Evaluation of travellers processing through a GBA+ lens:
5. Conclusion

Note: While a number of GBA+ identity factors could not be explored by this evaluation, it is important that the CBSA consider these identity factors when addressing the evaluation recommendations to account for the diversity of the travelling public.

The CBSA has undertaken efforts to integrate GBA+ considerations within the travellers stream, in support of Government of Canada policy initiatives and commitments.

However, as stated in the 2020-2021 Departmental Plan, the CBSA does not maintain an inventory of its programs that collect and keep individual client microdata information to undertake GBA+. The CBSA does not currently measure any travellers stream performance metrics through a GBA+ lens and does not have the reporting or data capacity to do so. This leads to challenges in verifying how travellers are impacted, and in assessing program effectiveness, along the GBA+ lines.

This evaluation experienced challenges associated with operational data collection and entry, retention, availability, consistency, and traceability. The evaluation's attempt to complete a GBA+ of the travellers stream demonstrated the complexities associated with GBA+ as an intersectional analysis tool. In the absence of complete and comprehensive datasets, this evaluation attempted to identify areas of potential concern, through GBA+, in travellers processing.

At the national level, [*] travellers are more likely to be referred and examined than [*] travellers. This is consistent with the belief (based on a combination of experience, training, enforcement trends, and other information sources) [*]. This belief and practice should be further reviewed, through the use of random examinations and analysis of examination results, to determine whether certain improvements are needed.

Travellers from lower socioeconomic countries are [*] referred and examined when compared to incoming passage volumes. While the CBSA does not rely on a single factor to risk assess incoming travellers, this observation suggests that the agency should further examine if this is an unintended consequence of current policy and practice, and whether changes are required.

As for racial and ethnicity considerations, when using citizenship as a proxy, this evaluation's operational data did not indicate that citizens of [*] (who may belong to a racialized community) were targeted for secondary examination more frequently than other citizenship groups. However, the use of proxy measures can be problematic for determining ethnicity and race, as they do not account for the diversity of a country's population (e.g. as a result of global trends in migration). Broader policy and privacy considerations are required to determine how and if the agency should attempt to identify (e.g. self identification), record, and retain data on a traveller's race of ethnicity.

Finally, this evaluation reveals that GBA+ can support program management to improve program effectiveness by analyzing program performance through the GBA+ lens.

To further explore GBA+ in the travellers stream, the agency needs to:

• explore opportunities for GBA+ by reconciling existing demographic data within the agency's operational systems (e.g. PAXIS, SPPH, ICES)
• reduce reliance on manually-collected data sources (e.g. ORA and NTC target tracking^{Footnote 31}) for long-term reporting needs
• assess the benefit and need (e.g. operational versus analytical) for collecting or retaining (e.g. API/PNR data) new or additional demographic information on incoming travellers, with cognizance of data principles and privacy concerns

Based on the evaluation findings, four recommendations have been made in the following key areas:

1. Travellers Data Management (Recommendation 1 and 2)
2. GBA+ Related Training (Recommendation 3)
3. Travellers Policies, Practices, and Guidance (Recommendation 4)

5.1 Travellers data management

While the CBSA continues to strive to normalize GBA+ and integrate it in everyday work practices, the agency does not currently measure travellers stream performance through a GBA+ lens. Data collection, management, and reporting challenges currently limit the agency's ability to undertake innovative and complex GBA+ using operational data. As a result, the evaluation team could not complete a comprehensive GBA+ of the travellers continuum, across all modes.

These challenges can be divided into two main categories:

1. data collection:
   • manual data collection, entry, and monitoring requires high level of effort to capture the desired elements and can result in data quality issues
   • the agency does not always capture the "right" data in a consistent way
   • lack of standardization in how certain data elements are defined (business versus IT definitions)
2. data management and reporting:
   • lack of fully integrated agency and Travellers Program data
   • CBSA IT systems designed in silos and, as a result, it is difficult to reconcile and draw linkages between the information collected
   • agency has not yet adopted a systems-wide, unique identifier that can be used to link traveller data across all relevant IT systems

The Travellers Branch is working with the Enterprise Architecture Division (EAD) to identify and map business and information requirements through the agency Collaboration Platform. According to the EAD, the TB is at an advanced stage in identifying their business requirements. The Intelligence and Enforcement Branch (IEB), in contrast, would benefit from adopting a similar approach to business requirement definition and mapping to support future efforts.

Recommendation 1

The Vice-President (VP) of Strategic Policy Branch should, in collaboration with the VP of Travellers Branch, VP of Intelligence and Enforcement Branch, VP of Commercial and Trade Branch (i.e. Indigenous Affairs Secretariat), VP of Chief Transformation Officer Branch, and VP of Finance and Corporate Management Branch (i.e. Recourse Directorate, CBSA Complaints), formally define the objectives, methodology, and priority areas for data collection, retention, management, and analysis to better support GBA+ in the travellers stream.

Recommendation 2

The VP of Travellers Branch should, in consultation with key branches, develop and seek Executive Committee-level approval of a plan, with implementation timelines and change management strategies, to support the future use and integration of GBA+ in the travellers stream and to leverage the results for improvements in travellers processing.

5.2 GBA+ related training and awareness

There is a need to address gaps in current mandatory training for personnel in the travellers stream and to increase participation in GBA+ related courses, to ensure a common awareness and understanding of the value of GBA+ amongst those responsible for the development of policy and guidance materials, as well as those responsible for frontline operations.^{Footnote 32}

This is also critical in addressing concerns regarding agency culture and in identifying ways to support frontline personnel in the performance of their duties, while improving communication on the role of GBA+, diversity and identity, and anti-racism in an operational, law enforcement context.

Recommendation 3

The VP of the Travellers Branch should, in collaboration with key branches, make the "Processing of Indigenous Travellers and their Sacred Goods" and the "Positive Space at the CBSA" courses, as well as Unconscious Bias training, mandatory for frontline employees in the travellers stream and create a plan to raise awareness of GBA+ related courses (mandatory and non-mandatory) and resources within the public service among all travellers stream employees.

5.3 Travellers policies, practices and guidance

The agency's policies, practices, and guidance can have unintended consequences for diverse groups of travellers, particularly if they have not been developed and/or have not been reviewed through a GBA+ lens.

There is a need to include GBA+ considerations in the development of policy guidance.^{Footnote 33} Further, given concerns around a lack of reporting of incidents of discrimination toward travellers, there is a need to increase support for frontline personnel and management, and to increase awareness among travellers stream personnel of the potential inequities and barriers that may be encountered by diverse groups of travellers within the travellers continuum.^{Footnote 34}

Recommendation 4

The VP of Travellers Branch should, in collaboration with the VP of Human Resources Branch and the VP of Chief Transformation Officer Branch, develop and implement a plan to improve the awareness and reporting of mistreatment and discrimination of travellers witnessed by CBSA personnel, without fear of reprisal.