When people submit applications to Immigration, Refugees and Citizenship Canada (IRCC) they typically have spent significant time carefully completing forms and assembling documents. They expect that their applications will be processed by visa officers who carefully review the information before them. However, applicants need to understand that artificial intelligence is playing an increasing role in visa processing, as is the bulk processing of applications.
IRCC has not been forthcoming with how it uses technology to process applications, however, through a series of Access to Information Act requests as well as Federal Court of Canada litigation, the public is beginning to get a sense of measures being implemented.
Automated processing of some categories of applications is not new. Since 2015 most visa-exempt foreign nationals have had to apply for an Electronic Travel Authorization before they could board a plane to travel to Canada. These applications were, for the most part, automated applications.
What is less known is that in 2017, IRCC successfully conducted a pilot in which automated systems based on predicative analytics triaged and automatically approved low-risk online temporary resident visa applications from China.
Visa applications were sorted into tiers – the lowest risk for auto-approval, medium and high risk for officer review. This triage model was deployed for all applications from China in 2018, and in the same year was piloted in India. The goal appears to be for artificial intelligence to automatically approve low-risk applications, with officers only manually assessing those that have been flagged as medium to high risk.
In addition to automated triaging, IRCC has also introduced software so that officers can bulk process applications. The software tool is known as Chinook.
According to an affidavit that IRCC filed in Federal Court, Chinook is a standalone tool that streamlines administrative steps. Applicant information is extracted from their applications and presented in a spreadsheet. Visa officers are assigned a workload of applications through Chinook. They are able to see multiple applications at a time on a single spreadsheet.
This allows them to review the contents of multiple applications on a single screen and allows them to complete administrative steps through batch processes. It also allows visa officers to create “risk indicators” and “local word flags” so that officers can identify possible applications in the processing queue of concern or priority.
According to the Federal Court affidavit, when visa officers enter Chinook, a message pops up that says, amongst other things, “The Chinook User Interface allows you to view multiple applications for review and initial assessment. It does not replace reviewing documents… and/or reviewing other information… The refusal notes generator is means to assist with general bona fide refusals. If the notes do not reflect your refusal reasons, please write an individual note.”
There have been many concerns raised about the implementation of automated triaging and Chinook. These include the possibility that it is what has led to increased refusal rates, that individual care is not being given to applications, that applications are not being carefully reviewed and instead quickly bulk refused, that AI flagging a file as high-risk will lead to an officer wanting to simply affirm the AI’s finding, that refusal reasons are increasingly consisting of boiler plate templates which is not helpful for applicants, and that it may perpetuate systemic racism.
Because IRCC has not been transparent about the implementation of these systems and their results, it is difficult to confirm if these concerns are founded. Regardless, it is important that those submitting applications understand that Canada’s immigration system is no longer one in which human officers meticulously process individual applications in the order that they are received. I have previously written about how it is important for individuals with refused applications to obtain the internal reasons for refusal, or Global Case Management System (“GCMS”) notes. IRCC’s use of artificial intelligence and bulk refusal generators makes this even more important, as a review of the internal reasons or GCMS are often indicative of whether such software was used, and whether a refused applicant should either file a reconsideration request or seek judicial review to see if a human may reach a different conclusion.