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Submitted to the Minister of Public Safety pursuant to Subsection 33(2) of the Canadian Security Intelligence Service Act

Note: This is the text of the Inspector General of the Canadian Security Intelligence Service’s 2010 Certificate made public in May 2011 pursuant to a request under Canada’s Access to Information Act.
(The 2010 Certificate was classified TOP SECRET when submitted to the Minister of Public Safety in November 2010. The symbol [*] represents classified information removed from the document.)


Section 33 (2) of the Canadian Security Intelligence Service Act (CSIS Act) requires that I submit to you a Certificate stating the extent to which I am satisfied with the Director’s Annual Report. It also requires that I state whether, in my opinion, the Service has done anything in the course of its operational activities, in the time period covered by the Annual Report, which is not authorized by the Act, has contravened any Ministerial Directions, or has involved the unreasonable or unnecessary use of its powers. The mandate and functions of the Inspector General are described in an appendix to this Certificate.

This is my seventh Certificate that I am submitting since my appointment in 2003. It is, however, my first Certificate for you as Minister. While we have had the opportunity to discuss my responsibilities, I do believe that it is important to re-iterate that this Office was created, in large part, to provide independent assurance to the Minister to support Ministerial responsibility for CSIS. The office carries out internal, and at the same time, independent reviews of CSIS for you.

The internal dimension means that there is a direct reporting relationship to you, similar to that between you and other public office holders in your portfolio. Consequently, the Inspector General works in concert with, not in opposition to, the Director of CSIS.  This also means that you, as Minister, may direct the Inspector General to carry out any review or investigation of CSIS operations or activities on which you require independent advice.

The independent facet of the Inspector General’s function means that the Inspector General’s judgements or review results are not subject to direction or control by CSIS, your Deputy Minister, the Security Intelligence Review Committee (SIRC), or even, with all due respect, you as Minister. It also means that great care is taken to ensure that the Inspector General is, in no way, part of the decision-making process affecting such matters as targets, warrants, and section 16 requests for assistance. When the Inspector General or her staff reviews something, it is de novo, for the first time without any stake in how the matter was initially decided. The independence of the work is what lends to the office value and credibility for you, as Minister, in what is submitted and reported to you.

To provide you with this independent perspective and assurance about the work of CSIS, the office undertakes a variety of review activities, which I will report on in more detail in the following pages.

Building Awareness and Strengthen the Culture of Compliance

In keeping with my established approach, I have sought and obtained briefings on several matters from senior executives at CSIS Headquarters and the associated operational branches and have undertaken and completed visits to all regions of CSIS, in order to meet with regional management and select investigators. All of these visits this past year were held in the regional offices except one, which was held in the Calgary district office, and, in the context of a review of the Atlantic Region, I visited both the Halifax office and the St. John’s district office. Also, while visiting the British Columbia regional office in Burnaby, I was provided with a tour and briefing on the CSIS sub-office at Vancouver International Airport. At CSIS Headquarters, I also met with the Directors General and their management teams of three branches, including Asia/Europe/Americas, Human Sources and Operational Support and Security Screening.

These occasions provide an opportunity for open communication and enhance mutual understanding and trust in the working relationship. I am able to have in-depth discussions with front-line managers and staff, and receive briefings in my support role for your Ministerial responsibility. These visits give me a first hand view into the daily operational work of employees of the Service, their environment, and the challenges that they face. This component of my work also provides me with an avenue to pursue my efforts, on your behalf, to strengthen an organizational culture of compliance within the Service, which I view as an important dimension of my work and which is underscored by the CSIS Act.

Consistent with this objective, my office also provided briefings on the roles and responsibilities of the Inspector General to all Intelligence Officer Entry Training Courses.


As in previous years, I have maintained an active interest in staying abreast of international developments in part by maintaining contacts and consulting the larger intelligence review community. In March, I attended the biennial International Intelligence Review Agencies Conference in Sydney, Australia. I was invited to participate both as a chair of a plenary session concerning Sensitive Groups and as a panel member in a plenary session entitled Review Approach and Impact. The conference afforded me the opportunity to meet other Inspectors General and a wide range of senior office-holders and Parliamentarians in the intelligence review community from the five eyes community, the United States, the United Kingdom, Australia and New Zealand, and other countries including Belgium, Norway, Poland, South Africa, Sweden and The Netherlands.

In addition, while conducting a review of the CSIS [*] Station [*] I met with [*] with whom I discussed, generally, intelligence liaison and the threat environment in the region.

A member of my staff also participated in a capacity building exercise coordinated by the Service in a Latin American country.

My office participated in the annual Canadian Association of Security and Intelligence Studies 2010 Conference which was held recently in Ottawa. This provided a solid training opportunity for my staff to benefit from discussions and presentations of academics, experts and practitioners, both international and Canadian.

The Office

To assist me in carrying out my duties as Inspector General, I have a staff of eight.  I described, in my Certificate last year, the steps that I have taken to improve the operations of this office so I will not go into detail here, suffice to say my staff has remained stable with one very sad exception. This past April, [*], a review officer, passed away following a long illness. We lost a very vibrant and professional young lady in her untimely death.

The experience and energy possessed by my staff have a positive impact both on the quality and the quantity of the review work, but it should be underscored that the nature of review work is, in many ways, an exercise in risk management. It is not possible to review all operational activities of CSIS. The size of the samples reviewed is largely governed by the resources available and the extent to which the Service and the Service’s systems facilitate the work. The sample of activities reviewed must, however, be large enough by review standards to be conclusive and to fulfill the mandate and support your Ministerial accountability. I believe that I have achieved this objective.

I have endeavoured to build in efficiencies in our work, by minimizing unnecessary overlap with SIRC and, with the cooperation of the Service, develop means to access their information holdings while minimizing requirements for ad hoc requests to operational desks. The resource level of my office has not increased since 1996. As you are aware, CSIS has received substantial resource increases in recent years. It is always a challenge to try to keep pace with the increases in size and scope of the activities of the Service. That being said, I remain cognizant, however, of any workload pressures that our work may place on the Service and adjust whenever possible. In the upcoming year, I am developing our review plan to somewhat minimize bottle-necks for the Service while continuing to maintain the same level of review work essential to provide you with the necessary assurances.

Relationship with the Service

I place the utmost importance on maintaining a healthy working relationship with CSIS, at all levels of contact, while at the same time making clear, and respecting, our separate and distinct roles in the national security system.  Review work requires a delicate balance.  On the one hand, if the reviewer is, or appears to be, too close to the reviewed organization, this can diminish the value and relevance of the work. On the other hand, if the relationship is adversarial, this could compromise the functioning of the office and the ability to support your Ministerial accountability. The reality is that both CSIS and my office share the mutual objective of working to continuously improve the effectiveness of CSIS operations while enhancing democratic accountability.


Minister, let me begin by stating the following:

In respect of all the reports and information that I, and my Office, have obtained and reviewed and of all the discussions held, and subject to the concerns raised below, I am as satisfied as I can be with the Director’s Annual Report to you on the Service’s operational activities for the period 2009-2010. In that respect, it is my opinion that the Service has not acted beyond the framework of its statutory authority, has not contravened any Ministerial Directions, and has not exercised its powers unreasonably or unnecessarily.

Director’s Annual Report 2009-2010

In order to ensure that every statement in the Director’s section 33 (1) Report is fully supported and documented, my office reviews all the pertinent information and intelligence collected and retained by the Service. At a minimum, this involves the “facting” intelligence reports on which each statement in the report is based. This baseline is supplemented by exchanges of questions and answers in writing, by discussions, briefings and interviews. This year, for the first time, the Director appended the Integrated Threat Assessment Centre’s (ITAC) Annual Report 2009-2010. This is a report to the National Security Advisor of the Prime Minister designed to inform her on how ITAC is fulfilling its role as set out in Canada’s National Security Policy of 2004. As this report was included as part of the Director’s Report to you, my office “facted” only those components of the ITAC report which were of an operational nature.

With respect to the Director’s Report, I have determined that the letter complies with section 33 (1) of the CSIS Act and with Ministerial Direction reporting requirements as set out in the 2008 Ministerial Direction on Operations. While I have determined that the report does meet these requirements and in fact is a solid document describing the Service’s activities in relation to the intelligence priorities for 2009-2010, my staff identified minor inaccuracies and a translation error which were conveyed in a letter to the Director dated November 8, 2010. With regard to the ITAC Report which was appended to the Director’s Report, there were two instances of inaccurate numbers. Again, this information has been conveyed to the Director.

Compliance Statement 2009-2010

On September 15, 2010, the Director wrote to me with a Compliance Statement for 2009-2010 in which he advised me that, with respect to the CSIS Act and Ministerial Direction, no cases of non-compliance were identified. He did identify 15 cases, though, where employees were found to be in non-compliance with operational policy.

Without going into details on each, four cases dealt with action being taken without appropriate approvals in place and eleven dealt with delays in submitting reports [*].  I am satisfied that the Service has taken appropriate action in each instance. If you would like additional details, I would be pleased to provide them.

Review of CSIS Operational Activities

My Certification process is based not only on the Director’s Report dated August 19, 2010, but also on reviews of CSIS operational activities and monitoring of compliance with CSIS operational policy conducted during the annual reporting period. This year, the following reviews were completed:

2. Acquisition and Execution of Warrants
3. Human Source Operations
4. CSIS Atlantic Region
5. Foreign Station – [*]
6. Foreign Station – [*]
7. Section 16 Collection
8. CSIS Investigations [*]
9. CSIS Operations [*]
10. [*]

During the past year, I also received comprehensive briefings from CSIS personnel on:

1. Developments in the Service’s collection and retention of information
2. The Service’s support to Canadian hostage recovery activities
3. CSIS operations with respect to fundamental institutions
4. [*].

All these activities contribute to my ability to offer you, with some degree of confidence, the assurances that you require to support your accountability for CSIS.

Approach to Review Work

The Inspector General’s Remit

As Inspector General, I am responsible pursuant to the CSIS Act for reviewing the operational activities of the Service and for identifying areas where operational activity has not been in compliance with the CSIS Act, Ministerial Direction and the operational policies of the Service.

As noted above, each year the office completes a number of reviews of Service operational activities. In the past, these reviews overlapped the Director’s reporting period by three months. This approach was designed to ensure that the review activities of the office did not interfere with ongoing Service operations. During the 2009-2010 review period, I amended the period of review for projects to include a six-month overlap with the reporting period to better capture operational activity in our review work which would also be covered by the Director’s Report and therefore better inform you as Minister.  I think the Service would agree that this change did not impact on ongoing operations. The results of our reviews are shared with CSIS and action is taken by the Service to respond to compliance issues, which normally relate to operational policies, and to correct errors with the objective of ensuring the accuracy of CSIS information and strengthening policy and processes.

The Director noted in his Compliance Statement for 2009-2010, which I have referenced above, that the consequences of non-compliance with operational policy are generally less severe than those relating to the CSIS Act or Ministerial Direction. In general terms, one could agree with this assessment but non-compliance with operational policy can be nonetheless serious and have significant repercussions for the Service, the Government and Canadians. Operational policies are designed to implement the legislation and Ministerial Direction and, in essence, provide clear operational guidance to Service personnel whether it describes how to write an operational note, assess risk of an operation or identify approval levels for foreign investigative activity. Historically, it is errors, non-compliance with operational policy or inadequate operational policies that have caused the Service the most difficulty and has had a resultant negative impact both in terms of reputation and credibility.

Policy Environment

As you are aware, during the reporting period two Ministerial Directions were issued, both by your predecessor: Ministerial Direction on Information Sharing with Foreign Agencies and Ministerial Direction on Intelligence Priorities for 2009-2010. [*]

During the previous reporting period, a new Ministerial Direction on Operations was issued. In my 2009 Certificate, I noted two significant changes from the previous Ministerial Direction on Operations which I determined required close monitoring by this office, on your behalf, both in terms of CSIS operational policy development and actual operations. These included:

1. the principle of linking the level of risk of an operation to an appropriate level of decision maker; and
2. the replacement of a number of explicit requirements for consultation with and notification to you, as Minister, with a requirement, based on a risk assessment, to notify you when the Director determines that there is a potential for an activity to have an adverse impact on Canadian interests.

I noted that the shift to a risk-based decision-making framework could be beneficial in terms of efficiencies and effectiveness, but will have implications at all levels in the Service, as policies are amended to reflect this principle. It will place greater responsibilities on middle managers who will require training and expertise to ensure that these increased responsibilities are exercised appropriately. I want to highlight that a focus on these issues has been a component of the reviews undertaken during this review period.

Review Findings

Cross-cutting Issues

The reviews conducted by the office this year have identified again what I consider to be a large number of instances of non-compliance with CSIS operational policy and similarly, a large number of errors identified in CSIS information holdings.  While my office only reviews a sample of CSIS operations, these instances of non-compliance and errors are not isolated to one program or one set of processes. They appear in the range of core activities of the Service and across regions.

A second area of concern, and one which I have raised in my past six Certificates, is the length of time taken to develop or amend operational policies to reflect changing requirements and enhanced operational activities of the Service. This issue is evident in a number of areas. As I have expressed in my previous Certificates, I view a sound, up-to-date operational policy framework as essential to the functioning of the Service, particularly given the more strategic focus of the revised Ministerial Directions; the general shift to delegate decision making downwards in the organization; and the increasing complexity and evolution of operational activities both domestically and foreign in response to the threat environment.

As I pointed out in my 2009 Certificate, Deputy Director Operations (DDO) Directives were being developed quickly to fill some policy gaps and this process appears to have continued into the 2009-2010 year. I do believe that the Service recognizes this as an issue requiring attention. I am hopeful that positive developments will occur in key policy areas during 2010-2011.

[*] These are some of the most sensitive of CSIS activities and, as such, are designed to be guided by rigorous operational policy and central management. [*]

Compliance Issues

The review [*] by my office identified less instances of non-compliance with operational policy than were identified last year. It is noted though that compliance issues [*] also accounted for the majority of the instances of non-compliance in the Director’s Compliance Statement for 2009-2010 which I have referenced above.

A policy issue has existed for a number of years [*]. [*] Systemic non-compliance with respect to application [*]. [*]

A case in point relates to [*]. [*] The value of the policy is clearly evident. Every effort to fulfill this requirement should be made. Where it is not possible when faced with the insurmountable administrative and logistic difficulties of implementation, it would seem, at a minimum, that [*] and a record of the decision placed on file.

I have identified the problem [*] as a concern for several years in previous Certificates. [*]


In my 2009 Certificate, I reported on the increasing rate of errors in reporting [*] both operational and administrative. The potential negative consequences that errors of this type could have on Service investigations, and on individuals affected by the use of Service information, cannot be overstated.  Accuracy in assessments [*] is essential if the Service is to make use of the information it collects in a fair and balanced manner. Once errors regarding [*] are introduced into operational reporting or dates of interviews are wrong, they have the potential to result in decisions that are based on inaccurate information. There is also the concern as to whether this inaccurate information has been shared or formed the basis for operational decisions. When errors of this nature do come to light, they have a highly detrimental effect on the Service’s credibility both with Canadians, the judicial system and with other intelligence agencies. Unfortunately the rate of errors continues to grow.

An example of recurring errors this year was identified [*] and echoes my 2009 Certificate. [*] The Service did correct these errors when they were identified but I consider this to be a large number of errors for a fairly small sample.



The Service recognizes that the warrant acquisition process is a key tool to support their functions. With regard to acquisition of warrants, I reported last year that the review work by the office did not identify any instances of non-compliance with operational policy, but unfortunately the rate of errors continued to be troubling. The Service executive viewed this issue as serious given the implications of errors creeping into affidavits.

In the fall of 2008, the Service added a quality-control measure to the warrant application process to ensure that the “facting” material supporting the statements in affidavits was accurately reported. This step in the process, coordinated and conducted by the DDO Secretariat was conducted on six of the seven warrant applications reviewed. Given that my staff did not identify any issues or errors in the affidavits under this review, this new quality-control measure appears to be functioning as intended.

Execution of Warrant Powers

My staff examined the execution of a sample of warrant powers against [*] named on the warrants. Several instances of non-compliance with operational policies related to [*].  [*]


Operational Reporting

Note Retention

On June 26, 2008, the Supreme Court of Canada (SCC) found that the Service’s destruction of operational notes was a breach of its duty to retain information and intelligence, as stated in section 12 of the CSIS Act. Based on the Service’s interpretation of the SCC decision and the new potential risks to the Service, the Director decided that the Service would retain everything that contributed to a CSIS record.

In terms of implementing the decision, on July 8, 2008 the Service issued a DDO Directive containing interim guidelines for the retention of operational notes, electronic intercepts and other investigative material.  On March 27, 2009 Operational Policies and Procedures on Reporting were amended to reflect the new retention requirements. Between January and May 2009, Service personnel also received a training presentation called “Retention of documentation and operational notes”. This latter initiative was designed to provide context and background information in relation to the SCC decision and its implementation.

Normally, when the Service implements a new program or policy, I allow a period of time for the organization to work out any difficulties before I undertake any review activity. In this case, given the import attached to the judicial decision and the implications for Service operations, I felt that it was necessary to sample the implementation of the decision on a selective basis.

Based on the chronology of events outlined above, it was determined that cases where operational reports omitted reference to operational notes or investigative material would be considered non-compliant with the DDO Directive or Operational Policy based on their date of implementation. Using these criteria, my office identified a high level of non-compliance in samples taken for the Review of Targeting and for the regional review.  A significant number were also identified with respect to [*]. [*] The Service is correcting this deficiency.

With respect to errors, when conducting the Targeting Review, my staff identified a similarly high number of errors in terms of where in an operational report reference is to be made to original notes. The same issue was identified in the regional review. It was determined that the origin of these errors could be directly linked to a contradiction between the policy and the direction provided during the training presentation. The Service did undertake to correct these errors.

Developing a process and capacity to retain all operational notes, electronic intercepts and other investigative material is a major task. Equally complex is the task of developing a process which will facilitate retrieval. It is for this reason that I consider the type of error identified above as significant. One must know where to look to determine whether operational notes exist and where to find them for retrieval and future reference. This is an underlying premise of the SCC decision.

A case in point: In the context of a review, my staff requested the retrieval of the original hard copy operational notes that were referenced in reports for review. In a number of cases the Service was unable to locate hard copies of the operational notes. After further review, the Service ascertained that the operational reports were erroneous and that no operational notes had been taken to support the information reported in these reports. The fact that the Service’s initial reports in these cases had erroneously indicated that notes had been taken is indicative that more attention is required by the Service in reporting as to whether or not operational notes are retained in support of reported information.

I recognize that the Service is in the process of implementing a judicial decision which is arguably one of the most significant changes to the interpretation of the CSIS Act in the past few years. It will be important that it is done right and meets the requirements and intent of the SCC.  For this reason, note retention policy and its implementation will be a component of all reviews undertaken by this office next year.

Accuracy of Information

In my previous four Certificates, I have identified errors in the accuracy of information as a significant concern. I am aware that Service executive and senior managers have taken my concerns seriously and have taken steps to improve accuracy of reporting. Improvements can be seen in some areas but it continues to be a real issue in others.  I do wish to underscore the point again, though, that when errors are identified, the Service responds by making corrections.  The ongoing concern is how the incorrect information may have been used or shared.

Sharing of Information

Records Tracking Codes are used to track operational information exchanged between CSIS and external organizations, both domestic and foreign. Service personnel who disclose or receive information and intelligence are responsible for recording and tracking their exchanges in operational reports. In my previous Certificate, I noted that reviews by my office had identified a higher number of reports regarding exchanges of information which did not include tracking codes. I also noted that the Service modified the reporting system to better ensure that the Records Tracking Code field was mandatory. This change has had a very positive effect and a substantially lower number of reports missing the codes were seen in our reviews this year, however, some still exist. It is hoped that this matter can be resolved.

Authority for Collecting Information

In my previous Certificate, I noted that, [*]. [*]The reviews undertaken by my office this year identified far fewer instances than last year, but still significant in number. It is noted, though, that all but two of these occurred prior to the system correction implemented by the Service in July 2009. While the new system seems to be working reasonably well, there does remain a problem with reporting prior to the July date which could have implications for the future.

Operational Reporting – Clarity of Policy and Procedures

In the context of the [*] my staff posed a number of questions regarding the assessment and approval process for several operational reports in the samples selected for review and the Service’s interpretation of the related policy and procedures. These questions were posed given the importance that I attach to accuracy in operational reporting and possible misinterpretation by intelligence officers when writing reports.

The Service agreed that the wording of the policy may lead to interpretation issues with the message it is intended to convey in conjunction with the associated procedures.

A question was raised in the context of the [*] Review, in respect of the same policy regarding the matter of approvals of a number of operational reports which were written and approved by the same person. In this instance the Service was asked whether an author of a report could approve the report. This question was posed, as the policy framework for approvals of operational reports lacks clarity but implies that a second set of eyes would be beneficial. It is my assessment that, in most cases, some level of quality control and approval is beneficial and preferable, particularly in light of the potential implications of errors. The Service responded that their interpretation of the policy allows, in some cases such as when an intelligence officer is in a supervisory position, for the author of the report to approve it.

The Service has agreed that the wording of the policy would be amended to ensure that both policy and procedures reflect the same intent and requirement. In the interests of enhancing the process to ensure accuracy of reporting, I believe there would be value in reconsidering a policy that allows the same person who wrote the operational report to approve it.

My office was advised that the Service is awaiting the Government of Canada’s responses to the Air India and Iacobucci Commissions of Inquiry prior to revisiting the policy. It is unclear as to why the Service would need to wait for these responses to amend internal policy and procedures which have shown to raise interpretation issues. It is hoped, however, that whenever the policy modifications are undertaken, they will clarify review and assessment requirements for operational reporting.

CSIS Abroad

Policy Framework

I have noted for some time now that CSIS policy with respect to foreign operations [*] is inadequate. This continued to be the case during this review period. My office’s review and discussions [*] reinforced this assessment that operational policy fails to account for the operational reality [*]. During the review period, [*] consisted of a combination of domestic-oriented operational policies, DDO Directives, and supplemental direction [*].

I was advised, during the course of this review, that the Service was nearing completion of a new series of policies to provide specific direction on foreign operations and was pleased this past summer with the publication of a suite of policies designed to address the new reality of foreign operations. These new policies incorporate elements from the 2008 MD and DDO Directives issued between 2008 and 2010, update former Operational Policies [*].  From my perspective, I consider this to be a much needed and very positive step given the enhanced foreign operational stance, [*]. When the Service completes [*] Policy [*] those assigned to Foreign Stations will have a clearly-defined framework within which to operate.

CSIS Foreign Stations

In recognition of the increased foreign activity of the Service, for the first time this year I included in our annual plan the review of two foreign stations, [*]. Only the former included an onsite visit. These stations were chosen in part because they reflect a new and emerging operating stance abroad. [*] To the extent that the resource base permits, it is my intention to include two foreign posts in each annual review cycle in light of the increasing foreign posture.

Given the state of policy and written procedures during the review period, the Station personnel could not refer to one clear set of directions to guide their activities. This is in contrast to domestic regional personnel who can refer, for the most part, to a relatively mature set of domestic-oriented operational policies. [*] The advent of the new suite of policies on foreign operations [*] should mitigate this challenge to an extent. That being said, [*] policy gaps and compliance issues footnoted, were able to operate effectively in a challenging operational environment.


It appears, from the material reviewed by my staff, that discussions did occur between senior personnel in Ottawa, but that being said, upon completion of the reviews, the issue did not appear to have been resolved.

[*] If it is not yet resolved, I encourage the Service to continue to vigorously pursue with their colleagues a means to address this potentially serious void.

Collection of Foreign Intelligence

This year, my office completed a review of section 16 collection. I have undertaken to have such reviews completed biennially for you to ensure that I am in a position to brief you as required on the Service’s activities with respect to what has been termed, by many, as their secondary mandate. As you are aware, this is an area that, over the years, has garnered a great deal of interest politically and more broadly with Canadians.

The documentation examined for the review gave no indication that the Service contravened the geographic restriction on the collection of section 16 information. This observation must, however, be qualified with the acknowledgment that this area presents unique challenges for the Service and review bodies alike.

The CSIS Act is quite categorical in distinguishing between security intelligence and foreign intelligence, but the range of threats to be addressed by security agencies is not as easily delineated. In my 2004 and 2005 Certificates, I expressed concern over the potential risk that foreign intelligence collected abroad (whilst undertaking the collection of security intelligence abroad) could infringe the statutory requirement to collect foreign intelligence only within Canada.


The review of a sample of section 16 [*] demonstrated that my concerns in this area remain valid. [*]


As the Service increases the number of employees and operations abroad, it is reasonable to conclude that the opportunities for the collection of foreign intelligence overseas will only increase. Additionally, the increasing overlap and merging of information requirements under the section 12 security intelligence mandates, which can be carried out abroad, and the section 16 foreign intelligence mandates, which can only be carried out in Canada, may make it increasingly challenging for the Service to comply with the geographic restriction in the CSIS Act. For this reason, I think that the Service should consider implementing measures to address issues pertaining to the potential for collection of foreign intelligence outside Canada. [*]


New Circumstances

I noted, in my previous Certificate, that it would be important to monitor internal operational policies against the revised Ministerial Directions to ensure that activities are conducted, as required, and reflect the risk-based approach to operational activities as set out in the Ministerial Direction on Operations. Operational activities and the policies guiding them that I believe will require particularly close monitoring by the Inspector General, on your behalf, relate to changes in the Ministerial Directions which no longer explicitly require your involvement or notification.


It is important that the Service update existing policy and develop additional policy sooner rather than later which takes into consideration the circumstances unique to [*]. [*]



As you are aware, the Service now has policy for the provision of personal protection firearms to accredited Service personnel for activities in dangerous operational environments. As CSIS continues to expand its presence abroad, circumstances will arise wherein CSIS personnel are presented with operational opportunities that would involve travel to dangerous operational environments. CSIS personnel who are expected to pursue these opportunities should be offered reasonable means to mitigate personal and operational risk. In some cases, this may require the provision of personal protection firearms. Afghanistan is the obvious case in point.



As I complete my seventh year in office as Inspector General, I can assure you, Minister, with some degree of confidence, that I believe the Executive and staff of CSIS endeavour to exercise their duties and functions within the legislatively provided framework of authority in a professional and effective manner. As the 6th and longest serving Inspector General, I have had the somewhat unique opportunity and privilege to gain a detailed understanding and appreciation of what is a very complex organization carrying out specialized and, at times, extremely challenging work. This experience has shown me that, for my office to work effectively, there needs to be trust. Trust empowers the intelligence review and accountability functions and is largely developed over time from the demonstrable quality and balance of the review work. I am confident in the quality of the review work of my office and the usefulness of this work for the benefit and continuing improvement of CSIS. The responsiveness of the Service to the issues identified speaks to the effectiveness and concrete value of the review process.

Over my time as Inspector General, I have met many CSIS employees. I am always impressed by their level of commitment and dedication. Their work is done largely “in the shadows” and, by necessity, secret. From my experience, these are loyal, dedicated and innovative public servants. Their successes are largely unknown and unrecognized outside their own organization. These individuals serve Canada and Canadians well, often in difficult circumstances. They deserve our respect and appreciation.

As the Director indicated to you in his letter dated August 19, 2010, over the last year, CSIS has undertaken a major Business Modernization Project with resultant changes in the organizational structure. I am optimistic that the observations offered from the review work of my office will be a useful guide for the organization in this change process as it positions itself to be ready to respond to the increasing demands for intelligence to support the security of Canada and the safety of Canadians.

As a final comment, I would highlight that the nature of review work is not only to enhance accountability but also to develop public confidence in the accountability framework established by government. I am confident that the work of my office fulfills this role by providing you, as Minister responsible for CSIS, with independent advice and dedicated support.