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Letter to Minister Lecce on the Peel District School Board Review

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June 5, 2020

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The Honourable Stephen Lecce
Minister of Education
438 University Ave, 5th Floor
Toronto, Ontario
M7A 1N3

Dear Minister Lecce:

RE: Peel District School Board Review

I hope this letter finds you well. I am writing on behalf of the Ontario Human Rights Commission (OHRC) to acknowledge the steps the Ministry of Education (Ministry) has taken on its review of the Peel District School Board (PDSB) in response to growing concerns about systemic discrimination, anti-Black racism, discord among senior leadership, and issues of governance. The OHRC is very troubled by the review’s findings, and the significant human rights issues raised in the way that the PDSB manages issues related to Black students. 

We are encouraged by your efforts to foster greater accountability for systemic discrimination through the 27 binding Directions your Ministry released on March 13, 2020. While the review and the Directions are important and necessary initial steps towards addressing and eliminating systemic racism in the PDSB, we are also hopeful that the Ministry will take further steps to ensure that school boards across the province improve conditions for Black students by learning from and possibly implementing appropriate elements from the Directions. 


PDSB review

The OHRC is very concerned that the PDSB has not addressed many of the systemic issues and statistical disparities related to Black students. Some of the troubling statistics cited in the review include:  

  • Black students represent 10.2% of the secondary school population, but approximately 22.5% of students receiving suspensions
  • Only 7.7% of Black secondary school students are enrolled in academic courses; however, 21.7% are enrolled in applied courses and 25.4% in the locally developed credit course stream
  • Between 2013 and 2019, the PDSB recorded 52 suspensions at the junior kindergarten level and 103 at the senior kindergarten level.

While the suspension data for elementary school students cited in the review was not disaggregated, the OHRC notes that there have been long-standing concerns that Black students are over-represented in suspension and expulsion statistics for students of all ages.  

The review also made important findings about Black students facing systemic issues that are consistent with concerns the OHRC has heard from the community. These issues include streaming Black students into non-academic courses, subjecting them to more stringent behavioural standards than their non-racialized counterparts, failing to confront and respond to instances of racism, and the absence of meaningful engagement between the PDSB and the Black community.

The findings from the review are extremely disheartening and call for decisive action. We echo the review’s call to eliminate disparities in student achievement and suspension rates, and to hire more Black guidance counsellors who understand the experiences of Black students.

The OHRC also stresses a pressing need for robust accountability measures to track the PDSB’s progress towards eliminating systemic disparities. We concur with the review’s findings that the PDSB must become a champion in collecting data on staff and student identities to address inequities in education and employment. The OHRC has been a long-standing advocate for collecting disaggregated data, and we encourage public sector organizations to collect this data in a way that is consistent with Ontario’s Data Standards for the Identification and Monitoring of Systemic Racism. 

Furthermore, the review’s findings on the PDSB’s organizational structure, discord amongst trustees and governance issues must be corrected in a manner that adheres to the Ontario Human Rights Code. Failure to do so may result in irreparable harm to the learning experiences of all 155,000 students at the PDSB.


Ministerial Directions

The OHRC is encouraged that the Directions reflect the urgent need to eliminate race-based disparities and develop an effective policy framework. The PDSB sent a letter to the OHRC dated May 15, 2020, regarding Direction sixteen (16), which calls for the PDSB to consult with the OHRC about the development of an anti-racism policy. We look forward to engaging with the PDSB about this policy, which has the potential to improve conditions for Black students. For the OHRC to meaningfully engage in this consultative work, we must be fully informed about the PDSB’s compliance with the Directions. The PDSB’s compliance will inform the OHRC’s approach and will likely shape the nature of the advice we provide to the PDSB. Accordingly, we are requesting a copy of Arleen Huggins’ report on the PDSB’s compliance with the Minister's binding Directions, along with any other relevant documents. We also call on the Ministry to release the report publicly to provide all stakeholders with a meaningful opportunity to remain engaged as the Directions are implemented.  


Province-wide concerns

Community members expressed serious concern for the plight of Black students across the province. They note that Black students in Ontario’s urban centres and suburban communities face many of the same concerns about systemic racism and anti-Black racism that were cited in the review. The OHRC would appreciate the Ministry advising whether there are any plans to expand the implementation of the Directions beyond Peel region. 

Improving the well-being of Black students in the province must become a priority. Given the importance of this work and the OHRC’s expertise in addressing issues of this nature, we welcome the opportunity to work with the Ministry to ensure that future recommendations provide redress for the historic experiences of Black students who faced systemic discrimination in the education system.

In keeping with the OHRC’s commitment to public accountability and its duties in serving the people of Ontario, this letter will be made public.



Raj Dhir
Executive Director

cc:       Peter Joshua, Director of Education, Peel District School Board
           Hon. Doug Downey, Attorney General
           Violetta Igneski, OHRC Commissioner
           Randall Arsenault, OHRC Commissioner