Audit of Operational Controls at
Ports of Entry (Based on the
1996 Tassé Report) – Final Report

2.2.1 Observations at Ports of Entry

Accountability for Immigration Key Control Forms

Throughout the country, the audit team found that most employees knew the importance of securing immigration key control forms, but in practice security in this area was not always adequate; there seemed to be a disconnect between theory and practice.

In most ports of entry, managers were aware of chapter SA6. However, we found that some administrative employees, who were involved in ordering and receiving immigration key control forms, as well as some immigration officers and port of entry supervisors, were not aware of the chapter.

Throughout the country, we found that it was unclear who at the port of entry had the ultimate responsibility and accountability for the control of immigration key control forms.

Chapter SA6 outlines the responsibilities of the “forms control officer” (FCO). All employees who handle immigration key control forms should be made aware of this chapter.

At some sites, the administrative person from the area office or the port of entry ordered and received these immigration key control forms. When forms were on site at the port of entry, a shift supervisor or manager would assume responsibility for monitoring them.

What is needed is clear responsibility for the control of all immigration key control forms. In a sense, the position of FCO could be divided between two staff members (the finance clerk and manager). The responsibilities of this position extend beyond ordering and receiving these documents.

Recording of Generic Immigration Key Control Forms in Logbooks

Except in Ontario, and at three sites in the Quebec and Atlantic regions, there (section removed).

For the most part, the logbooks for manual immigration key control forms issued were adequate. However, manual immigration key control forms are rarely issued—at some sites, they are issued only once a year.

Storage of Immigration Key Control Forms

We found that “deep” storage of immigration key control forms was generally satisfactory. However, we noted the following weaknesses in “working” storage.

  • The manual immigration key control forms (the forms used when FOSS is down) were (section removed).
  • Manual immigration key control forms were found locked in a cabinet, (section removed).
  • (section removed)

At some sites, we found excellent controls for the manual immigration key control forms and the generic forms.

Inventory Counts and Reconciliations

To determine how many immigration key control forms have been used, it is necessary to do periodic inventory counts and reconcile them with the records. For all sites except three, we observed that:

  • (section removed)
  • (section removed)

For reconciliations to occur, complete and accurate logbooks must be in place that show how many immigration key control forms have been issued and how many have been voided. The duties of the FCO are described in chapter SA6, section 3.2(e), as “Recording key forms, and preparing the quarterly and annual inventories.”

Printers

Across the country, only two regions had enclosed (secured) printer stations. Given the fact that (section removed), it is advisable that the Department obtain secure printer locations.

At one site, we noted that the IMM 1442s had been removed from the printers and locked up after working hours, a practice that provides good control.

Transfer of Immigration Key Control Forms to Operational Areas

When immigration key control forms had to be transferred from the area office or administrative area to the port of entry, or from one port of entry to another, we noted that the (section removed).

All employees who transfer documents should initial the logbook. This step acknowledges the accountability and responsibility of the person who does the physical transfer of the immigration key control forms.

Transfer of Immigration Key Control Forms to Outports

Some ports of entry that we visited had outport responsibilities. At two sites, when immigration key control forms were transferred from the port of entry to the outport, (section removed).

The other ports of entry ensured that these transfers of immigration key control forms from the site to the outport were properly recorded.

IMM 1000s: Immigrant Visa and Record of Landing

At two sites, we observed that IMM 1000s (immigrant visas and records of landing) were in the inventory of immigration key control forms.

Only in exceptional cases should a port of entry maintain IMM 1000s. These IMM 1000s should be destroyed or transferred to an inland office.

Excess Supply of Immigration Key Control Forms

At some ports of entry, we found that there were too many manual immigration key control forms on hand. One port of entry had more than 4000 IMM 1097s, even though it issued only about a dozen a year.

Ports of entry should review their usage to ensure that their supply on hand will equal demand. Excess manual immigration key control forms should be transferred or destroyed.

Cancellation and Destruction of Spoiled Immigration Key Control Forms

We observed the following:

  • the serial numbers of destroyed immigration key control forms (section removed)
  • there was no (section removed)

At the time of the audit, the module in FOSS for tracking voided and deleted documentation was just being rolled out. We observed that not all ports of entry were recording such documentation in FOSS.

Recommendations

The regions and the ports of entry should implement the following recommendations.

Recommendation 1: All immigration employees should know the requirements of chapter SA6.

Management Response

Several steps have been taken to deal with this recommendation, as noted below.

Action Plan

1(a) Clarify and update the contents of chapter SA6 (the main source governing the management of control forms at CIC).

CIC’s Information Management and Technologies Branch (IMTB) drafted revisions to chapter SA6 and reviewed similar procedures in related manuals (the POS Manual, the Immigration Control Manual, and a Department of Foreign Affairs and International Trade manual). IMTB presented these revisions for review by the Departmental Control Forms Working Group in the spring of 2002. The completed chapter SA6, with revised form control instructions, was completed and posted on the departmental intranet in September 2002. All employees, including port of entry staff, were advised through an operational memorandum to refer to the new instructions.

1(b) Monitor quarterly and annual reporting by domestic offices.
IMTB dedicated a full-time person to work with all offices. The Branch had excellent results in 2002 as a comprehensive follow-up with all domestic offices indicated that nearly all offices were reporting as per the quarterly schedule.

This is an ongoing process.

1(c) Create a Departmental Control Forms Working Group with broad representation.

Over the last six months, two meetings chaired by IMTB have been held. At the last meeting, revisions to chapter SA6 (in chapter 3 of the Immigration Control Manual) were discussed, along with the need for the policy decisions to be formalized. This is an ongoing process, as meetings are to be held on an ad hoc basis.

1(d) Follow up with FCOs to ensure appropriate monitoring and training is taking place at local offices.

Recommendation 2: Managers should understand that they have ultimate responsibility and accountability for immigration key control forms.

Management Response

Managers will be accountable for immigration key control forms within their offices, as specified in chapter SA6.

Action Plan

As part of the distribution of the revised chapter SA6, a major effort to communicate with all offices will be made. IMTB will arrange to have an article published in Visa, the CIC employee news bulletin, describing FCOs’ responsibilities.

Recommendation 3: Management should ensure regular monitoring and follow-up of control forms logbooks, and recording of control forms in logbooks.

Management Response

Regular monitoring of control forms logbooks will be carried out. Logbooks of control forms will be maintained, and there will be regular monitoring and follow-up of the control forms logbooks.

Action Plan

3(a) Reinforce FCOs’ role.

In every office, an FCO will work with staff to ensure compliance (education and monitoring). The FCO is responsible for logbooks being maintained in the office under his or her care.

This is an ongoing process; the revised chapter SA6 was issued in September 2002.

3(b) Ensure that FCOs monitor local reporting procedures.

All offices will be using appropriate forms IMM 1334, IMM 5425 and IMM 5442 to record information that will be used to reconcile with logbooks and to compile quarterly reports for Information Management (IM).

This is an ongoing process.

3(c) Follow up with FCOs to facilitate, advise and ensure compliance.

IMTB will continue to ensure that appropriate procedures in chapter SA6 detail correct procedures for maintaining logbooks and reporting quarterly.

This is an ongoing process.

Recommendation 4: Deep and working storage should be secured.

Management Response

Weaknesses identified with regard to working storage of control forms will be addressed by FCOs working with staff in local offices.

Action Plan

The audit report indicated that “deep storage” is generally secure. As per action plan item 1(a) above, IMTB manages content of chapter SA6 (the main source of instructions and guidance for the management of control forms at CIC). The new chapter SA6 instructs all offices more precisely on how to manage the bulk of forms in storage until required. Regions will be reminded that FCOs must play key roles in monitoring compliance with working storage procedures at local offices.

Recommendation 5: Regular inventory counts should be conducted and reconciled with physical inventory.

Management Response

Management agrees with this recommendation.

Action Plan

FCOs will conduct regular inventory and reconciliation of control form stock for the offices for which they are responsible. As well, offices will be instructed to order no more than (section removed). IMTB will monitor inventory practices and require inventory reports to be submitted regularly.

This is an ongoing process.

Recommendation 6: Enclosed printer stations should be used for IMM 1442s.

Management Response

Management agrees with this recommendation. Enclosed full document entry printers will be used where control forms are printed.

Action Plan

Since the introduction of the IMM 1442 generic document, which is always printed by FOSS, NHQ has asked regions to ensure that the printers are locked in a cabinet or a room with limited access.

Enclosed, secure cabinets to house printers and supplies of control forms will be acquired for all control form printers in non-secure areas.

A quarterly inventory report is to be submitted to the CIC FCO.

Recommendation 7: Immigration key control forms should be transferred properly from one site to another.

Management Response

Transfer procedures are defined in chapter SA6.

Action Plan

As per chapter SA6, forms are to be transferred only in the most urgent circumstances. The sending office shall (section removed).

Recommendation 8: Required immigration key control forms should be on the premises.

Management Response

Proper inventory control practices will be monitored.

Action Plan

FCOs will conduct regular inventory and reconciliation of control form stock for the offices for which they are responsible. IMTB will monitor inventory practices and require inventory reports to be submitted regularly.

These processes are ongoing.

Recommendation 9: All voided and deleted immigration key control forms should be recorded and destroyed properly and two people should witness the destruction of all immigration key control forms.

Management Response

Management agrees with this recommendation.

Action Plan

As per chapter SA6, IMTB will remind FCOs that the serial numbers of all forms destroyed must be recorded on the IMM 5448, and that two officers must witness this destruction. They shall sign the IMM 5448. A copy of the IMM 5448 must be forwarded to IMTB.

Detailed information on destroying forms will be issued to all offices.

Note: In cases where, in monitoring control form management practices and reporting on the use and destruction of control forms, IMTB notes that any office is not complying with the requirements specified in chapter SA6, IMTB will notify the appropriate authorities in the international and domestic regions, the Director of IMTB, the Director General of IMTB, and the Director General of the region.

Some of these processes have been completed, while others are ongoing.

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