quickly scans through the digital pile of documents, noting the important bits, skimming through the rest. She squints, zooms in, tilting her head sideways as she stares at the screen. There is little time for close scrutiny — dozens of other applications require a decision before the end of the day. Approve or refuse? A decision is made, the response dispatched to the applicant. Depending on the results, he could find himself with official permission to start packing his bags — or staring at a long, dreary tick-box refusal letter informing him, with regret, that he does not meet the requirements for a Canadian visa.
EVERY SINGLE WORKDAY, THIS SCENARIO repeats itself thousands of times, with IRCC officers such as myself across Canada and around the world deciding who will have the privilege of gaining legal entry to Canada. The question is — how do we know we are getting the decision right?
A new network for a complex world
The Risk Assessment Officer (RAO) Network was created by IRCC management just over two years ago in order to help find the answer by providing decision-makers with the intelligence and data they need to make informed decisions. It’s a much-needed function, as IRCC tries to keep up with exploding application intake from huge countries such as India, China and Nigeria and a shifting geopolitical context that seems to become more complex by the day.
As much as we may wish each application to be decided in a clinical fashion, based on verifiable, documentary evidence, the fact is, such an exact threshold is unrealistic. IRCC often deals with people from countries corroded by corruption or devastated by war. Officers know, for example, that it can be difficult to obtain an original document like a police certificate if your local registry has been blown up or where the local authority demands 10,000 rupees for its issuance. Officers also know that a sworn statement from three village elders does not meet the Canadian standard for proving parentage of, say, an infant being sponsored to come to Canada.
The Objectives of Canada’s Immigration and Refugee Protection Act (IRPA) provide an eloquent framework to help guide officers through the thick complexity inherent in processing a truly global clientele. Objectives include: “to enrich and strengthen the social and cultural fabric of Canadian society”; “to see that families are reunited in Canada”; “to facilitate the entry of visitors, students and temporary workers for purposes such as trade, commerce, tourism, international understanding and cultural, educational and scientific activities”; and “to protect public health and safety and to maintain the security of Canadian society.”
But well-written legislation is not enough: local knowledge and, ultimately, judgment come very much into play. With offices in only a few dozen countries and limited contact with clients, visa officers must take a holistic approach to decision making if they’re going to get it right because behind each visa application is a real person with specific motivations for wanting to enter Canada.
Thus, being a visa officer is part art and part science. RAOs are expected to be at the vanguard of the latter, though they are still somewhat in search of a professional identity.
Anti-fraud, and more
The RAO Network evolved out of Anti-Fraud Officer positions that had previously belonged to the Canada Border Services Agency (CBSA). These officers were the leads investigating visa fraud. When CBSA’s overseas priorities changed, however, the positions became available; after much bureaucratic wrangling between IRCC and CBSA in airless Ottawa boardrooms, IRCC found itself with a new corps of officials which it rechristened Risk Assessment Officers. This included a position in London where I’ve been the RAO since the summer of 2016.
However, IRCC management wanted these jobs to be more than just sussing out fake documents. The expectation was that RAOs would play a prominent role within the new “work-sharing” processing model IRCC has deployed to address rapidly rising intake. Work-sharing involves moving work around the global network to where capacity exists. A Nigerian applicant, for example, could have their visa processed in Accra, Nairobi, London or even Ottawa depending on the category in which they apply; a Pakistani visa application could be decided in Abu Dhabi or Warsaw, London or Ottawa.
RAOs are to be at the forefront of decisions to move work across the IRCC network. They are supposed to help identify cases that can be moved from over-burdened visa offices to those where operational capacity exists and help train officers in destination offices, so that they have the information they need to make decisions. RAOs would then follow up with quality assurance exercises meant to ensure these decisions were sound.
RAOs have embraced this role enthusiastically, if inconsistently. Anti-fraud work continues to represent a significant portion of the workload, especially in the many countries where sketchy consultants sell application packages of fake documents to anyone eager to try their luck with a Canadian visa application.
From Ghana, to India, to Vietnam, applicants submit fake bank statements, employment contracts, and payslips; fake diplomas, visas, passports and ID cards; and fake birth, marriage, divorce and death certificates in support of their application, sometimes having paid thousands of dollars to an agent for the documents. The quality varies — some go to great lengths to construct a false identity or fake employment history, showing an admirable attention to detail; others are not as meticulous, submitting blatant fabrications that would fail to fool a grade-schooler. Regardless, RAOs provide training to officers to help them spot these “non-bona fide” applicants so they can be refused, and if found to have misrepresented a fact material to the case, potentially barred from applying again for a period of five years.
This gatekeeper function is important in these times of mass migration flows and rising numbers of asylum claims in Canada and elsewhere. RAOs are expected to broadly define who poses a risk to Canada and who doesn’t, and ensure that decision-makers with various levels of experience have the intelligence required to make sound decisions regardless of where that decision-maker may be located.
Canadians have remained remarkably upbeat about immigration as support has plummeted in countries across the globe. So the stakes are high: the RAO role involves more than just finding fake bank statements and visas. It’s an important component of an immigration system that has wide support across Canada because it is seen as being well-managed: broadly speaking, Canada lets in the people it wants and refuses those who don’t qualify, fairly, efficiently and within the rule of law.
Relevant old school methods
But how does the department quickly approve the applicants that deserve our trust while scrutinizing the ones who do not? How do we accelerate the welcome process for desirable newcomers, while protecting Canada from those who would abuse our trust? RAOs play a key role in answering these crucial questions successfully and in maintaining the integrity of Canada’s immigration programs.
Responding to these challenges is an evolving task and could require embracing different techniques, new and old. Let’s start with the old. Since IRCC has moved increasingly towards electronic processing, where all documents are uploaded and officers see few, if any, originals, IRCC could increase the use of a tool associated with the days before electronic applications: interviews.
With their risk assessment mandate, RAOs are well-placed to take on this role. If anti-fraud work is the reactive response to risk in the caseload, quality assurance is a proactive measure used to identify potential problems up front. A potential component of a quality assurance framework could be a return to interviewing a small sample of applicants on a regular basis — not enough to slow down overall processing times, but enough to be statistically valid. RAOs can take on this responsibility.
Interviewing can be particularly important in countries with unreliable documentation. A skilled interviewing officer can quickly determine whether an applicant indeed has 15 years of experience as, say, a software engineer or nurse, or scrutinize and validate the travel plans of an alleged tourist. The results of these interviews would provide valuable information to decision-makers who may be sitting in an office a continent away and can also feed data crunching systems. In addition, they could further buttress the integrity and credibility of the immigration system. Finally, interviewing could also reconnect visa officers with their clientele, reminding them that they are processing actual people — not just applications.
Data deep dive
Now onto the new. While the anti-fraud stuff can be sexy, it only addresses a portion of the caseload and IRCC’s overall strategy. The majority of applicants are not trying to fool us; they submit genuine documents and have every intention of respecting the terms of their visa issuance. Plus, we want them in our country: Canada’s aging population needs immigrants, our educational institutions need international students, some of our businesses need foreign labour and our hotels, ski resorts and airlines need tourists. Identifying these high-value applicants and quickly finalizing the paperwork is crucial if work-sharing is to be a success and IRCC is to manage the relentless growth of travellers seeking a Canadian visa.
Most agree that a key component of the response will be good data — and knowing what to do with it. That’s GCMS comes in.
The Global Case Management System (GCMS) is IRCC’s IT processing machine. It is not well liked. GCMS is almost comically user-unfriendly: staring at its interface is like looking at a galaxy of text boxes, the screen crammed with a seemingly infinite number of data points in unreadable 8 pt font. Even the simplest task seems to require at least 15 mouse clicks, each less intuitive than the last.
But for all its carpal-tunnel-inducing faults, mastering GCMS’s more complex functions may be the key to the success of the RAO Network and IRCC’s work-sharing struggles. For GCMS’s powerful reporting system is the vehicle for unlocking a treasure trove of data that — if harnessed effectively — can play a huge role in addressing the risk of moving work across the IRCC network by providing a base for predictive analytics. Although less sexy than nabbing fraudsters, leveraging the big data buried within GCMS and other systems is important for maintaining both program integrity and good client service.
Empower innovators – then get out of the way!
IRCC is just beginning to put advanced analytics into practice. Meanwhile, GCMS training for RAOs is not yet advanced enough to truly exploit GCMS to its full potential. The department, therefore, is unable to fulfill the potential of this powerful (albeit clunky) tool.
Now is as good a time as any for IRCC to re-examine how it trains and develops RAOs and other visa officers, who rightly spend considerable time learning the Immigration Act and Regulations — but far less mastering GCMS and its various capabilities. Effective training must combine knowledge of the Act and Regulations with a robust component on the more technical skills required of today’s visa officer. The expectation that officers will “learn GCMS on the job” is outdated and inefficient. Meanwhile mid-career officers need additional classroom training to maintain their skills and knowledge while expanding their horizons based on new ideas and methods of doing business.
In addition, it is critical that the department demonstrate that it is capable of evolving, harnessing technology and talent in equal measures. Fresh ideas are needed, like deploying data analysts overseas, or creating a viable analytics hub where program experts (i.e. visa officers) sit side-by-side with data analysts to produce the relevant information, statistical analysis and intelligence required to fuel an efficient and dependable work-sharing operation — instead of siloed in separate branches as is currently the case.
Innovative, tech-savvy officers — many of whom have already “hacked” GCMS on their own time to create new tools for improving application processing — should be identified and empowered to work on advancing predictive analytics and the leveraging of Big Data. Senior management engagement will be critical in order to protect these resources from outside meddling and surmount bureaucratic rules and sclerotic departmental structures that could hinder progress and get in the way of creative thinking. Finally, creativity, innovation and risk-taking need to move from buzz-words on a PowerPoint deck to being essential components of how we operate as a department.
Canada welcomes large numbers of immigrants and foreign visitors each year while maintaining a tolerant and open attitude towards newcomers. This delicate balance is admired around the world. When it comes to selecting, welcoming and integrating new immigrants it is difficult to argue that any other country does it better. At this critical historical juncture, where borders are slamming shut across the globe as the number of migrants on the move is at record levels, it is crucial that Canada not lose track of what has allowed it to maintain its openness towards new arrivals. A key element is a managed migration system led by a department with specially trained staff dedicated to upholding the objectives of IRPA.
The creation of the RAO Network is a step in the right direction — acknowledgment by IRCC that it recognizes the challenges of accepting ever-growing numbers of newcomers and the opportunities presented by new processes and technologies. But simply creating a new network is not enough: a refreshed training program, new data-focused structure and a commitment to innovation are essential if IRCC is to maintain the trust of Canadians.
Originally published in bout de papier, Vol. 30, No. 4 (2019), pp. 11–14. Read the rest of this issue →
