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Anti-Black racism in the Ontario Public Service

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June 14, 2019

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Office of the Chief Commissioner 
180 Dundas Street West, Suite 900 
Toronto ON M7A 2R9
Tel.: (416) 314-4537
Fax: (416) 314-7752         


Steven Davidson
Secretary of Cabinet
Whitney Block Rm 6420
99 Wellesley St. W
Toronto, ON M7A 1L2


Dear Secretary Davidson:

Thank you for meeting with me on May 27, 2019 to discuss anti-Black racism in the Ontario Public Service (OPS). I am writing today to request further details on the government’s existing and planned initiatives to address systemic racism in the OPS.

As we discussed, a group of racialized employees has asked to meet with the Ontario Human Rights Commission (OHRC) to discuss their concerns about anti-Black racism in the OPS. This meeting has been scheduled for June 19, 2019.

The OHRC has provided the government with advice for over 10 years

As you know, Ontario’s Human Rights Code (Code) prohibits racial discrimination in employment, and mandates the OHRC to promote, assist and encourage the government to engage in programs to alleviate tensions and conflict based on identification by a prohibited ground of discrimination.

Over the past decade, the OHRC has provided expert advice to the government on its past four reviews of the Workplace Discrimination and Harassment Policy (WDHP), including most recently in 2017 – 2018. The OHRC has consistently noted that the WDHP process is not effective for addressing systemic discrimination. We have recommended various amendments to the Policy and process.

Over the past 18 months, OPS members have informed the OHRC about their experiences of individual and systemic anti-Black racism, and the failure of current systems and processes to adequately address and respond to these experiences. Racialized OPS members have requested that the OHRC intervene in matters before the Human Rights Tribunal of Ontario, and raise concerns on their behalf with the government. 

Since December 2017, the OHRC has met with the Secretary of Cabinet (SOC) — yourself and your predecessor, Steve Orsini — on at least four occasions to discuss the government’s efforts to address anti-Black racism.

We have also written to the SOC at least five times, most recently by email dated March 25, 2019. In a letter dated January 14, 2019, we discussed how the OHRC could, with appropriate dedicated resources, conduct the contemplated external, independent review of the WDHP. We did not receive a response to this letter.

Government initiatives to address anti-Black racism in the OPS

As the Ontario government has recognized in A better way forward: Ontario’s 3-year anti-racism strategic plan, it is critical that the OPS lead by example in creating a culture of human rights and inclusion in the workplace.

We recognize that the government has taken several steps dating back to the 2009 Diversity Plan to address systemic racism in the OPS. More recently, we note the release of the 2017 Anti-Racism Strategic Plan and Anti-Black Racism Strategy, the 2018 Anti-Racism Policy, and the Report and recommendations of the independent external review of complex WDHP cases by Arleen Huggins. Unfortunately, it is not clear how these initiatives are coordinated, the timelines for full implementation, how success is being measured, and the outcomes that have been achieved to date.

We also note the government’s January 2018 commitment to engage an external party to review the WDHP through an anti-racism lens to explore “new opportunities and approaches to try resolving issues before the commencement of a formal WDHP complaint.” To date, we understand that the government has not yet engaged an external reviewer.

OHRC request for more information

The OHRC has issued guidance to help organizations meet their human rights obligations. In Human rights and policing: Creating and sustaining organizational change, the OHRC identifies components of an effective human rights organizational change strategy. The following key components generally apply to any organization that wishes to proactively address human rights issues and concerns:

  • A comprehensive organizational change approach
  • A unified, committed and involved leadership
  • An articulated vision and shared terminology
  • Empowered and capable lead change agents
  • A multi-stakeholder structure and process for change
  • Ongoing monitoring and evaluation
  • Ongoing communication and reporting
  • Identifying and planning for resistance
  • Choosing strategic “areas of focus” for change.

At this point, the OHRC has concerns about the government’s approach to addressing anti-Black racism when assessed against these key components.

The OHRC questions the value of further anti-racism policies, statements, programs and policy reviews without effectively implementing past recommendations and clear plans to assess outcomes with reference to the lived experiences of employees adversely impacted by racism in the workplace.

To help the OHRC assess the government’s response to ongoing concerns about anti-Black racism in the OPS, please provide the relevant action plans and terms of reference, resource allocations, implementation timelines, key performance indicators, outcomes and anticipated public reporting for each of the following initiatives:

  1. 2017 Anti-Racism Strategic Plan
    1. Standard framework to collect disaggregated data
    2. Anti-racism impact assessment framework
    3. Minister’s anti-racism consultation group
    4. Annual anti-racism conference
    5. Population-specific anti-racism initiatives.
  2. 2017 Anti-Black Racism Strategy
    1. Leadership table with Ministers, bureaucracy and community members
    2. Anti-Black racism capacity and competency building program for government employees and institutions
    3. Implementing the Anti-Racism Directorate’s Race Data Standards and Anti-Racism Impact Assessment tool.
  3. 2018 OPS Anti-Racism Policy
    1. Multi-year enterprise-wide anti-racism program
    2. Systemic racism barrier identification and removal
    3. Anti-racism competency and capacity building
    4. Annual progress report.
  4. 2018 recommendations from the independent external review of complex WDHP cases (Huggins Report).
  5. 2019 external review of the WDHP program.

We would appreciate a response to the above requests in advance of the meeting on June 19, 2019.

Finally, during our discussion, you suggested that our teams should continue meeting with respect to this matter on a regular basis.  We welcome this opportunity and look forward to our next meeting.

Yours sincerely,


Renu Mandhane, B.A., J.D., LL.M. Chief Commissioner

cc. Paul Boniferro, Deputy Attorney General, Ministry of the Attorney General
Sam Erry, Deputy Minister, Ministry of the Solicitor General
Akwatu Khenti, Assistant Deputy Minister, Anti-Racism Directorate
Brian Fior, Chief Inclusion Officer and Head of People Strategy
OHRC Commissioners