Blog Post

Transparency and accountability should be by design

By: Marco Campana
July 6, 2023

I recently attended an IRCC consultation focused on “Client Service Excellence.” The background paper they shared referenced below is here (and embedded down below). I haven't been asked to not share it, so I'm sharing it here with my thoughts.

Participants included SPOs, Immigration lawyer and consultant representatives, a couple of private sector info providers, and a rep from Quebec Immigration, along with a bunch of IRCC folks listening in the background. I searched their names and we had some Directors, an ADM, and perhaps of most interest, IRCC's Chief Digital Officer attending.

As you'll see below the two main discussion questions were:

  1. What are some concrete strategies when it comes to service excellence? How could these be applied to the immigration system?
  2. How can governments at all levels and civil society work together to provide a seamless end-to-end experience for clients (from application, to arrival, to temporary or permanent settlement)?

We had an interesting two-hour discussion which focused on both how IRCC can better serve Newcomers and centre them in their planning and service delivery (as per Government of Canada Digital Standards), but also how the entire system of immigration and settlement navigation and information provision could be made more effective and seamless. You know me, so I spent time talking about how we're talking about this as a sector and that IRCC needs to be more on board. In particular by not abandoning the National Steering Committee on Technology (NCST) process they helped create.

All in all, an interesting conversation with many great points raised by all. I don't know if any of this will be incorporated into IRCC's work or shared beyond having to make an Access to Information request (IRCC's current go-to approach for operational transparency and accountability, it seems), but I'll share whatever they share back from the process.

Here's the background (just copying from emails sent to me to give you more context)

Immigration, Refugees and Citizenship Canada (IRCC) invites you to join a discussion on how to position Canada’s immigration system as a global leader in client service excellence.

This session is being held as part of a broad-based engagement initiative – An Immigration System for Canada’s Future that the Honourable Sean Fraser, Minister of Immigration, Refugees and Citizenship, launched in February 2023. This initiative explores how immigration policies and programs can support a shared vision for Canada’s future. We invite you to learn more about our engagement activities to date by visiting our website.

As part of this initiative, a series of thematic sessions are being held to further delve into specific topics, and explore how we best respond to emerging needs and remain a global leader in the context of evolving migration trends and international challenges.

Providing an exemplary client experience is critical for supporting Canada’s goals of remaining a destination of choice for top talent, visitors and international students. Facilitating a supportive migration journey for immigrants – particularly for refugees and other vulnerable newcomers – is equally important in order to ensure that services are approachable, efficient, easy to use, and digital, where appropriate. To do this well, the Department needs to deliver consistent, accessible, predictable and timely services across its various business lines.

To support your participation in the session, we are pleased to share a background paper on service excellence. We invite you to use it to inform your participation and learning. Feel free to read through it before you enter the session, consult it while you are participating and reflect on it after the discussion. 

While the discussion paper contains many questions to spark your curiosity, during our discussion we will focus on the following two lines of inquiry:

  • What are some concrete strategies when it comes to service excellence? How could these be applied to the immigration system?
  • How can governments at all levels and civil society work together to provide a seamless end-to-end experience for clients (from application, to arrival, to temporary or permanent settlement)?

Client Service Excellence must be based on transparency

I've been mulling over that experience, trying to figure out a good way to share it.

So when I saw a recent post on LinkedIn about Meta (Facebook) sharing how their AI ranking and recommendation system works I thought, well, this is a great comparison of IRCC and what they can do. Because, well, IRCC is kind of the Meta of Canadian government departments. A closed system that changes constantly without really informing anyone, forced to share via federal courts or access to information requests rather than having an actual open sharing system...

If you doubt me, just read this excellent Globe and Mail investigation on IRCC's lack of sharing culture and this 2019 report that focuses on the impacts of automated decision-making in Canada’s immigration and refugee system from a human rights perspective.

Like Meta, this isn't at all a new conversation.

The solution?

A transparent commitment to transparency in sharing not only finished products, but also processes. We know this from discussions about the "black box of AI" and other technologies. How they exclude, discriminate, and oppress. And so, transparency of everything is essential.

As I pushed in the IRCC consultation, the Government of Canada's own Digital Standards recommend work in the open by default, as well as sharing sharing and collaborating in the open. To push for transparency is aligned with Government of Canada standards and vision.

But it isn't actually happening.

So, where to look for inspiration? Shockingly, in this case, from Meta's example.

Anyway, the following posts are useful from this perspective, but also the broader perspective of how we approach AI in our sector (funders included).

Oh, and lest you think I've lost all my cynicism, I don't expect Meta's "revelation" to shift them into some sort of responsible tech company category. Mistrust, confirm, continue mistrusting is the approach to use with them...

But, still interesting:

"When it comes to AI ranking and recommender systems, and other complex algorithms, transparency matters.

More organizations should be doing this: Going beyond stating the high-level principles that govern their AIs, organizations should drill down to the details on specific pillars, such as transparency and explainability. Make it accessible, and help build trust that the whole filed of AI will need for anyone to succeed.

Think why it’s Meta doing this. They know they have trust and credibility problems. They’ve got competition. Differentiating in this way is great for them — and puts them ahead in ways that matter to people. It’s a good strategic choice more companies could make to win trust in their own markets."

"It is no small feat to explain AI. That’s why it took three years, dozens of engagements with amazing experts, thousands of hours spent on writing, design, engineering, translating, data analysis, negotiation to come to today’s launch of AI System Cards: a consistent and detailed way to explain the complex AI systems that power Meta’s ranking and recommender systems.

Please check them out, compare the various cards and learn more about how the technology that powers your social channels is made possible."

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