Seeking Solutions

The National Statistics Council, the senior, external advisory group appointed by the government of Canada to advise the Chief Statistician, is deeply concerned by the effect of the announced changes to the 2011 Census. We believe that the changes will harm the integrity and quality of the Canadian statistical system. At the same time, the Council recognizes that concerns about intrusiveness and confidentiality should be addressed.

It is urgent we find solutions that protect the quality of the information Canadians depend upon while responding to concerns over the way in which the Census is conducted.
What is at risk?

First, the proposed, voluntary National Household Survey will suffer from significant respondent self-selection bias. Even with substantial efforts to mitigate the inevitable decline in response rates, this will degrade the data upon which much of the Canadian statistical system is based.

The proposed changes will likely result in Statistics Canada’s not being able to publish robust, detailed information for neighbourhoods, towns or rural areas. Much of the analytic work done by municipalities, private firms, health agencies, highway and transportation planners, school boards and large numbers of other groups that depend upon small-area knowledge and data will no longer be possible.

Our second concern is the potential loss of vital benchmark information. The mandatory ‘long form’ means that Statistics Canada has an accurate benchmark for the demographics of populations who are difficult to reach or who are less likely to complete a voluntary survey. This, in turn, means that sampling and weighting strategies for subsequent, voluntary surveys can compensate for differential response rates and produce more reliable information.

The importance of having Census benchmarks available is readily apparent when one considers some of the populations that we know are more difficult to reach – young people making the school-to-work transition, urban Aboriginal populations, the affluent, and new immigrants.

Without solid benchmark information, subsequent surveys and analysis rest on an uncertain foundation. The Bank of Canada cautiously stated that, while they do not use long-form data directly, they feel they will have to evaluate “the impact that any proposed change would have on the reliability and the quality” of economic data they use. The Bank’s statement exemplifies the repercussions the changes may have over the broader Canadian statistical system.

The National Statistics Council also recognizes the concern that Canadians not be overburdened by governments compelling them to respond to onerous or intrusive demands for unnecessary information. On a number of occasions, the National Statistics Council has urged changes and worked with Statistics Canada to reduce such respondent burden. With respect to the Census, the Council has strongly supported changes to data collection methods that enhance privacy such as mail-in and on-line options.

In addition, the Council strongly supports Statistics Canada’s commitment to the complete confidentiality of respondent information and it recognizes the agency’s undisputed success in reaching this goal. The Council shares the Privacy Commissioner’s Office view that Census questions are ‘inherently privacy-invasive’ and that the questions must be kept to what is necessary for good government and that the information gathered must be protected with the appropriate safeguards.

This focus on minimizing intrusiveness and protecting privacy is important to retaining the confidence of Canadians. We are satisfied that Canadians trust Statistics Canada and its procedures and that Canadians provide answers they would be unwilling to provide to a private survey firm. The Council also believes that confidence must be sustained through ongoing actions.

In a matter of a very few weeks at most, it will be impossible to change the 2011 Census or the National Household Survey. Meanwhile, debate over the future course of the Census has become heated without moving towards a resolution that meets both concerns about privacy and intrusiveness, as well as the need to maintain the quality of Canada’s statistical system. What then do we recommend?

The National Statistics Council recommends:

1.That, as part of a formal consultation process beginning with the 2016 Census, Statistics Canada examine each Census question to ensure that it, at a minimum, meets one of the following tests for inclusion in the Census:
a.It is required by legislation or Cabinet direction,
b.It is needed for small-area data uses for which there is no alternative data source,
c.It is needed to create benchmarks for measuring difficult-to-reach groups and ensuring that subsequent surveys or data derived from administrative sources can be sampled or weighted to reflect accurately the overall population,
d.It is needed to assess progress on issues of national importance, for example the economic integration of new immigrants, or
e.It is to be used as a basis for post-censal survey sampling of relatively small or dispersed groups, for example, urban Aboriginals or people with health conditions that limit their activity.
Even if a question met this requirement, it would still face tests of its overall importance to the Canadian statistical system and the needs of data users as weighed against cost and the intrusiveness of the question.

2.The Council is aware that other countries have conducted successful censuses without people having to face the potential of jail as a punishment for not filling out census forms. We, therefore, recommend that the Statistics Act be amended to remove jail sentences as a possible punishment for not filling out the Census. At the same time, the Council recommends that jail continue to be a punishment for those who wilfully break confidentiality provisions.

3.That the Census for 2011 include the long form being used for 20% of the population as the only way, given the very short timeframe, to safeguard the quality of the Canadian statistical system.

4.That the question series on household activities (question 33 in the 2006 long-form Census) be dropped as it was the question that occasioned the largest number of objections among the substantive questions and since it fails to meet any of the five tests outlined in point 1.

The National Statistics Council believes that these steps, taken together, can respect the valid concerns voiced by Canadians about privacy and intrusiveness, while ensuring that the vital information that currently flows from the long-form Census can be maintained and continues to serve Canadians’ needs.

Ian McKinnon,

Chair, The National Statistics Council

Twenty per cent of Canadians are required, by law, to fill out the long form – and their individual responses are kept strictly confidential under Statistics Canada’s extensive privacy protections. “The census long-form questionnaire is a unique tool that affords decision-makers a rich set of facts about Canadians, facts that are as reliable at the census tract or neighbourhood level as the nation-wide level,” says economist Armine Yalnizyan. “This is because of its huge sample size and the fact that response is mandatory…”

“The information that the census long-form generates is invaluable for decision-makers at every level of governance. We are unlikely to get a similarly high quality of information across geographies and sub-groups of the population from the proposed survey. Though current plans envisage circulating the new survey to one in three households, the response rate will be significantly lower because it will be a voluntary questionnaire. Response rates will be particularly depressed in areas where there are active campaigns urging non-compliance, as was the case during the 2006 Census,” says Yalnizyan. 

“Without robust Census data, it is difficult for local governments, health districts and other community service providers to respond effectively to shifting patterns of need or introduce changes – including cuts – that do the least harm or provide the greatest value for money. Indeed, it is the local level that is most hampered by this federal decision. The issue raised by cutting the Census long-form questionnaire is not just about having good information; it’s about having relevant tools for democracy,” she notes.

An on-line petition has been created to allow people to register their support for maintaining the long census form.

 ”The impact of the recent crisis on people’s consciousness has emphasised the importance of dealing with the social consequences of the [capitalist] system,” he said. “I think societies everywhere will come to the conclusion that an important part of the capitalist system is having a powerful social sector to address social issues, because government doesn’t have the resources. It is not enough to increase the standard of living at the high end. It is right at the same time to worry about those who are left behind.”

In Growing Unequal, the OECD has documented that sharp cuts in social spending combined with tax cuts led to an increase in income inequality and poverty in Canada over the past decade. Canada is behind the UK and the US in strengthening the financial capacity of the non-profit sector.

“The current strategy of sending to tenants a constant stream of letters, some of which use threatening language, needs to change,” warned Justice Patrick LeSage. “Tenants need to be put on notice of their arrears; however, threatening eviction at the first sign of arrears is not a productive step to engaging the tenant. Staff must make every effort to contact tenants in order to understand the root of the arrears problem and where possible rectify it at the earliest opportunity. This will not be accomplished solely by letter writing.”

Justice LeSage notes that TCHC faces considerable challenges. It doesn’t have the financial or other resources to provide intensive support to tenants, including frail and elderly people. It faces a complex and often cumbersome set of legislative and regulatory rules imposed by the provincial government through the Social Housing Reform Act.

However, Justice LeSage calls for a greater recognition of the need to engage tenants in a meaningful way in eviction processes. The important role of tenants in the overall management and administration of Toronto’s community housing has been a theme that goes back at least to the 1950s, when University of Toronto Housing expert Albert Rose called for an overhaul of the housing company’s management to support a strong role for tenants.

“It is not surprising, in view of the unfortunate association of public housing and ‘charity’ in the public mind, that scant attention is being paid at this time to the role of the tenant of public housing as a person, as a citizen, and as a responsible participant in the administration of the project,” wrote Dr Rose in a 1952 article. He added:

“No matter how benevolent the administrative staff may be, through personal inclination or as a matter of policy, the basic objective is not the creation of a benevolent autocracy or benevolent paternalism. The only real way of avoiding bureaucratic administration and benevolent paternalism lies in the devolution of certain aspects of administration to the tenants through the creation and encouragement of an independent Tenants’ Association. To the extent that the tenants of Canadian public housing develop a sense of responsibility and participation, to that extent will the basic objectives of public housing, namely the provision of adequate shelter and an opportunity for a fuller life in an adequate community setting, be realized.”

Mr. Gosling was 81 in May of 2009 when he was evicted from his TCHC home after 21 years as a tenant. As Justice LeSage noted: “His problems arose when he failed to complete the paperwork to qualify for subsidized rent and his rent increased. After eviction he remained homeless until he died of an infection five months later.”

After six months of homelessness, Mr. Gosling developed severe health problems and died. At the time of his death, in the face of public and media pressure (including a campaign by The Toronto Star’s Joe Fiorito), TCHC was negotiating to bring Mr. Gosling back into TCHC. The health impacts of insecure housing and homelessness have been widely documented, including research from Street Health that was funded by the Wellesley Institute.

TCHC is the largest social housing provider in Canada, and the second-largest in North America, and is home to about 164,000 low and moderate-income people in almost 59,000 homes throughout Toronto.

Justice LeSage writes:

“It became clear to me through these consultations that TCHC tenants need more assistance than is currently available at TCHC, to ‘maintain healthy, successful tenancies’, one of the goals in the current Community Management Plan. Tenants now have access to the Office of the Toronto Ombudsman to investigate matters on their behalf. I believe the creation of this Ombudsman’s office will help TCHC continue to achieve its goals. However, I feel tenants require additional assistance in this complicated subsidized housing system. My mandate extends only to reviewing the eviction process for vulnerable tenants, however, I believe the proposal I describe below could assist TCHC tenants in other ways and also contribute directly to the financial success of TCHC.”

“A new independent office should be created to ensure TCHC staff have satisfied all prerequisites prior to an eviction matter proceeding to the Landlord and Tenant Board. I propose this ‘office’ be independent, and be named the Commissioner of Housing Equity.
The TCHC Board of Directors should appoint the Commissioner. The original term should be for two or three years, and subject to renewal. The Commissioner ought to have an understanding of social housing and of the issues facing vulnerable tenants.”

“The Commissioner of Housing Equity should have some characteristics of an independent auditor, in ensuring that all policies and practices have been followed, and some characteristics of an ombudsman, in its role of mediating fair settlements. It would not, however, fulfill the role of advocate for the tenants. It will have as its focus the assurance that all eviction prevention policies are and have been engaged. The Commissioner will also invite tenants facing eviction for arrears to participate in mediation to be conducted by outside/independent mediators. I suggest that the Tenant Services Coordinator responsible for that tenancy be the TCHC representative at the mediation since they have the most knowledge of that tenant, their rental history and circumstances.”