Question Period Note: Ai And Automation For Immigration Decisions

Concerns about IRCC’s use of automation and artificial intelligence in decision-making on client applications have prompted the development of an AI strategy.

• Embracing technology is essential to modernizing our immigration system and improving client service.

• Advanced analytics help identify routine applications for streamlined processing. This allows us to better manage our work so clients receive decisions sooner.

• Our tools do not refuse or recommend refusing applications. All refusals are made by human officers based on their own review.

• All of IRCC’s advanced analytics tools are continuously reviewed by IRCC employees to make sure they are working as intended and that the results are consistent with applications that receive a full human review.

The use of advanced analytics (AA) enables IRCC to automate some processing steps for routine applications. By leveraging technology, IRCC is able to direct officer resources toward more complex or sensitive applications, and increase the efficiency of our processing.
IRCC follows TBS directives and conducts Algorithmic Impact Assessments (AIA) for all automated systems that play a role in administrative decision-making, whether these systems use AI or not, to promote transparency. The AIA is GC’s oversight process intended to determine risk and reduce potential negative impacts of automated systems.
IRCC’s AI Strategy formalizes our current approach to using AI. While IRCC has developed guidelines and a framework for AI governance for more than a decade, this technology has evolved significantly in that period of time. Our department has been at the forefront of adopting technology responsibly, which means we have previously and will continue to address considerations like fairness, transparency, and privacy.
By developing a cohesive strategy, we’re able to identify our priorities and explore how AI can best support employees and programs across IRCC to better serve our clients.

IRCC use of automated systems
• IRCC is using a number of innovative approaches to manage high application volumes, improve service delivery and enhance the client experience.
• In support of our clients, we are using digital tools to create processing efficiencies where appropriate. IRCC’s approach to automated systems, including those developed and leveraging advanced analytics and AI is, by and large, facilitative in nature. Models are put in place to streamline processing and approve straightforward cases, never to automatically refuse applicants. All models go through a rigorous review process before implementation, to ensure they are equitable, explainable, privacy protecting and technically sound.
• IRCC’s use of automated systems can be divided into the following broad categories:
o Automating positive eligibility determinations
o Distributing applications between officers based on available capacity or the characteristics of the application (e.g. one that requires a decision-maker with local knowledge)
o Identifying applications that may require additional verification
o Creating ‘annotations’ that summarize basic information on each client to reduce officer searches in the Global Case Management System
o Triaging client emails to enable faster replies
o Assessing biometrics

• None of IRCC’s automated systems, including those that have been developed with AA and AI, can refuse an application, nor can they recommend a refusal to an officer. All final decisions to refuse applications are made by officers after thorough review. Officers are provided with training on IRCC’s automated decision support tools to ensure they understand that a lack of an automated approval does not constitute a recommendation to refuse an application.
• IRCC does not allow the use of generative AI tools, such as ChatGPT, in support of decision-making on client applications. The Department is exploring potential benefits to using generative AI in certain other capacities, such as synthesizing information in support of research and policy development. IRCC is approaching generative AI usage with an emphasis on caution, in line with guidance for public servants provided by Treasury Board Secretariat.
• IRCC is finalizing a departmental AI Strategy, outlining a responsible adoption framework for integrating AI across its programs and services. The strategy, which formalizes our approach to using AI, emphasizes the importance of adhering to guiding principles, enhancing AI governance, and aligning with international standards and best practices.
Key projects
• In 2018, IRCC began using advanced analytics to help officers triage online Temporary Resident Visa (TRV) applications from China and India. In January 2022, the China and India models were updated, and a third model was introduced for TRV applications from all other countries. All three of these advanced analytics models function in the same way: they sort incoming files to streamline officer review, and they automatically approve the eligibility portion of certain straightforward applications.
• In spring 2021, IRCC launched another advanced analytics project for in-Canada Family Class spousal and common-law applications. Similar to the TRV models, this project aimed to automate some positive eligibility determinations and enable the strategic allocation of resources so that all applications can benefit from this initiative. All applications that do not receive an automated eligibility approval by the model are sent for an individualized assessment by officers in accordance with standard practice. In May 2024, IRCC expanded its use of advanced analytics to all spousal and partner applications under the family class. Two new tools were launched to help process overseas family class spousal and partner applications to reunite families sooner by automating some positive eligibility determinations.
• In 2023, the Integrity Trends Analysis Tool (ITAT), was launched as part of broader departmental efforts to become a more data-driven organization – one that makes evidence-based decisions with efficiency, consistency and a commitment to program integrity. The goal was to leverage proven technology to optimize globalized risk management in the ever-growing inventory of temporary resident applications.

• ITAT uses AI (machine learning and AA) to uncover risk patterns, which the Department then uses to identify incoming applications that may require further verification. ITAT’s outputs are not shared directly with officers making decisions on individual applications, and ITAT does not automatically put “red flags” on certain clients’ files. Instead, ITAT looks at cases where our officers have confirmed that clients have previously attempted to misuse our programs – for example, by verifying supporting documents and determining that they are fraudulent.

• A two-step, “human-in-the-loop” process helps to guard against the risk that officers might refuse an application simply because it was identified by an automated system. ITAT only reviews data in client applications. It does not automate or replace human decision-making, and it is not used for immigration and criminal investigations.

• In October 2022, IRCC began using advanced analytics to help identify low-complexity in-Canada temporary resident applications (Visitor Records) for positive eligibility determination. The model also optimizes processing by triaging the remainder of cases into homogeneous groups to optimize file management and work sharing.
• In late 2023, IRCC launched an automated decision support tool for International Experience Canada work permit applications. In addition to the posting of an Algorithmic Impact Assessment, the department ramped up transparency efforts by also posting a peer review and a GBA Plus assessment for the model. IRCC will continue to work to post additional assessments along with Algorithmic Impact Assessments for our automated decision support tools to provide a larger window into how these tools are developed and utilized.
• Media coverage has incorrectly suggested that IRCC’s ‘Chinook’ tool employs AI or AA to automate decisions. Chinook is a processing aid that extracts basic information from client applications and displays it in a clear format that is more user-friendly for officers. Chinook is not powered by AI or AA, and does not make or recommend decisions on applications.
Ensuring responsible use of data-driven technologies
• The department has developed detailed guidance, including a Policy Playbook on Automated Support for Decision-making, to help consider how these technologies can be used responsibly, effectively and efficiently. IRCC has also established an internal governance framework to ensure that new decision support tools go through a rigorous review and approval process. A broad-based committee of senior executives acts as the key oversight body in this governance framework.
• IRCC is always working to be a leader in the responsible use of data-driven technologies and has developed its approach to align with the Treasury Board Directive on Automated Decision-Making, as well as other key legal and privacy requirements. To date, IRCC has published more Algorithmic Impact Assessments on Canada’s Open Government Portal than any other federal department or agency.
• Protecting individuals’ personal information continues to be a priority for IRCC as the Department tests new and innovative approaches. The use of personal information for analytics-based processing is in accordance with the Immigration and Refugee Protection Act and the Privacy Act. Its use is consistent with the purpose for which it was initially collected.

• Rules used by tools to approve eligibility have gone through an extensive review process for potential bias impacts.
• Before we explore any technology to support one of our services, multidisciplinary teams assess the quality of data available and the needs specific to that service, including the benefits and impacts for clients, the integrity of our immigration system, and the safety and security of Canadians.