Thank you for the question.
We have multiple suggestions. One of them is that the Canada Border Services Agency should adopt an updated and public code of conduct. That's extremely important.
We're also concerned about the commission possibly refusing to handle a complaint when a parallel process is under way. We feel it's very important that the commission be able to handle matters that concern it, but also that it clearly inform the individual of other parallel processes should it refuse, say, to handle a complaint because it falls under another jurisdiction.
As you can imagine, we're extremely concerned about the situation of those in detention who don't all have full access to complaint mechanisms, and about where the agency is going by setting up an online complaint system, because detainees don't have access to the Internet right now. I know that's something they're looking at changing, but right now the online complaint system is kind of a more robust parallel process. The follow‑up is not the same at all for complaints made in person or on paper by detainees.
We're also concerned about people detained in provincial institutions rather than at Canada Border Services Agency immigration holding centres, since the commission seems to have limited investigative powers in institutions under provincial jurisdiction.
We provide more details in the executive summary we submitted to you and in our brief, and I also specify some of our recommendations.