Review of the Immigration Control
Officer Network – Final Report

3.2 Roles and Responsibilities

As described in section 2.0, the traditional roles of the ICO have included interdiction, intelligence and reporting, as well as liaison activities. However, the roles and responsibilities of the ICO have expanded since the position’s inception.

The extent to which the ICO is involved in each of these activities varies significantly from mission to mission. For example, some ICOs allocate more of their time to intelligence gathering and reporting activities than to interdiction activities (such as monitoring passenger check-in and boarding at airports). This variance among the missions reflects the assessment of priorities by the program manager and the ICO. The total time allocated to these three activities also varies significantly from mission to mission, based on immediate needs and risks facing the mission. Some ICOs spend as little as 35 percent of their total time on traditional ICO activities (interdiction, intelligence and reporting, and liaison), while others spend as much as 100 percent of their total time this way.

ICOs have also been engaged in other activities that, traditionally, were not identified as ICO activities. These include the following:

  • visa applicant processing and security screening (B-checks), and criminality checks;
  • organized crime intelligence and reporting; and
  • fraud investigations.

There are a number of issues and concerns related to involving the ICO in these activities, which are described in more detail below.

3.2.1 Overall Role of the ICO

From location to location, ICO activities vary significantly from two perspectives. They vary in terms of the activities the ICO is involved in, as well as the extent to which the ICO undertakes certain activities. The ICO Network was created with a specific vision and desired outcome. ICO sites have been carefully chosen, based on their need for ICO services. What must also be appreciated is that the ICO is a member of the team in a mission trying to deliver various programs on behalf of the Department. This fact does not mean that the ICO should undertake multiple activities related to a multitude of programs in the mission. For example, a visa officer would not train airline personnel (unless the visa officer was being used as backup resource). Therefore, while it is important to allow program managers the flexibility to allocate resources to issues or priorities of the location, it is also important to uphold the intent and role of the ICO.

The following is a proposed outline for a generic ICO job description and operating principle.

Operating Principle

The ICO is responsible for monitoring, analysing, reporting and interdicting the movement of inadmissible passengers to Canada. The ICO is responsible for establishing and maintaining a network of contacts among host country officials and officials of other like-minded governments, airline personnel and law enforcement agents.

ICO-Related Activities

The following section lists ICO-related activities. The extent to which these activities are conducted will vary, mission-by-mission. Discussions with the missions show that they face widely disparate situations. For example, in (section removed), the two ICOs are in a consulate where no immigration activities are conducted. In this case, it would be reasonable to assume that 100 percent of their time would be spent on ICO-related activities. In other missions, such as (section removed), there are only two senior officers—the program manager and the ICO. In this case, the ICO provides backup to the program manager; therefore, it would not be reasonable to expect the ICO to dedicate 100 percent of his or her time to ICO-related duties. In this case, the ICO will also be assisting in visa processing activities and answering technical questions staff may have.

The duties of an ICO are as follows.

  • Interdiction
    • Monitoring passenger check-in and boarding at airports.
    • Monitoring airline compliance under the terms of memoranda of agreement.
    • Providing training for airline staff or designates in document examination and in verification of Canadian travel documents and visas.
    • Collecting, analysing and disseminating interdiction-related information.
  • Intelligence and Reporting
    • Gathering, analysing and disseminating information on inadmissible passengers (for example, information on demographics, mass migrations, illegal migration trends and routes, and host government enforcement initiatives and policies).
  • Liaison
    • Developing and maintaining networks of contacts in the host country among immigration and customs officials, police authorities, airport security staff, intelligence agents, political contacts and so on.
  • Other
    • Facilitating removals.

The ICO’s allocation of time to these activities should be equal to, or greater than, 80 percent of his or her total time. If an ICO is spending less than 80 percent of his or her time on an annual basis on ICO duties, then an assessment should be made as to whether an ICO is really required or whether another type of officer would be more suitable. A specially trained position has been allocated to the particular location to perform specific tasks of interdiction, liaison, reporting and intelligence. If the individual is not spending 80 percent of his or her time on these activities, then why was an ICO allocated to the site and why was specialized training provided? In assessing this situation, it is important to note the following:

  • the ICO is part of a team delivering CIC programs;
  • as part of a team, the ICO should be expected to perform non-ICO related duties to support CIC; and
  • some immigration programs, such as (section removed), are smaller, and therefore the ICO may have broader non-ICO duties than would an ICO in a larger program, such as (section removed).

In a given year, an ICO may spend less than 80 percent of his or her time on ICO-related duties, reflecting the issues and priorities faced by the mission. Eighty percent is meant as a benchmark for ICOs. If they are spending less than 80 percent of their time on ICO-related duties, the Enforcement Branch, IR and program managers need to be in agreement about the reasons and the length of time that this situation will occur. The objective is not to build a fence or wall around the ICO but rather to have a disciplined process in place that links the rationale for having an ICO in a specific location with the appropriate training for the actual duties of the ICO.

Recommendation 2

A generic ICO job description should be developed, along the lines set out in this report, to include a baseline percentage of the ICO’s dedication to this function. The proposed management framework must hold the program manager or ICO accountable for any deviation from the baseline percentage. Once the job description is approved, a communication strategy should be developed to ensure that all stakeholders are informed and understand the operating principle and job description of the ICO.

Management Response

Management agrees in principle that a generic ICO job description should be developed that is acceptable to all three branches—the Enforcement Branch, IR and the Case Management Branch—and that program managers should be held accountable for meeting the agreed-on objectives (see recommendations 7 and 8).

3.2.2 Visa Application Processing and Security Screening

These activities are clearly not ICO activities. They are part of the visa officer’s job description. Some locations have been utilizing the ICO as a resource on a consistent basis to undertake some of the interviews or other processing activities related to the visa application process. This is inconsistent with the intent of the ICO position and role in the mission.

Some locations have centralized security screening activities within the ICO unit. In other locations, one visa officer carries out these activities. Other locations make security screening part of the multiple checks the visa officers need to undertake. One of the reasons for centralizing security screening within the ICO unit relates to the relationships and liaisons the ICO has with the RCMP or local enforcement agencies. While there is some merit in centralizing security screening within the ICO unit, this activity is more of a processing activity, which has already been identified as an activity to be carried out by a visa officer and not by an ICO. In addition, there are other activities—such as processing refugees (done by ICOs in (section removed), for example)—that should also be viewed as non-ICO duties.

There are a number of reasons for this situation. However, the contributor indicated most often by the interviewees was Program Review. The size of the cuts faced by the Department at that time meant managers had to find ways of meeting program needs with fewer resources. As a result, ICOs in some locations have been doing less ICO work and, in some cases, mostly non-ICO-related work. In other locations, the ICO has been utilized as a backup resource or to assist during peak times.

While such use should not be the norm, it is important to allow a program manager the flexibility to allocate resources according to priorities and urgencies of the day and location. However, if the program manager deems it necessary to have the ICO consistently involved in visa-processing activities, the resource allocation process should be revisited at the end of the year to determine whether a visa officer is required rather than an ICO. The allocation issue will be discussed further in section 3.3, Assignment of ICOs.

Recommendation 3

ICOs should not be involved in routine visa processing activities, including selection interviews and security screening.

Management Response

Management agrees with this recommendation.

3.2.3 Organized Crime Activities

(section removed).

(section removed) ICO positions have been dedicated to activities related to organized crime. The methods, tools, approaches and risks associated with organized crime investigations are quite different from the typical role of ICOs. They involve common intelligence activities but they are not focused on the same area. Much of the organized crime intelligence is related to law enforcement and a wide range of criminal activities. The focus from an interdiction standpoint is on issues related to the smuggling of people—for example, counterfeit travel documents and organized movements. (section removed)

There is a need to define the activities related to organized crime investigations and the associated skills, tools and approaches. Once these have been defined, (section removed). The Case Management Branch and IR will also need to determine who is best suited to undertake this role.

Recommendation 4

(section removed).

Management Response

Management agrees that some (section removed) for those officers involved in organized crime work and would add that there are issues to be resolved regarding occupational health and safety, and functional guidance, direction and authority.

3.2.4 Fraud Investigations

Fraud refers to misrepresentations made to obtain Canadian travel documentation. The Department is in the process of developing a fraud strategy. In the absence of this strategy, program managers have been developing their own approaches to fraud detection. The approaches vary not only in terms of which frauds are pursued and how, but also in terms of who is involved. In some missions, each officer is responsible for fraud investigation; in other missions, a centralized unit investigates fraud. In a number of cases, this is the ICO unit. Other countries have engaged outside individuals or agencies to investigate activities related to fraud. For example, the (section removed) are using various legal firms.

The investigative work ranges from telephone calls to physical visits investigating whether the information provided by applicants to the Department is accurate. Such activities are important and time consuming. The question is not whether they should be done, (section removed).

Recommendation 5

The Department should develop an anti-fraud policy and strategy that would include the following components:
(section removed)

Once developed, the policy and strategy will define the Department’s position on fraud and how the Department intends to fulfil its role (the definition will include a description of the role of mission resources as part of the overall strategy).

Management Response

Management agrees with this recommendation. Discussions have been held between IR and the Enforcement Branch to begin the development of an anti-fraud strategy.

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