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April 22, 2015
Hon. Yasir Naqvi
Minister of Community Safety and Correctional Services
18th Floor
25 Grosvenor St.
Toronto ON M7A1Y6
Dear Minister,
The Ontario Human Rights Commission (OHRC) welcomes your Ministry’s consideration of legislating standards set out in the Ontario Association of Chiefs of Police 2014 Guideline for Police Record Checks.
We agree there is a lack of consistency with the various levels of record checks and their purposes, as well as the types of information disclosed. The OHRC has raised concern for a while now that police record checks have a negative impact on people with mental health disabilities who have non-criminal contact with police. That’s why we got involved in the development of the first OACP Guideline and endorsed its release in 2011.
Police record checks also have negative impacts on other groups protected under Ontario’s Human Rights Code, particularly Indigenous peoples and racialized communities, causing a barrier to accessing employment, housing and other services. Mandating standards for police record checks, while important and necessary, will not be enough to address these concerns.
There is a broader view that changes to Ontario’s Human Rights Code could help support the objectives of mandating police record checks standards as well as help bring a better balance to public policy goals for human rights, privacy, offender rehabilitation, crime prevention and public safety.
Please find attached a more detailed submission of our comments. We welcome further opportunity to discuss our views.
Sincerely,
Ruth Goba
Interim Chief Commissioner
Ontario Human Rights Commissioner
Copy: Hon. Madeleine Meilleur, Attorney General of Ontario
Brian Beamish, Information and Privacy Commissioner of Ontario
Chief Jennifer Evans (Peel Regional Police), President of the Ontario Association of Chiefs of Police
Bruce Simpson, President of the John Howard Society of Ontario
Richard Pound, President of the Canadian Civil Liberties Association