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Human rights recommendations on income security reform, and “Income Security: a Roadmap for Change”

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March 13, 2018

Honourable Michael Coteau
Minister of Community and Social Services
Hepburn Block, 6th Floor
80 Grosvenor St.
Toronto, ON M7A 1E9

Dear Minister Coteau:

RE: Human rights recommendations on income security reform, and “Income Security: a Roadmap for Change”

I hope this letter finds you well. The Ontario Human Rights Commission (OHRC) commends your Ministry for the work it is doing to reform the income security system, as an integral part of the Government’s poverty reduction efforts. I am writing to express support for the Community Working Groups’ report, “Income Security: a Roadmap for Change,” and to make recommendations to ensure that the Ministry’s final Income Security Plan reflects both Ontario’s Human Rights Code (Code) and Canada’s international commitments to social and economic rights.

In the OHRC’s 2017-2022 strategic plan, we committed to using our mandate and powers to advance human rights by making clear how systemic discrimination causes and sustains poverty, and in particular, to “bring a human rights lens to government and community strategies aimed at addressing poverty, homelessness, and hunger.”

Our strategic plan reflects the fact that many people who identify with Code grounds are disproportionately under-housed, homeless or living in poverty in Ontario. Often, these grounds intersect to produce unique and compounded forms of discrimination for people living in poverty. The Ontario government has acknowledged the connection between poverty and identification with a Code-protected group in subsection 2.2(3) of the Poverty Reduction Act, SO 2009, c 10, which recognizes that “not all groups of people share the same level of risk of poverty,” and that “the poverty reduction strategy must recognize the heightened risk among groups such as immigrants, women, single mothers, people with disabilities, aboriginal peoples and racialized groups.”

If implemented, the Roadmap would have the potential to significantly improve the lives of people identified by Code grounds who are affected by poverty. It expertly explores the disproportionate poverty experienced by some groups, particularly people with disabilities, and Indigenous and racialized people. It includes important insights and recommendations addressing the complicated ways that discrimination and systemic barriers can create, compound and perpetuate poverty.

We are pleased that the Roadmap has a “human rights-based equity lens,” and is broadly consistent with principles set out in the Code, and/or with United Nations recommendations on poverty reduction strategies. In particular, the Roadmap:  

  • Foregrounds key principles, including equity and fairness, respect and dignity, access, reconciliation, adequacy, and social and economic inclusion
  • Identifies who is poor, and how poverty is appropriately measured, including:
    • certain key groups disproportionately affected by poverty, and
    • the need to measure poverty and set income targets not only by relative income markers, but also in relation to actual costs of living, to meet the principle of adequacy
  • Sets targets and benchmarks, and prioritizes immediately addressing the needs of people in deepest poverty
  • Proposes ways to ensure the participation of people living in poverty in government processes and programs that are meant to help them
  • Describes monitoring, accountability and reporting mechanisms.

The Roadmap recommendations also rightly address access to justice, adequate food and health, and privacy.

While the OHRC broadly supports the approach the Roadmap takes, we recommend that the final Income Security Plan address some key gaps relating to human rights protections and groups disproportionately affected by poverty.

1. Recognize poverty as a human rights issue, and specifically the right to an adequate standard of living

Since the Universal Declaration of Human Rights was adopted in 1948, the right to an adequate standard of living, including food, clothing and housing, has been recognized as a fundamental human right. When it ratified the International Covenant on Economic, Social and Cultural Rights (ICESCR) in 1976, Canada committed to recognize these rights and take appropriate steps to realize them, to the maximum of its available resources, including through legislation (Articles 2, 11).

The Roadmap repeatedly refers to economic and/or social “needs” and/or “inclusion” – these are indeed very important to address. However, the internationally recognized right to an adequate standard of living, along with anti-discrimination commitments, underpins the Province’s obligations relating to need and inclusion. To meet Canada’s commitments in Ontario, the Ministry’s final Plan should recognize economic and social rights, and the right to an adequate standard of living.


2. Refer explicitly to both Ontario’s Human Rights Code and the International Covenant on Economic, Social and Cultural Rights (ICESCR)

It is essential that the Ministry’s final Plan acknowledge the full human rights context of poverty and income security. This includes Ontario’s own human rights legislation, and ICESCR, the international document that sets out government obligations relating to economic and social rights and an adequate standard of living. The Roadmap’s Guiding Principles rightly cite international documents relating to the rights of Indigenous and racialized persons, people with disabilities, and children. However, the Ministry’s final Plan should also refer to the Code and ICESCR, as both are central to a rights-based approach to income security reform.


3. Address the needs and experiences of other Code groups disproportionately affected by poverty, specifically women, LGBT youth and trans Ontarians

The Roadmap is appropriately robust in its discussion of some groups identified by Code grounds that disproportionately experience poverty, such as Indigenous and racialized people, people with disabilities, children, and single adults. However, the final Plan would also benefit from a gender analysis, and discussion of the particular impact of poverty on women.

Similarly, while Canadian census data has not historically been gathered about lesbian, gay, bisexual and transgender people, it is important that this omission not be repeated in the Ministry’s final Plan. There is solid research indicating that LGBT youth experience high rates of homelessness, and that trans people, despite high levels of educational achievement, have a disproportionate rate of poverty. The acute poverty and discrimination these groups experience must be addressed in the Ministry’s final Plan if it is to be successful in meeting their needs. 

We look forward to seeing a final Income Security Plan that addresses our recommendations, and meets its potential to alleviate poverty in Ontario.  Consistent with our mandate to report on the state of human rights in the province, and in the interest of transparency and accountability, we may make this letter public.


Renu Mandhane, B.A., J.D., LL.M.
Chief Commissioner
Ontario Human Rights Commission

cc: Hon. Peter Milczyn, Minister Responsible for the Poverty Reduction Strategy and Minister of Housing

Hon. Yasir Naqvi, Attorney General

OHRC Commissioners