The Game of Progress in Canada’s International Student Policy, Part 2

By Earl Blaney (RCIC)

This is part 2 of a two-part article. Part 1 appeared in the January 2022 issue of ImmQuest.

Amongst the elusive challenges international students are forced to undertake, all avoidable, if not for the continued focus on increased enrollment, are the following:

Challenge: Avoiding Investment in Dead End Education Programs

It is hard to find a Canadian government policy document that does not mention Canada’s interest in retaining in- ternational students as Permanent Residents (PR) to fill skilled labour market shortages.1 However, despite labour market shortages, large numbers of international students are caught post-graduation in unskilled, low wage jobs.2 So, ifthere isa skillsshortageathighskilledpositions, and a highvolumeofinternationalstudentscomingto Canadato studywithaccesstoskillstraininganda work permit, why is this occurring?

To answer this question, one does not need to look further than who is directing the traffic. The explicit job of educa- tion agents is to guide students towards education pro- grams that will result in immigration application success and yield commission payments for the student’s arrival in Canada. Overseas education agents, most of whom have never been to Canada in the first place, do not have an adept understanding of Canadian labour market needs. If an education agent abroad can send a student to a rural college in British Columbia, because that is where the agent’s bread is buttered, they will, regardless of whether or not the students’ post graduation skill set is best suited for that region, regardless of whether Canada needs those skill sets. This raises a larger question: Why Designated Learning Institutions (DLI) are permitted to market edu- cation programs with no skilled edu-employment out- come to international students in the first place when (in most cases) they are entirely dependant on skilled em- ployment outcomes for student to PR transition success?

The rebuttal from DLI’s would be that not every interna- tional student wants to become a permanent resident of Canada. True, but only in a very limited number of cases, and should it not simply be made clear from the outset? How many international students would come to Canada to study “Protection and Security Investigation” if they un- derstood that the edu-employment outcome of that pro- gram NOC 6541 (skill level C, unskilled)? Or a Travel Services program at a community college resulting in an edu-employment outcome of NOC 6521 (Skill level C, unskilled) if they knew in advance these programs were not conducive to skilled level employment? These considera- tions are not only limited to unskilled outcomes, but in many cases programs are marketed to suggest post gra- duation labour market entry at the highest skill levels, something unattainable for most foreign students. Health Care Administration Leadership and Business Manage- ment programs are good examples of programs that most international students, without significant senior level Canadian work experience would be ill suited to transition into skilled employment positions of matching caliber.

This helps explain why it is easy to find international graduates from all education backgrounds serving you coffee through a drive thru windows on your way to work each morning (NOC 6711, skill level D, unskilled) or ac- cepting your money at gas bars across the country (NOC 6621, skill level D, unskilled); theyarehopingfor promotion to supervisory level experience in those roles (NOC 6311 and NOC 6211, both skill level B, skilled, respectively) which is the only hope they have left.

Challenge: Avoid Bureaucratic Pitfalls

The government of Canada could be doing a much better job. Records show that nearly a decade after its own policy highlighted the priority of using international graduates to fill skilled labour market gaps, Global Affairs Canada has just recently started examining possible options to coordinate labour market demand with edu-export promotion.3

Another significant example of discordance is Economic and Social Development Canada’s recent announcement of a planned rehaul of Canada’s National Occupation Classifi- cation system.4 The changes, converting existing occupation classifications from skill levels to Training, Education, Ex- perience and Responsibilities (TEER) classifications, are ex- pected to have drastic (yet still unknown) impacts on what occupation experience claims will be considered for eco- nomic class eligibility, when IRCC adopts the new system, which is expected to occur sometime in 2022. Meanwhile, international student recruits are already financially com- mitting in advance, to education programs in Canada, blind to how this will impact their investment.

Immigration, Refugee and Citizenship Canada (IRCC) is responsible for evaluating applications for prospective international students who wish to enter Canada to pursue studies. One of the main points of screening5 and causes of study permit refusals6 has always been a negative de- terminationmadeunder Regulation 216 (1) often caused by a R 220.1 determination that the applicant’s primary pur- pose of entry is not related to being a “bonafide student”.7 For example, why would a nurse who has already com- pleted their nursing degree want to come to Canada to pursue further studies in this area? Application refused.8 Refusing prospective international students, with an al- ready established skill set who often seek to enter Canada for studies necessary to meet burdensome occupational regulatory requirements, cannot possibly be the best way to facilitate skills acquisition goals.

One of the early concerns of Canada’s International stu- dent policy was to ensure that programming was estab- lished to meet the highest possible edu-export quality. Of concern was the quality of many of Canada’s private career colleges. It was for this reason that respective provincial Ministries were charged with the creation of a DLI list, and the reason that IRCC has not extended post graduation work permit eligibility to most private career college programs.9 But loopholes have easily been created by public colleges forging partnerships with private career colleges. The former typically granting the credential in the public college’s name, while the education was ad- ministered by the later. This conveniently converted re- spective programs from ineligible to eligible for post graduate work permits (PGPW) and subsequently im- proved the marketing potential to the coveted interna- tional student market. A temporary moratorium of this practice took place, duetoareportoutliningunacceptable risks to students.10 It can only be assumed that the benefit for public colleges is additional revenue, from a further influx of international students, without the need to hire additional resources, although the details these kinds of agreements are kept secret.11

Challenge: Find Jobs Without Guidance

Respective DLI’s are aware of international students’ in- terestinposteducationworkforceintegration success. A review of any DLI’s international student landing page or marketing material will reference grad employment sta- tistics.12 The problem is that although these high-level Key Performance Indicator (KPI) statistics make for excellent marketing material, they have essentially no value for even the most astute international students who would re- search them, as they are not indicators of success rates for specific education programs at the institution, let alone skill level of the job attained by graduates, nor indicators of whether the employment relates to education program completed.

When specific education program graduate data is avail- able (as required by binding policy directives, in Ontario for example),13 often the reporting data is so low (less than 20% of graduates reporting)14 that DLI’s do not want to release this data over concerns of creating a negative im- pression to potential international recruits.15 Typically colleges in Ontario outsource graduate employment data collection to third party companies,16 often based in overseas call centres who’scontactdetailsforthegraduate often reflect the information gathered at the time of re- cruitment process — which means they end up calling the overseas education agent, who has long lost contact with the student, to collect data. As an example, the Ministry of Colleges and Universities, the party responsible for en- suring DLI data collection, is on record expressing the low levels of viability and reliability of data collected, due to poor response rates.

This, in part, explains the poor collection of results that could be used as a tool to provide guidance. However, it is also worth noting that typically the results that are avail- able are about five years out of date.17 Ironically, the same policy directive charges post-secondary institutions with “Taking appropriate corrective action, as necessary, where expected outcomes or quality of performance are not achieved”.18 Of greater concern, perhaps, are the parts of Canada that do not require program specific data to be collected at all.19

Challenge: Overcoming Language Barriers You Didn’t Know You Had

Dropping the requirement to provide the results of a designated language test from a growing list of country specific Study Permit checklists20 is inconsistent with a firm requirement to include a satisfactory language test score with Study Direct stream applications.21 DLI re- cruitment departments have caught on, and are in turn extending waivers to admissions criteria, exempting prospective students from language test scores, despite lack of data to justify such exemptions.22 Trade com- missioners are in the background cheering these devel- opments,23 which make recruitment easier and helps increase outbound targets numbers — their badges of honour. Edu-tech platforms, also eager to benefit from market growth, encourage their vast networks of sub- agents to embrace these kinds of expansive exemptions, andrefrainfromsubmittingoncerequiredtestscoresthat may indicate non-competent language abilities.24 If students are assured that their language competency is notanissue, whichitoftenis,25 promotes false sense of security in the investment they are about to make. But it does help facilitate the investment.

It is worth noting that, although there is a significant amount of pressure on faculty to pass foreign students despite poor performance due to language issues,26 IRCC does not waive English language testing requirements for Permanent Residence applicants (regardless of country of origin), nor do employers in Canada assume English competency(based on country of origin).  Andhere Where the investment risks collapse for the student, although the investment received by DLI is secure.

Challenge: Avoiding Pestilence

The COVID-19 pandemic sent shockwaves through the edu-export industry and as discussed above, did result in the first shrinkage of edu-export in a decade. How much shrinkage would depend on which data set you referred to.27 Logically, part of the reason for this reduction was due to the financial impact on funds available for prospective students and hesitation of foreign nationals to travel. However, Ottawa was sure to leave the option for inter- national students to enter Canada open, despite risks to both students themselves and the Canadian public, pla- cing contributors to this important $21 billion dollar in- dustry on travel exemption lists from the onset of the pandemic.28 In April of 2021, due to the rise of the Delta variant in India and Pakistan, a temporary pause was put into place for direct flights coming from those countries.29 Thebanwaslifted fivemonthslatertothe cheersfrom DLIs on September 27, 2021.30

Of course, some international students entered Canada with undetected infection or were infected after arrival31 and predictably some died.32 There have also been reports of visa or permit clearance being issued without insurance coverage which has left some families of international students in staggering debt.33 And although allowing entry to Canada was good for the business side of things, there are plenty of reports that point to disproportionate psychological trauma resulting from the isolation inter- national students faced during this period.34

Canadian DLIs were required to come up with individual COVID-19 readiness plans before they tookin international students during the pandemic.35 What is clear is that no federal public health authority reviewed these plans. In Ontario, the province accepting the largest volume of in- ternational students during the pandemic, the provincial health authority began a review of each institution’s plan, but due to a large number not meeting expected stan- dards,36 the process was abandoned. Time constraints impacting January 2021 international student arrivals was the concern. The solution? Allow DLI’s to simply self de- clare that their plan was competent paving the way for the arrival of international students on campus.37

Challenge: Avoiding False Starts

Due to the rise of online teaching platforms, IRCC began conducting an internal review of the department’s ap- proach to distance learning, in the context of study permits and post-graduate work authorization in 2017.38 Despite some stakeholder pressure to support online education initiatives with increased policy benefits, such as eligibility for PGWP for online studies, IRCC decided against it. In particular, the decision was justified as follows:

An objective of the Post Graduation Work Permit (the Program) is to support former international students to transition to permanent residency. To achieve this, a certain level of in-class learning during the program of study is REQUIRED to access the Program so as to support the student in establishing social networks, communicate in an official language and improve their overall social capitol.39

It was clear from the policy review that international stu- dents preferred in-class studies for the same reason. IRCC also outlined concerns about the impact of online studies on the quality of education programming as well as pro- gram integrity concerns related to identification verifica- tion.40

Then came COVID-19 and those concerns evaporated by necessity.

There is no doubt that the post graduate work permit program has merit as a cost recovery benefit and work experience program,41 but the real value of the program, from an international student perspective, is the window of opportunity it provides to acquire Canadian skilled work experience typically necessary for a student to PR transi- tion to occur.

During COVID-19, with processing backlogs impacting IRCC’s ability to process and issue study permits and DLI’s across Canada defaulting to online delivery, IRCC was forced to make concessions to Canadian stakeholders who otherwise were about to discover what the real value of Canadian education was without immigration prospects attached.42 IRCC could not allow that to happen. Despite their own research showed it would significantly negatively impact students’ chances of achieving their own invest- ment goals, PGWP eligibility was extended to overseas online studies, even for students who would never set foot in Canada during their study period.43

As early as 2021 there will be entire groups of international students arriving in Canada who have not studied in Ca- nada at all. These online graduates will arrive in Canada to attempt to capitalize on their investment, which in most cases will require them to gain a skilled employment offer on entry and hold skilled employment for the remaining twelve-month period.44 To do so would be a monumental feat, considering a total lack of introduction to the com- plexities of living in Canada, zero understanding of the Canadian workforce culture and the complete lack of Ca- nadian employment references. Imagine showing up in Mumbai with an urgent need to land a career in that city in- stantaneously. These students cannot expect much help from the learning institutions who received their front-end investment, as what limited career services they typically offer are only available to their current student bodies.

Prompted by IRCC’s study permit processing backlog,45 the department’s progressive views related to online education advanced step further. In June 2020, tosave September revenue streams for Canadian stakeholders, IRCC announced in a series of tweets the roll out of a two- stage study permit system designed to facilitate edu-ex- port sales despite significant complications in delivery of the goods.46 Stage 1 (approval in principle) was meant to stoke consumer confidence by providing a type of green light for students to continue their plan of investment, which would not have been possible without some assur- ance of eventual study permit approval. Historically, on average, about one third of all Canadian study permits are refused.47 Trade Commissioners at Canadian missions abroad organized online sessions to ensure recruits that visa officers would evaluate all discretionary aspects of their applications upfront, during stage 1, leaving only non- discretionary medical and criminal checks, for stage 2 (final approval) processing.48Despitethismessaging, which had the impact desired, there were reports of large numbers of students who had invested in education programs based on receiving stage 1 approvals, who were subsequently denied stage 2 approvals for reasons meant to be covered exclusively at stage 1.49 There is at least one law firm in Canada that appears to be evaluating the prospects of a class action suit to recover student losses.50 Meanwhile, these sales still count as net gains for edu-export, despite the impact on the Edu-Canada brand.

Challenge: Accomplish What Many Native Canadians May Not

At most an international graduate has exactly two years from the end of their program completion to attain a skilled employment offer and retain full time skilled level em- ployment for a one-year period before the expiry of their PGWP. Students whose families could only afford one year of international education will have to accomplish the same immediately after graduating from their education program.51 In this way the pressure on international graduates, who are often less advantaged than their Ca- nadian counterparts, is immense.

Graduating from education programs that do not have a clear-cut skilled employment outcome is one problem, but lack of established network, limited cultural integration, problematic language skills, limited recognition of foreign education credentials and work experience all take sig- nificant tolls on the prospects of skilled employment for international graduates.

Finding entry level employment and working their way up the ladder is not an option due to tight time constraints. To meet the eligibility requirements of Canadian Experience Class, the main immigration stream available to facilitate studentto PRtransitions, oneyearofskilledemploymentis required during the PGWP phase.52 If international grad- uates are to integrate into the Canadian skilled labour force, are we giving them a reasonable chance to do so?

Aside from the fact that IRCC recognizes that the current PGWP program is not working well in this regard,53 there are other issues the department may be entirely unaware of. When workers are desperate and vulnerable there is an increased likelihood of exploitation. This is a principle IRCC recognizes as impactful to other streams (for example) the Temporary Foreign Worker program,54 but has not adopted specific protections for international graduates, despite reports of abuses.55

When employers are aware that skilled work is an im- migrationrequirement, agreeing to frame an available job, at least on paper, as a skilled employment experience, becomes a powerful tool for negotiation. These kinds of favours can be held over an international employee’s head throughout their tenure, with the final paperwork meeting IRCC specification, typically only being handed over at the back end of the process.

The End Game

Canada’s International Study Program certainly has the capacity to do more harm than good, but only if consumers of edu-export are better protected. The Government of Canada should take time to reflect on its success in at- tracting large numbers of international students to Ca- nada. Rather than supporting unlimited expansion, the Government of Canada must focus on concrete improve- ments in other areas, to enhance the prospects of long- term sustainability based on consumer satisfaction. Here are some proposed changes, that are not numbers gain related, which have the potential to positively impact Ca- nada’s International Study Program:

1)    Regulate education agents and online recruitment platforms that facilitate recruitment for Canada’s Designated Learning Institutions (DLIs). This move would help Canada keep pace with developments in competitor countries like Australia and New Zealand who have recognized the need for regulation and have established a platform by which consumer protection concerns can be evaluated and actioned upon when appropriate.56

2)    Once regulation occurs, trade commissioners and professional regulatory groups like the ICCRC (Im- migration Consultants of Canada Regulatory Coun- cil) should work at bridging connections between overseas education agents with licensed, authorized immigration service providers who would act as accountable parties for the involved immigration support. This would ensure that prospective immi- grants are receiving the levels of service and protec- tion required by Canadian law.

3)    The federal government, in their annual immigration targets report, should layout a plan outlining clear, minimum targets for international student to Perma-nent Residence transitions. This would provide consu- merswithabetter indication of their likelihood of success before investing and hold the government accountable to ensure better degrees of client satisfaction.

4) IRCC in alignment with Global Affairs Canada (GAC) should consider dividing international student intake into two groups:

  1. A)  International Education Experience Pathway: Would be designed for applicants who are primar- ily interested in returning home after their Cana- dian study and work permit These students could select from an unlimited number of programs, regardless of whether their biodata and education program are well connected to significant skilled, in demand labour market con- tributions.
  2. B)  Student to Permanent Residence Transition Pathway: Wouldbedesignedtoselectperspective students whose biodata as well as education program interest likely align with prospects of future economic class

5) IRCC should review the Post Graduate Work Permit program and consider expanding the allotment of work permit validity timeframes for graduates who are well positioned to make long term contributions to Canada’s Economy, ensuring that graduates have fair chance of success in establishing a skilled employment career path in Canada.

6) Make language testing a mandatory Study Permit application requirement, regardless of country of origin. This will help offset problems international students (and faculty) encounter in classrooms and during the PGWP phase.

7) IRCC’s method of “bonafide student” screening is antiquated and must be revised. Applicants coming to Canadatogainskillsetsvaluableforlabourmarket integrationshouldnot beforcedtopresent otherwise. Rather a screening system must be put in place to evaluate whether “dual intent” type applications are viable or not from the outset. This type of evaluation can likely be managed by existing data analytics technology, the type already commonly used by private immigration firms to assess client’s study to PR transition potential. This evaluation could be built into the Study Permit application process.

8) Post secondary accountability offices across the country should require that designated learning institutions under their watch, identify and insure that appropriate levels of international student support services keep pace with increases in interna- tional student enrollment. If they do not have the power to do so, this must be enacted by legislation.57

9) The Canadian government should provide funding for and help establish an independent, representa- tive, international student organization (like the Council of International Students Australia (CISA) in Australia)58 and give students themselves a seat at the table. This would help ensure that concerns at ground level related to International Student Policy were heard and that the perspective of international students was a consideration in future policy devel- opments.

10) The Federal government should provide respective provincial governments sufficient time to put leg- islation in place to protect international students attending education institutions across Canada. The legislation would be of similar nature to Manitoba’s International Education Act, but admi- nistered by an entity that ensures objective enforce- ment.

Canada’s international reputation, one of the main driving factors in ISP’s success, has been tarnished through recent media reports which highlight concerns for both consumers and program integrity. To repair that damage, and prevent more from occurring, improvements to our system need to take place. In making these adjustments, the Canadian government needs to do a better job at incorporating consumer perspective and care into the system. Allowing stakeholders who are primarily focused on growth and increased profits to control the narrative is certainly not the best way to accomplish that.

End Notes:

1 For example: Building on Success: International Education Strategy (2019-2024) “As most international students are young, have Canadian educational qualifications and in-demand labor skills, and are proficient in one of our official languages, they are often ideal candidates for permanent residency.” The Honourable Ahmed Hussen, P.C., M.P. Minister of Immigration, Refugees and Citizenship. For example: International Education: A Key Driver of Canada’s Future Prosperity “International students choosing to remain in Canada after their studies constitute a desirable source of qualified immigrants who are capable of integrating well into Canadian economy and society.

2 The Post-Graduation Work Permit Program: Proposed Options for Program Redesign (June 2015). Citizenship and Immigration Canada. Available: <https://drive.google.com/file/d/1yfVS9s_DwU6qo0TClRDMMgX0M3lqo kYf/view>.

3 See internal emails from International education Division at GAC related to this topic. Available: <https://drive.google.com/file/d/1ywE8D4w9yr7IVJ8 T7Ahg_BSBnraemTVW/view?usp=sharing>.

4 National Occupation Classification (2021). Government of Canada. Available: https://noc.esdc.gc.ca/Structure/Noc2021?wbdisable=true.

5 Study Permits: Other Considerations. (January 16, 2019). Government of Canada. Available: <https://www.canada.ca/en/immigration-refugees- citizenship/corporate/publications-manuals/operational-bulletins- manuals/temporary-residents/study-permits/other-considerations.html>.

6 Complete Reasons for Refusals. ATIA. Available: https://drive.google.com/file/d/1RGlcSvdl40PWpqxmQL74hwbLv1xLoFtM/view?usp=sharing.

7 Immigration and Refugee Protection Regulations (SOR/2002-227). Government of Canada. Available: <https://laws-lois.justice.gc.ca/eng/ regulations/sor-2002-227/page-34.html#h-689238>.

8 Refusal Grounds Example. Available: <https://drive.google.com/file/d/ 1X85U4GCwfVCz2zl3tajdGi6jgWOHm2OS/view?usp=sharing>.

9 Private Career College Access to Post-Graduation Work Permit Program. See IRCC ATIA release which explains policy that discludes (generally) Private Career College graduates from PGWP eligibility. Available: https://drive.google.com/file/d/1i_e51vJlyZLAmsULHuMvH4Z-ZwSBgA-9/view.

10 Deals Between Public-Private Colleges Pose Unacceptable Risks to Students, Ontario Report Says (April 22, 2018). The Globe and Mail. Available: https://www.theglobeandmail.com/canada/education/article-deals-between-public-private-colleges-pose-unacceptable-risks-to/.

11 For example FOIA requests for details of these agreements are typically withheld in full if requested. Available: <https://drive.google.com/file/d/ 1qAK7Pv5mvPZdHPHTokjJgZZYDstTI3Jx/view?usp=sharing>.

12 Graduate Employment Stat Examples. Available: <https://drive.google.com/file/d/1PFeLaoZKABjuHbSWdobAkKtSkkbh9xd2/view?usp= sharing>.

13 Governance and Accountability Framework (September 2010) Ministry of Training, Colleges and Universities Colleges of Applied Arts and Technology Policy Framework. See page 6. Available: http://www.tcu.gov.on.ca/pepg/documents/GovernanceandAccountabilityFramework2010.pdf.

14 For example, see the following:

Niagara college program specific grad employment statistics. Available:

<https://drive.google.com/file/d/1xLYJ77PmlyE_4qDbq7446Fyso9QxO6an/view>. Fanshawe College program specific grad employment statistics. Available:

https://drive.google.com/file/d/1fypa2fUXNk1yySZROp7wsojP2jWF4aFL/view.

Conestoga College program specific grad employment statistics. Available: <https://drive.google.com/file/d/1Z1-Cb-a2gEVtyaUyIn6L7LMC xgDWv1ad/view>.

15 See email exchanges with Fanshawe College and Conestoga College respectively. Available: <https://drive.google.com/file/d/1q9eWt277AsTey a5sRhKfmNkjUXlLNoOS/view?usp=sharing>.

16 See email from Fanshawe college confirming the use and name of 3rd party company for KPI data collection. Available: <https://drive.google.com/file/d/1JpuS6intkOqMYZxQDcEoIK13CzZ0-fkn/view?usp=sharing>.

17 Graduate Employment Report. Algonquin College. Available: <https:// drive.google.com/file/d/1CqmALv0ihFt9-8LhxdK9IIIWTIGIpzlR/view?usp=sharing>.

18 Governance and Accountability Framework (September 2010) Ministry of Training, Colleges and Universities Colleges of Applied Arts and Technology Policy Framework. See page 5. Available: <http://www.tcu.gov.on.ca/ pepg/documents/GovernanceandAccountabilityFramework2010.pdf>.

19 See email exchange with the government of Nova Scotia. Available:

<https://drive.google.com/file/d/17L-6jvL7-bTb0EsnOeLsru_q7bKph_Uz/ view?usp=sharing>; and see email exchange with Cape Bretton University (for example). Available: <https://drive.google.com/file/d/1o3Ly58w94yT EBPKlalejq7c1BZ_Cnd0B/view?usp=sharing>.

20 Study Permit, Manila Visa Office Instructions. Immigration Canada. Available: <https://www.cic.gc.ca/english/pdf/kits/forms/IMM5836E.pdf>.21 Student Direct Stream (SDS). Government of Canada. Available: <https://www.canada.ca/en/immigration-refugees-citizenship

20 Study Permit, Manila Visa Office Instructions. Immigration Canada. Available: <https://www.cic.gc.ca/english/pdf/kits/forms/IMM5836E. pdf>.

21 Student Direct Stream (SDS). Government of Canada. Available: <https:// www.canada.ca/en/immigration-refugees-citizenship/corporate/ publications-manuals/operational-bulletins-manuals/temporary- residents/study-permits/direct-stream.html>.

22 See for example internal communications Fanshawe College retrieved by way of FIPPA request. Available: <https://drive.google.com/file/d/ 1nBJPX9p3QHbGCddnFVfLRfZFIxTLpSwv/view?usp=sharing>.

23 See trade Commissioner email to DLI representative retrieved by way of ATIA. Available: <https://drive.google.com/file/d/1iFwAkG1W7keBVKTA1N ChuIUqqeh9iAWa/view?usp=sharing>.

24 See email sent in this regard to sub agent network. Available: <https:// drive.google.com/file/d/1X67F9ZuQQL-dOKyVwZaAU7R8ZkztHvGW/ view?usp=sharing>.

25 English Language Testing Issue. Fanshaw College. Available: <https:// drive.google.com/file/d/1ugWIXMdaGgIi6u1P2CXKaN2eFjm-clkF/view? usp=sharing>.

26 Douglas Todd: B.C college faculty feel pressuer to ’pass’ foreign students (August 17, 2017). Vancouver Sun. Available: <https://vancouversun.com/ opinion/columnists/douglas-todd-b-c-college-faculty-feel-pressure-to- pass-foreign-students>.

27  Global Affairs Canada, and CBIE (which uses IRCC data sets) both present different number totals of international students in Canada. CBIE Data Set: TTL 530, 540. Available: <https://cbie.ca/infographic/> GAC Data Set: TTL 730,370. Available: <https://drive.google.com/file/d/1rYLVabcSeNnd732 D-9k_y0OWSyJSUVKU/view?usp=sharing> (likely part of the difference is explained by study permit exemptions).

28 Canada Provides Update on Exemptions to Travel Restrictions to Protect Canadians and Support the Economy (March 27, 2020). Government of Canada. Available: <https://www.canada.ca/en/immigration-refugees- citizenship/news/2020/03/canada-provides-update-on-exemptions-to- travel-restrictions-to-protect-canadians-and-support-the-economy.html>.

29 D’Andrea, Aaron. Canada Extends Ban on Flights from India to August 21 due to Delta Variant Fears (July 19, 2021). Global News. Available: <https:// globalnews.ca/news/8040573/canada-covid-india-flight-ban-august/>.

30 Jiang, Peter. ‘It’s Obviously Good News’: UBC students praise end of India flight ban, one month later (October 27, 2021). The Ubyssey. Available:

<https://www.ubyssey.ca/news/students-praise-lifted-india-flight-ban/>.

31 Rabson, Mia. Hundreds of Travellers to Canada Test Positive for COVID-19 Variants (April 28, 2021). CBC. Available: <https://www.cbc.ca/news/ politics/covid-variants-quarantine-travellers-1.6006046>.

32 Ng, Edward. COVID-19 deaths among immmigrants: Evidence from the early months of the pandemic (June 9, 2021). Statistics Canada. Available:

<https://www150.statcan.gc.ca/n1/pub/45-28-0001/2021001/article/ 00017-eng.htm>.

33 Support Dino and his Family. Gofundme. Available: <https://www.gofund me.com/f/help-dino-and-his-family?utm_campaign=p_cp+share-sheet& utm_medium=copy_link_all&utm_source=customer>.

34 Firang, David. The impact of COVID-19 pandemic on international students in Canada. (2020). International Social Work. 63(6).

35 Coronavirus disease (COVID-19): Designated learning institutions reopening to international students. Governmennt of Canada. Available: <https:// www.canada.ca/en/immigration-refugees-citizenship/services/ coronavirus-covid19/students/approved-dli.html>.

36 See multiple examples of feedback related to problems with DLI Readiness plans identified by public health authorities in Ontario (retrieved by FIPPA November 2021). Available: <https://drive.google.com/file/d/103RPCeU0 3dflxG0M-K2vWSrFJgj3eBAY/view>.

37 See Memorandum to DLI’s, December 23, 2021 from Tamara Gilbert,

Assistant Deputy Minister, Advanced Education and Learner Support Ministry of Colleges and Universities. Available: <https://drive.google.com/file/d/19yOlqlReuZJyZbNOI9bCsRIv5bfBAkT7/view>.

38 See ATIA release (IRCC) Available: <https://drive.google.com/file/d/ 1h8p0wtVN8Pw9WIiycNJ2PoehuQ2FKoAx/view>.

39  Ibid. Page 7.

40 Ibid. Page 8.

41  Evaluation of the Interational Student Program (April 2015). Government of Canada. Available: <https://www.canada.ca/en/immigration-refugees- citizenship/corporate/reports-statistics/evaluations/international-student

-program.html>.

42 See in particular page 3 and page 5 of the summary of stakeholder concerns retrieved by ATIA request. Available: <https://drive.google.com/drive/ folders/1C9Cx_uXgWE4rDbtketlhPRwaPAdpswTU>.

43 Post-Graduation Work Permit Program (PGWPP): COVID-19 program delivery. Government of Canada. Available: <https://www.canada.ca/en/ immigration-refugees-citizenship/corporate/publications-manuals/ operational-bulletins-manuals/service-delivery/coronavirus/temporary- residence/study-permit/pgwpp.html>.

44  Many of these students will have invested in a one-year online program abroad and remain PGWP eligible, due to concessions made during COVID- 19 by IRCC. Completing an academic program of one year duration entitles graduates toa one year post grad work permit. Most international graduates will require a one-year Canadian skilled work claim to have any chance of successful student to PR transition. The PGWP would be issued at the airport on arrival and would have exactly a one-year validity period.

45 Appeal to IRCC, Give Us Our Study Permits — We have waited for More than 22 weeks. Change.org. Available: <https://www.change.org/p/appeal-to- minister-for-immigration-refugees-and-citizenship-canada-ircc-give-us- our-study-permits-we-have-waited-for-160-days?utm_source=share_ petition&utm_medium=custom_url&recruited_by_id=725a4c80-ad54-11ea

-b06a-97d4345a6d79>.

46 Immigration, Refugees and Citizenship Canada. Minister Menicino announ- ces changes to facilitate online learning for international students (July 14, 2020). Government of Canada. <https://www.canada.ca/en/immigration

-refugees-citizenship/news/2020/07/minister-mendicino-announces- changes-to-facilitate-online-learning-for-international-students.html>.

47 Study Permit Approval Rates by Country 2020. Immigration, Refugees and Citizenship Canada. Available: <https://drive.google.com/file/d/195EPk_ ETo8o-z-vGbHB2ACUwhtxKKHtr/view>.

48 See in particular page 3 of the linked ATIA related (Global Affairs Canada) “Approval in Principle” chart. Available: <https://drive.google.com/file/d/ 1hRXoq7PxS2WaAc42YcgHil0W2HM5QxmL/view?usp=sharing>.

49 Nott, Will. Canada: Visa delays risking mental health of int’l students (February 1, 2021). The Pie News. Available: <https://thepienews.com/news

/canada-visa-delays-risking-mental-health-of-intl-students/>.

50 Seeking: Canadian Study Permit Applicants Refused through IRCC’s Two- Stage Process After a First Stage Approval/Commencement of Studies Overseas (August 9, 2021). Heron Law Offices. Available: <https:// heronlaw.ca/seeking-canadian-study-permit-applicants-refused-through

-irccs-two-stage-process-after-a-first-stage-approval-commencement- of-studies-overseas/>.

51  Immigration, Refugees and Citizenship Canada. Post-graduation work permit eligibility requirements. Government of Canada. Available: <https:// www.canada.ca/en/immigration-refugees-citizenship/corporate/ publications-manuals/operational-bulletins-manuals/temporary- residents/study-permits/post-graduation-work-permit-program/ eligibility.html>.

52  Immigration, Refugees and Citizenship Canada. Eligibility to apply for the

Canadian Experience Class (Express Entry. Government of Canada. Available: <https://www.canada.ca/en/immigration-refugees-citizenship/ services/immigrate-canada/express-entry/eligibility/canadian-experience

-class.html>.

53 The Post-Graduation Work Permit Program: Proposed Options for Program Redesign (June 2015). Citizenship and Immigration Canada. Available:

<https://drive.google.com/file/d/1yfVS9s_DwU6qo0TClRDMMgX0M3lqo kYf/view?usp=sharing>.

54 Immigration, Refugees and Citizenship Canada. Temporary foreign workers: Your rights are protected. Government of Canada. Available: <https:// www.canada.ca/en/employment-social-development/services/foreign- workers/protected-rights.html>.

55 Hune-Brown, Nicholas. The Shadowy Business of International Education (August 18, 2021). The Walrus. Available: <https://thewalrus.ca/the- shadowy-business-of-international-education/>.

56 Tertiary and International Learners Code of Practice (2021). New Zealand Qualification Authority. Available: <https://www.nzqa.govt.nz/providers- partners/tertiary-and-international-learners-code/>.

57 See email from Director of Post Secondary Accountability office in Ontario. Available: <https://drive.google.com/file/d/1A3TKSFGRTzklhKUq81- g0UO6vNh41MUL/view?usp=sharing>.

58 Submissions to the Australian Strategy for International Education 2021- 2030 Consultation (May 12, 2021). Council of International Students Australia. Available: <https://www.dese.gov.au/system/files/documents/submission-file/2021-05/Council%20for%20International%20Students%20Australia.pdf>.

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