On behalf of Unifor’s 162,000 members across Ontario, we would like to extend our thanks to the Anti-Racism Directorate (ARD) on providing this opportunity to send our feedback and recommendations as the province looks to update Ontario’s Anti-Racism Strategic Plan. We would also like to thank the ARD leadership and staff for their ongoing work and commitment in reducing systemic racism across the province, despite political hurdles and roadblocks that have been faced in the last few years. As a labour union that has been actively advocating at both the political and grassroots level on the need for strong anti-racism policies and programs, we find it more critical than ever to engage in processes such as these to ensure we continue the collective struggle for social and racial justice.
Like you, we are concerned about the detrimental impacts of systemic racism on Indigenous, Black and people of colour and the ways in which it threatens our workplaces and communities. Further, we are also gravely concerned about the drastic increase in hate crimes and the rise of organized and militant right-wing nationalist and white supremacy groups in the province. We believe that pro-active government intervention is needed to ensure that we both break down barriers that prohibit racialized people’s full social, economic and political participation, while ensuring that people are safe from racially motivate hate speech and violence.
We hope that the following recommendations will assist the ARD in revising and strengthening Ontario’s Anti-Racism strategy and look forward in collaborating in the future in order to advance equity and racial justice across the province.
We have developed and grouped our recommendations based on the strategic plan’s existing five pillars:
- Policy, research and evaluation
- Sustainability and accountability
- Public education and awareness
- Community collaboration
- Population-specific anti-racism initiatives
If the ARD plans on revising or expanding the current pillars or themes, please feel free to re-group our recommendations accordingly.
Policy, Research and Evaluation
1. Broaden current race-based data collection initiatives to include the Ontario Ministry of Labour, Training and Skills Development
We are pleased at the progress that has been made in developing proper standards for race-based data collection, as well as the movement to begin data collection in a number of government ministries and sectors, such as education, child welfare and justice. Unifor recommends that these initiatives be expanded to include employment and skills training at the Ministry of Labour, Training and Skills Development level.
As a labour union, we know how Indigenous, Black and workers of colour face a number of systemic barriers in employment, including workplace racism and discrimination. These results in workers of colour being disproportionately represented in low-wage precarious forms of work. To better understand and develop effect policies to eliminate these barriers, we require access to disaggregated race-based data to identify the labour market outcomes and challenges different racialized groups face. This would also include data collected around employment standards violations, incidents regarding workplace health and safety, and barriers in government funded employment and training programs.
2. Exploring the development and implementation of provincial Employment Equity legislation
Ontario Employment Equity legislation was introduced in 1993, but was quickly repealed by the Mike Harris government in 1995. Even though equity is protected under human rights legislation and anti-discrimination in outlined in the Ontario Labour Relations Act, the province still needs to re-introduce Employment Equity legislation to remove systemic barriers for equity deserving groups in areas such as hiring and promotions. While implementing Employment Equity legislation is outside the ARD’s mandate, we recommend that the ARD establish a multi-stakeholder committee comprised of government, labour, employers, community advocates and academics, to explore the development of a modernized Employment Equity Act and provide government with the necessary evidence-based research as to why it is necessary. Such legislation would cover not only the Ontario Public Service, but arms-length government agencies and departments, as well those organizations receiving on-going provincial funding.
3. Convene a special provincial working group to develop an equitable Just Transition framework
The impacts and ongoing threats of climate change have resulted in the need to envision, design and implement a Just Transition plan towards a low-carbon economy. However, such a plan would need to ensure that Black, Indigenous and workers of colour are not left behind. We propose striking a special working group charged with developing a framework and strategic plan to ensure that equity-deserving groups are provided with the necessary skills, training and resources to access current and future good green jobs.
4. Evaluate the provincial response to the COVID-19 pandemic through an anti-racism lens
The COVID-19 pandemic has taken a disproportionate toll on Indigenous, Black and communities of colour in terms of both rates of infections and deaths. We recommend a provincial task force be convened in order to investigate and evaluate the provincial government’s response to the pandemic and the ways in which it failed racialized communities. This would include critical pieces like the delay and early government refusal of collecting race-based data on number of COVID related infections and fatalities, and inequities in both vaccine and rapid test kit access and distribution. This evaluation process would conclude with a series of recommendations for the government to review in order to better prepare for future pandemics.
5. Develop a plan to implement the Ontario Human Rights Commission’s 10-step ‘Framework for change to address systemic racism in policing’
We continue to be concerned around the excessive levels force used by Ontario law enforcement against Indigenous, Black and people of colour -- particularly those experiencing mental health crisis. While the initial ARD’s anti-racism strategic plan has taken steps to address this issue, we feel additional measures are needed to better protect racialized communities, root out systemic racism in law enforcement and ensure greater police public accountability. As such, we recommend the ARD review and develop a plan for government to implement the Ontario Human Rights Commission’s 10-step framework for change to address systemic racism in policing. This comprehensive plan proposes concrete recommendations in many critical policing areas, such as racial profiling, responding to mental health and substance abuse incidents, ending racial profiling and greater independence on police complaint investigations.
6. Expand work to identify and address systemic barriers in provincial government programs and services
We commend the ARD’s work in developing an Anti-Racism Impact Assessment Framework to identify, remove and prevent systemic barriers in provincial government programs and policies. We recommend that this framework be used to conduct broader evaluation of systemic barriers and discrimination in accessing a range of cross-ministerial programs and services. This includes, for example, identifying barriers in accessing Ontario Student Assistance Program (OSAP) funds, employment and training services through Employment Ontario, Ontario Works and Ontario Disability Support Program benefits, community legal aid services, workers’ compensation through WSIB, health care and community health clinics, to name a few.
Sustainability and Accountability
1. Incorporating a gender and equity-based analysis to provincial budgets
The current practice of the federal government, in preparation of their yearly budget, is to incorporate a gender-based analysis (GBA+) to analyze and assess how budget decisions and the allocation of government resources impacts women and other diverse populations to ensure that specific needs are being met. We recommend that the provincial government replicate this practice and incorporate a gender and equity-based analysis into their budget development to evaluate how budget decisions and priorities have a direct impact on Indigenous and racialized people in communities on the ground.
2. Improve inter-governmental coordination around provincial Indigenous programs and services
In their 2020 report, Ontario’s Auditor-General raised critical issues around the lack of inter-governmental coordination, transparency and communication regarding provincial Indigenous programs and services. This, combined with an overall lack of accountability and oversight mechanisms, is resulting in program and service delivery failures and ineffective interventions in reducing disparities in Indigenous communities across the province. We feel the ARD can play a key coordinating and communications role in ensuring that all government ministries and departments are aware of existing programs and services for Indigenous people in Ontario to avoid duplication and ensure that these programs are better accessed by communities in need.
3. Develop appropriate protocols and terms of reference when engaging and consulting with Indigenous communities in crisis
By law, the province must consult with Indigenous communities when it engages in policy decisions that would have a direct impact on Indigenous treaty rights, such as the development of large infrastructure projects. However, it has been revealed that the provincial government has been inappropriately consulting with communities that are facing significant crisis – such as long-term boil water advisories and spikes in suicides in their communities. The Ontario Auditor-General also discovered that the provincial government was not collecting proper information confirming their duty to consult or that in some cases, there was no adequate consultations performed at all. We recommend the ARD play a role in ensuring that the government develop proper protocols and terms of reference when consulting with Indigenous communities in crisis and monitor to ensure that the government is appropriately fulfilling their obligations under the law and consulting with Indigenous communities in a meaningful way.
Public Education and Awareness
1. Ensure comprehensive anti-racism education and human rights training in Ontario’s school curriculum
We support advances made in ensuring Ontario’s public education curriculum incorporates components that cover important topics such as the legacy of colonialism and experience of Indigenous peoples in the residential school system. We believe that provincial curriculum must be broadened to ensure other forms of racism, such as anti-Black racism, Islamophobia, Sinophobia, etc., as well as white supremacy, are also taught to students across the province at a young age so that they are aware of how to respond to it. We further recommend that trusted organizations, academics and anti-racism advocates review this curriculum before being implemented. Additionally, human rights topics and training should be included so that students who are preparing to enter the labour market are aware of their rights under the law, particularly regarding harassment and discrimination in the workplace, and resources they can access in order to better assert and protect their rights.
2. Expand anti-racism and anti-oppression education and training for Members of Provincial Parliament and constituency office staff
While the ARD has worked to ensure that Ontario Public Service staff undergo and have access to anti-racism training, we are concerned about political leaders – including the Premier -- using their positions and platform to promote racist views, ideologies or harmful stereotypes. We strongly believe that MPPs, and their respective office constituency staff, undergo mandatory anti-racism/anti-oppression training before they are able to take their posts in the legislature, representing and serving the diverse people of Ontario.
3. Identify and compile names of Ontario municipalities and historical landmarks/heritage sites that are named on behalf of historical figures with ties to Indigenous genocide or anti-Black racism/slavery
As Canada continues to reckon with the legacies of colonialism, forced assimilation of Indigenous peoples, history of slavery and other forms of state sanctioned racism, we must acknowledge how many Ontario municipalities and heritage sites continue to glorify and commemorate the names of those associated with this history. These include, for example, the City of Vaughan, Kitchener, Russell Township and Dundas. While we acknowledge that changing the names of these areas is beyond the ARD’s scope, we believe there is still a strong public education opportunity and role that can be played so that there is increased awareness of the historic connections of the names tied to these towns and why they are problematic to continue to be used today.
1. Partner with Ontario labour unions in the development of employment, mentorship and skilled trades programs to boost employment for Black, Indigenous and workers of colour in various economic sectors
Larger national unions, like Unifor, represent members in nearly every sector of the economy. As such, we are well placed to facilitate employment, mentorship and training programs to increase employment opportunities for racialized workers and help them secure good union jobs. The ARD has highlighted a similar training program that is in place in the construction industry to increase opportunities in the industry for underrepresented groups, led by the union LiUNA.
We feel this can be replicated with other unions in a number of different industries, such as auto manufacturing, health care, telecommunications, transportation, media, etc. The province can help resource these programs that organized labour can then help implement on the ground, in partnership with other community organizations or educational institutions.
2. Establish a provincial Hate Crimes Task Force
We strongly recommend that the ARD help establish a provincial Hate Crimes Task Force. This Task Force, housed within the Ministry of the Attorney General, would coordinate with provincial law enforcement bodies, community groups, organizations, faith leaders, anti-racism advocates and other key stakeholders, to develop and implement a provincial Anti-Hate Crime Strategy. Part of this work would include reviewing and implementing previous recommendations developed through the Hate Crimes Community Working Group.
3. Enhance funding to support diversity in arts and culture
Racial diversity in arts and culture is critical in ensuring that different voices, perspectives and experiences have the opportunity to be told and disseminated to wider public audiences. However, Black, Indigenous and other communities of colour often find it difficult to secure resources to fund such projects. Further, many large cultural institutions have much work to do in order to address their own institutional racism, both in programing and leadership. We propose that the ARD provide funding grants to better support and promote racialized artists and ethno-specific cultural groups.
This can be done in close partnership with the Ontario Arts Council (OAC) that currently offers grants for artists of colour and Indigenous artists. However, demand is clearly outpacing the level of current amounts being provided. For instance, according to OAC statistics, in May of 2021, there were 102 applications for the Skills and Career Development: Indigenous Arts Professionals and Arts Professionals of Colour grants (totaling just over $945,000), yet only 47 grants were awarded totaling just under $400,000.
Population-Specific Anti-racism Initiatives
1. Expand the scope of the Directorate’s work to include documenting and addressing barriers faced by migrants with precarious immigration status
As Canada’s immigration system continues to increase the number of migrants entering the country without full permanent immigration status (e.g. temporary migrant workers and agricultural workers, international students, care workers, refugees, etc.), many of these workers face barriers in accessing provincial public programs and services. For those who are living without status, there is additionally, a constant fear of detention and deportation. Community advocates have previous called on the province to ensure that migrants have full access to provincial programs and services regardless of their immigration status. This would include services such as health care, education, social assistance, social housing, employment, language training, etc., while ensuring that local and provincial police forces are not reporting or doing the work of Canada’s Border and Service Agents to enforce detentions and deportations (i.e. making Ontario a “Sanctuary Province”). In light of this, we believe the ARD is well placed to incorporate the intersection of immigration into its work and assist in breaking down systemic barriers for temporary, precarious and non-status immigrants.
Unifor Ontario Regional Director