Audit of the Delivery of Bilingual Services to Travellers by the Canada Border Services Agency at Airport and Land-Border Crossings – Follow-up
Context and methodology
In May 2015, the Office of the Commissioner of Official Languages (the Office of the Commissioner) published its audit report on the delivery of bilingual services to travellers by the Canada Border Services Agency (the Agency). This audit, which was carried out at the Agency’s headquarters, included site visits to various points of entry located at airports and land-border crossings. Following the audit, the then Commissioner of Official Languages made eight recommendations to improve the experience of travellers who wish to receive services in the official language of their choice, in accordance with Part IV of the Official Languages Act (the Act).
The eight recommendations of the then Commissioner focused on the following four objectives:
- Ensure that the Agency’s senior management is committed to implementing Part IV of the Act.
- Ensure that the Agency’s designated bilingual points of entry across Canada actively offer service in both official languages and provide services of equal quality in the official language of the traveller’s choice.
- Ensure that the Agency understands and takes into account the needs of official language communitiesFootnote 1 when planning and providing bilingual services.
- Ensure that the Agency monitors and manages the quality of services it provides to the public in both official languages.
In July 2017, the Interim Commissioner of Official Languages started a follow-up of the audit to evaluate and document the measures taken by the Agency to implement her predecessor’s recommendations. Meetings were also held between the Office of the Commissioner and the Agency during the follow-up. The preliminary audit follow-up report was issued on February 6, 2019, following which the Agency provided comments and additional documents. These were analyzed and taken into account in this final audit follow-up report. The Treasury Board of Canada Secretariat also provided information related to Recommendation 1.
The Commissioner of Official Languages recommends that the Canada Border Services Agency annually review official data on the number of passengers at airports where services are provided and take action to:
- provide services of equal quality in both official languages at airports with over 1 million emplaned and deplaned passengers, and
- inform the Treasury Board of Canada Secretariat of any changes to the bilingual designation of offices at airports subsequent to the review.
In the context of the audit, the Agency indicated that its 2014–2017 official languages action plan included an annual review of data published by Statistics Canada on the number of passengers in airports where service is delivered. The institution also indicated that it was taking the necessary actions to fulfill its language obligations and inform the Treasury Board Secretariat of any changes required, as appropriate. The then Commissioner was satisfied with the proposed actions.
In order to evaluate the implementation of this recommendation, discussions were held with the Treasury Board Secretariat to clarify the scope of the Agency’s obligations regarding the application of the Official Languages (Communications with and Services to the Public) Regulations (the Regulations). More specifically, the current Commissioner of Official Languages (the Commissioner) wanted to identify the entity that is responsible for reviewing the conclusive statistics and making the required changes to ensure the delivery of services in both official languages, where required.
The institution was not able to show that it implemented the first component of the recommendation. In fact, although the analysis of the information obtained suggests that the review of data with the purpose of changing the language designation of an office remains, at least in practice, the responsibility of the Treasury Board Secretariat, the obligation to provide bilingual services when required by the Regulations falls upon the institution (the Agency in this case). The Agency therefore has the responsibility to prevent a situation like the one revealed in 2015 at the time of the audit from happening again. It should be recalled that the Kelowna International Airport (which had been meeting the significant demand criterion since 2005), and the airports in Saskatoon (2006) and Regina (2009) did not have procedures or staff in place to provide service of equal quality in both official languages. Whether or not Burolis designates these airports as unilingual offices does not change the Agency’s obligations. In fact, Burolis is a database that centralizes information to inform the public of the language obligations of offices belonging to federal institutions. It must not be used to confirm the obligations of these offices.
In response to the preliminary follow-up report, the Agency maintained its position that the Treasury Board Secretariat was responsible for reviewing data on the number of air passengers, and the Agency was responsible for updating Burolis. While this is an appropriate measure in itself, the Commissioner nonetheless maintains that the Agency must take the necessary steps to monitor the data that determines its obligations at airports across Canada, as it committed to do during the 2015 audit. These obligations become effective once the threshold of one million passengers is reached; therefore, it does not matter whether the Treasury Board Secretariat notifies the institutions concerned—they must take responsibility and be aware of their obligations.
The information submitted by the Agency before and after the preliminary follow-up report does not show that the institution has implemented measures to monitor the volume of passengers in airports and to adapt its procedures in cases where an airport crosses the threshold of a million emplaned and deplaned passengers in a year, since this threshold is an indicator of significant demand in airports. Given that the obligation applies as soon as the conditions described by the Regulations are met, federal institutions need to take action to comply with the Act. The follow-up revealed significant shortcomings in the Agency’s process for identifying its obligations and modifying its services, as applicable. Also, the Agency’s lack of accountability with respect to this issue represents a setback in terms of both the commitment it made in 2015 and meeting its language obligations.
In light of the above, the Agency has not implemented Recommendation 1.
The Commissioner of Official Languages recommends that the Canada Border Services Agency:
- determine and monitor the number of bilingual superintendents needed to ensure service of equal quality in both official languages at designated bilingual points of entry, and
- use this information to ensure the sufficient capacity of bilingual superintendents at designated bilingual points of entry.
At the time of the audit, the Agency indicated that the implementation of new official languages directives to identify needs and enhance the bilingual capacity of incumbents of supervisory positions was included in its 2014–2017 official languages action plan. The then Commissioner was satisfied with the action taken at that point.
In response to this recommendation, the Agency indicated that it had implemented a process for consulting the regional branches to identify the number of bilingual superintendents needed to provide services in both official languages during hours of operation. The Operations Branch also compiled data on the number of bilingual superintendents at each designated bilingual office to be able to compare the data and identify any discrepancies between the two numbers. The Agency proceeded in this manner in order to focus on each region’s expertise regarding its operations and requests for service in French. The exercise was carried out for all ports of entry designated as bilingual across the country, with the exception of those in Quebec, since all superintendents there are bilingual.
The Agency was able to submit to the Office of the Commissioner, at its request, the data obtained in May 2015 and the data obtained as of October 2017. The fact that the Agency was able to quickly provide updated statistics suggests that the institution is able to identify and monitor the number of bilingual superintendents that are needed to deliver services of equal quality in both official languages at designated bilingual points of entry. Therefore, the institution has implemented this component of the recommendation.
According to the second component of the recommendation, the institution had to use the information obtained by implementing the first component in order to ensure sufficient capacity of bilingual superintendents at all ports of entry designated as bilingual. In this respect, two findings stand out from the information submitted by the Agency.
First, the minimum number of bilingual superintendents required, as assessed by the regional branches, increased from 116 in May 2015 to 140 in October 2017. In contrast, the number of bilingual superintendents on the job decreased from 80 to 76 during this same time. When this data is combined, we note that the discrepancy between the minimum number of bilingual superintendents required and the number of bilingual superintendents on the job increased from 36 in May 2015 to 64 in October 2017. Although this finding is of concern, it should also be noted that, in four of the six regions consulted, the number of bilingual superintendents required has increased, which is a sign that the Agency is aware of the need to have more bilingual superintendents.
The Agency indicated that, in 2016, it had raised the linguistic profile of all the superintendent positions in bilingual regions to BBB/BBB. Moreover, the institution implemented a number of language training measures to improve the bilingual capacity of superintendents. One of these measures includes adding to the list of training priorities for 2017–2018 the positions of superintendents located in offices that acquired a bilingual designation during the Regulations compliance review conducted in December 2016.
In addition, the Agency’s language school made a significant change by increasing the promotion of second-language courses among front-line employees. Over the long term, the Agency hopes that this measure will increase the pool of qualified bilingual employees who could apply for superintendent positions. Lastly, in terms of superintendents already on the job who do not have sufficient second language skills, the institution has implemented a “gap closing program,” which consists of an intensive language training program to help employees raise the level of their second language skills to BBB or CBC in less than one year of training.
These measures are all a testament to the Agency’s new approach, which could produce positive results in the long term in addressing the shortage of bilingual superintendents in ports of entry designated as bilingual. However, the change in the numbers submitted by the institution from 2015 to 2017 indicates that, in spite of the implementation of measures to address the situation, the bilingual capacity of superintendents remains a significant issue within the Agency. Moreover, it should be noted that this follow-up did not seek to determine whether the BBB/BBB linguistic profile is sufficient to ensure that the bilingual duties of the superintendent position are performed in terms of delivering service of equal quality in both official languages.
In response to the preliminary follow-up report, the Agency said that it has added superintendent feeder group positions in bilingual regions to its language training priorities for the 2018–2019 and 2019–2020 fiscal years. The Commissioner approves of this initiative, which shows that the institution is continuing its efforts to increase its bilingual capacity, particularly at the superintendent level.
In light of the above, the Agency has partially implemented Recommendation 2.
The Commissioner of Official Languages recommends that the Canada Border Services Agency develop and conduct targeted recruitment activities to promote bilingual front-line service positions. These recruitment activities should be directed toward bilingual audiences across Canada, including official language minority communities.
At the time of the audit, the Agency had a national marketing plan in place to target applicants interested in a Border Services Officer position: primarily bilingual candidates and members of official language communities. The then Commissioner was satisfied with these measures.
In 2015, the Agency carried out an environmental scan to identify and understand the target audience of its recruitment activities and to develop methods for attracting the best applicants. This analysis contributed to the development of a new recruitment strategy in May 2015. Although a focus was placed on using electronic technologies for recruitment, primarily social media, the institution continued its recruitment activities on the ground. In fact, between October 2016 and November 2017, the Agency participated in 88 external recruitment activities, including 63 in communities considered to be bilingual. In spite of these activities, data on the new cohorts of recruits within the Agency between 2015 (the marketing strategy implemented following the audit went into effect in May 2015) and 2017 does not reveal, for the time being, an increase in the percentage of bilingual recruits hired by the Agency.
In fact, between 2013–2014 and 2014–2015, 6 new cohorts led to 535 new border services officers being hired, of which 162, or 30.3%, were bilingual. However, outside of Quebec, the province where almost all officers are bilingual, this percentage drops to 20.6%. Between 2015–2016 and 2016–2017, 11 cohorts of recruits started in their positions. They included 574 new border services officers, of which 172, or 30%, were bilingual. This percentage was slightly lower than the data prior to the implementation of the strategy and the audit. The problem is that when the data from Quebec is removed, there are only 58 new bilingual border services officers out of the 457 employed in the rest of Canada, which is 12.7%.
However, the 2017–2018 recruitment communication strategy could change the landscape by implementing targeted recruitment activities aimed specifically at certain audiences, such as bilingual applicants. These activities aim to address the shortage of bilingual border services officers. Moreover, during the interviews, the Agency notified the Office of the Commissioner of the deployment of recruiters on the ground. Their role is to approach target audiences, such as bilingual people, through discussions with members of official language communities. Since mobility is a real barrier to hiring bilingual officers who could then be relocated anywhere across the country, this new strategy is a step in the right direction in order to approach bilingual applicants in places where their recruitment is more difficult.
The action taken by the Agency since 2015 has yet to allow the organization to increase its bilingual capacity, but recruitment activities targeting official language communities, among others, is a promising approach for addressing the significant shortage of border services officers across the country.
In light of the above, the Agency has partially implemented Recommendation 3.
The Commissioner of Official Languages recommends that the Canada Border Services Agency provide ongoing second-language learning opportunities to bilingual border services officers in all regions to help bilingual officers learn the technical job-related terminology required for their work and to maintain their second-official-language skills.
At the time of the initial audit, the Agency had planned to issue reminders to its employees about language training opportunities. The then Commissioner indicated that he was partially satisfied with this response. He highlighted that, although these reminders are important, it is essential for the Agency to continue to come up with new opportunities for learning or retaining skills and to enhance the provision of language training for its employees.
For the 2017–2018 school year, the Agency identified eight priorities for accessing language training at its language school. One of these was a type of residual category for employees who were not included in one of the seven other priorities but who still wished to receive language training. This change testifies to changes in the Agency’s philosophy in terms of language training. In fact, the hiring of new second-language instructors allowed the institution to review its training model and provide more training opportunities to its employees, primarily in ports of entry.
Another change to be noted is that, starting in 2018–2019, all languages classes now have an equivalent in the other official language, which helped increase the learning opportunities of employees. Employees who wish to improve or retain their English-language skills now have an opportunity to do so, where previously there were fewer such opportunities. In addition to the new learning programs offered (such as grammar courses and short simulation sessions), the Agency indicated it was focusing on flexibility as a way to appeal to learners in order to offer customized service that meets the needs of border services officers, whether for training or skills retention.
Training programs are promoted on a large scale among all border services officers across the country, who can then register following the appropriate regional procedure. According to the Commissioner, a standardized procedure would be desirable because, currently, some registrations need to be approved by a committee, while others are approved directly by a manager, which is faster. Aside from training, within the Agency, each region is responsible for promoting second-language activities. As a result, the Commissioner encourages the institution to promote the sharing of initiatives and good practices among the regions in order to contribute to the true presence of both official languages and the retention of its employees’ skills.
In light of the above, the Agency has implemented Recommendation 4.
The Commissioner of Official Languages recommends that the Canada Border Services Agency:
- at headquarters, define and communicate to all service employees what is required to provide service of equal quality in both official languages;
- at all designated bilingual ports of entry, adapt and implement shift planning and port procedures as needed so as to ensure that service of equal quality in both official languages is actively offered and provided for all of its service activities at all levels of inspection during all hours of operation; and
- at headquarters, verify that the above-mentioned procedures have been implemented at all designated bilingual ports of entry.
At the time of the audit, the Agency indicated that it wanted to continue its initiatives to increase its bilingual capacity and to continue to remind its officers of the language obligations. The then Commissioner emphasized that, aside from the issue of bilingual capacity, the procedures implemented in certain ports of entry did not always guarantee service of equal quality.
In the context of this follow-up, in terms of the definition of substantive equality, the Agency’s response does not reveal that it has defined the elements necessary for the delivery of service of equal quality in both official languages. The institution did issue reminders to its employees about the language obligations, but these reminders specifically targeted active offer and the rights and obligations of employees, rather than service to the public. The other tools made available to officers, such as the pocket translator and the list of bilingual employees, are additional tools to help officers in their work. However, they do not help deliver service of equal quality in both languages.
In its response to this recommendation, the Agency stated that the principle of substantive equality is difficult to define because of the various needs and expectations of members of the public across the country. However, this is a reality that the institution must address, and it is the institution’s responsibility to take action to ensure that its services comply with this principle. The Agency’s poor bilingual capacity is a barrier to achieving this objective. However, the creation of procedures that take into account the principle of substantive equality would quite likely contribute to improving service to the public in both official languages. For now, the Agency has not been able to show that it has implemented specific measures to identify what a service of equal quality in both official languages means in order to better equip its officers and help them put this concept into practice.
In response to the preliminary follow-up report, the Agency said that it has developed a new directive on service to the public that defines service of equal quality in both official languages. The directive is still in the approval stage but is scheduled to take effect in the 2019–2020 fiscal year. It is an important step in ensuring that all Agency employees are informed of their obligations and in helping them to meet their obligations through the development of new tools and procedures. By clarifying the obligations of employees who serve the public, this essential definition should ultimately improve the quality of service provided to travellers. Given the importance of the directive in ensuring service of equal quality in both official languages, the fact that it has yet to be implemented four years after the audit is a concern. Employees throughout the Agency need to have a common understanding of their obligations, and the lack of this type of directive is an obstacle to meeting this objective.
Moreover, in terms of bilingual capacity, the second component of Recommendation 5 targets the shift planning procedures. A follow-up of the recommendations of an investigation carried out by the Office of the Commissioner in 2016 indicated positive impacts from the new shift planning system, primarily in terms of taking into account the language skills of front-line employees for last-minute replacements.
In addition, in March 2016, the Agency launched a pilot project at the Lansdowne port of entry, in the Thousand Islands, Ontario, to ensure the availability of service in French for travellers who wish to be served in this language. This initiative involved assigning a bilingual border services officer only for requests for service in French, to the exclusion of any other tasks. The very strong results of this pilot project led the Lansdowne port of entry to implement this measure on a permanent basis.
The Commissioner congratulates the Agency for being creative in improving the availability of service in both official languages other than by increasing bilingual capacity. Moreover, the Commissioner encourages the institution to use the findings from this pilot project and to continue to innovate to increase the availability of its services in both official languages and to improve its practices and procedures to ensure that they guarantee service of equal quality in both official languages.
In light of the above, the Agency has partially implemented Recommendation 5.
The Commissioner of Official Languages recommends that the Canada Border Services Agency:
- ensure that it fully understands the needs of official language minority communities by developing a formal national process to communicate with these communities across Canada, and
- develop and adopt a formal mechanism that takes the needs of official language minority communities into account during service planning and modification.
In the context of the audit, the Agency indicated that it wanted to continue discussions with official language communities in order to include their needs when planning and modifying services. The then Commissioner indicated that he was partially satisfied with the proposed measure because of the lack of a formal communication mechanism with official language communities and the consideration of their needs, particularly since such a mechanism was also not included in the action plan at the time.
In October 2015, the Agency sent letters to various organizations representing official language communities with the goal of establishing a dialogue with them. The purpose of this exercise was to improve the planning of the Agency’s programs and activities. In addition, the 2016–2019 action plan formalized this exercise and included a process for consulting official language communities that takes into account their needs and the subsequent adaptation of the Agency’s services, where necessary. This process provides for the regional directors general to ask members of official language communities for feedback every year, particularly on how the institution can address their concerns. It is critical for the Agency to continue to have these types of discussions with members of official language communities and to be able to adapt its services and programs accordingly.
This formal consultation process is in addition to regional initiatives, such as the participation of representatives from the Atlantic Region in the Atlantic Federal Council regarding section 41 of the Act and the participation of the regional official languages advisor for the Pacific Region in the British Columbia Federal Council. Representatives of the Northern Ontario and Southern Ontario regions also led discussions with associations representing official language communities in their respective regions.
The Commissioner encourages the Agency to continue its regular discussions with associations representing official language communities to build a long-term relationship of trust to ensure that the consideration of the needs of members of these communities is included in the planning of services. The Agency could also consider the possibility of pairing these discussions with the components of its recruitment strategy involving official language communities, particularly in a context where the mobility of applicants has been raised as a barrier to hiring new bilingual officers, in that many would prefer to work near their current community.
In light of the above, the Agency has implemented Recommendation 6.
The Commissioner of Official Languages recommends that the Canada Border Services Agency conduct an immediate review of its services in order to determine whether they satisfy the principle of substantive equality and, following the review, adapt its services, as necessary, to meet the needs of official language minority communities.
At the time of the audit, the Agency indicated that its 2014–2017 official languages action plan included an assessment of its services and programs in order to determine whether they complied with the principle of substantive equality. The then Commissioner indicated that he was satisfied with this measure.
The Human Resources Branch assessed the Agency’s list of programs to identify the ones that relate particularly to service to the public. The purpose of this exercise was to identify the nature of the services offered by these programs and to determine whether they needed to be modified so that their services could be adapted to official language communities.
This exercise allowed the institution to identify three programs that in particular involve contact with the travelling public, primarily members of official language communities, as follows: the Trusted Trader Program, the Trusted Traveller Program and the Recourse Program. The results of the analysis later conducted by the Agency show that these three programs were well adapted to the reality of members of official language communities and that, therefore, no modifications were necessary to ensure service of equal quality in both official languages. According to the institution, although this exercise did not lead to any changes, it allowed the Agency to get a fresh perspective on its various programs and to look for opportunities for improvement regarding service to the public, primarily for members of official language communities. However, the exercise was aimed at specific programs only, and this type of analysis should be carried out for all services provided to the public by the Agency.
Moreover, in the follow-up to the audit, the institution agreed that the current model for service delivery to the travelling public is not optimal for the needs of official language communities and that the review did not truly target this issue because it was primarily focused on the programs. The Agency has nonetheless mentioned that it is aware of this shortcoming and wishes to implement a functional approach in the context of the institution’s renewal. This change should help to improve service, primarily in terms of taking into account the needs of official language communities. In its response to the preliminary follow-up report, the Agency stated that its 2019–2022 action plan will include the implementation of a new mechanism to assess each new program to determine whether it respects the principle of substantive equality and to make any changes, if necessary.
In light of the above, the Agency has partially implemented Recommendation 7.
The Commissioner of Official Languages recommends that the Canada Border Services Agency:
- implement, across its entire organization, reliable and anonymous monitoring of the active offer of service and the delivery of services of equal quality in the official language of the traveller’s choice, and
- use the results of that monitoring to improve services in both official languages.
At the time of the audit, the Agency discussed the limitations in terms of opportunities for monitoring active offer because of difficulties associated with repeated border crossings but was committed to establishing mechanisms to monitor the availability and quality of service to the public in both official languages. In this respect, the then Commissioner indicated that monitoring the visual and telephone-based active offer was not sufficient and that the Agency had to develop a formal, reliable and anonymous monitoring mechanism for active offer and the availability of in-person service in both official languages.
In response to Recommendation 8, the institution focused on its mechanism for assessing management practices, which is more of a diagnostic tool than a true assessment of the measures in place at the ports of entry. Although these assessments are useful for determining the effectiveness of the measures in place at a specific port of entry and their improvement over time, they are based on facilitated conversations, which can only provide a piece of the picture. Moreover, due to budget restraints, the Agency was able to carry out only five assessments in two years, although the standard was previously eight to ten a year.
The other measures in place include regional initiatives, such as the telephone observations conducted every month by the Pacific Region’s official languages committee to evaluate active offer by telephone. The Operations Branch currently conducts this type of evaluation at a national level every year. The Agency indicated that the results of these observations are positive: that is, that employees who answer the telephone do provide an active offer. Lastly, the Agency maintains that it is the responsibility of superintendents to monitor the delivery of active offer and the quality of service in order to ensure that the public’s official languages rights are respected and to take corrective action, where appropriate. In this respect, although the performance assessments of superintendents should reflect the results of this monitoring, it remains that the lack of a formal mechanism makes the results of this type of monitoring somewhat sporadic.
The measures in place at the Agency all include some of the desired elements of a monitoring mechanism for active offer and for the delivery of service in the official language of the traveller’s choice, but none of them provide information from an anonymous monitoring mechanism that assesses active offer and the availability of equal service in both official languages in person. The audit report published in 2015 clearly indicates that the Agency was to establish such a mechanism and use the results to improve its services in both official languages. The data submitted by the institution and the interviews carried out in the context of this follow-up suggest that border services officers are aware of their obligation to provide an active offer but that they do not systematically comply with this obligation, which infringes on the rights of the public regarding official languages.
In early 2018, the Office of the Commissioner conducted observation exercises on bilingual services provided to the public by 10 federal institutions, including the Agency. The purpose of these exercises was to evaluate active offer and the availability of service in the official language of the linguistic minority. In response to this exercise, in which the Agency fully cooperated, the institution reiterated that a mystery traveller mechanism such as the one used on an exploratory basis during the observations is not viable because of the particular challenges, including those of a legal nature, posed by crossing the border during such an exercise. Despite these challenges, the Commissioner nevertheless encourages the institution to explore other methodological options that would allow it to monitor active offer and the provision of services of equal quality in the official language of the traveller’s choice. Without this type of systematic and anonymous mechanism, it is very difficult for the Agency to get the essential data it needs to develop procedures and tools tailored to its own challenges.
In light of the above, the Agency has not implemented Recommendation 8.
The follow-up of the audit on the delivery of bilingual services to travellers by the institution revealed that the Agency has made progress in several areas where shortcomings were identified at the time of the 2015 audit. In particular, the institution showed creativity regarding language training and launched a pilot project with encouraging results that deserve particular attention in developing new procedures for improving the quality of service to the public in both official languages. The Commissioner encourages the Agency to be similarly creative in addressing the remaining shortcomings.
Overall, the Agency’s insufficient bilingual capacity remains a major systemic barrier to complying with its official languages obligations. The new recruitment and training approaches are two promising avenues for improving the institution’s capacity to provide service of equal quality in both official languages, but the positive impacts on the ground remain to be seen. This problem is compounded by the fact that, four years after the audit, there is still no clear definition of substantive equality of services.
The Commissioner is particularly disappointed with the Agency’s lack of accountability with respect to the first recommendation and its lack of initiative to introduce a formal and anonymous monitoring mechanism for its services to the public. The lack of this type of mechanism is a significant shortcoming that results in the institution’s not having the information it needs to improve its procedures for serving the public.
In conclusion, this follow-up revealed that recommendations : recommendation 4 and recommendation 6 were implemented, whereas recommendations : recommendation 2, recommendation 3, recommendation 5 and recommendation 7 were partially implemented. Recommendations :recommendation 1 and recommendation 8 were not implemented and remain important elements on which the Agency should continue to focus to improve the availability and quality of its service to the public in both official languages.
The Commissioner commends the Agency on its cooperation throughout the audit follow-up and on its genuine willingness to improve the quality of services it provides to the travelling public at airport and land-border points of entry across Canada. Unfortunately, that willingness is not always supported by actions that produce concrete outcomes. Four years after the audit was conducted by the Office of the Commissioner, the Agency has gone back on some of the commitments it made during the audit, which calls into question both its commitment to improving its situation and its leadership. Canadians will not be able to expect real progress until the Agency takes responsibility by committing to overcoming the remaining obstacles to its meeting its objectives under the Act.