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OHRC submission regarding Ontario’s next Poverty Reduction Strategy

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April 30, 2020

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Hon. Todd Smith
Minister of Children, Community and Social Services
7th Floor, 438 University Ave
Toronto, ON M5G 2K8

Dear Minister:

Re: Ontario’s next Poverty Reduction Strategy

I hope this letter finds you well, especially during this time of the COVID-19 pandemic. I am writing today on behalf of the Ontario Human Rights Commission (OHRC) about the government’s consultation on Ontario’s next Poverty Reduction Strategy (Strategy). The OHRC calls on Ontario to take a human rights-based approach to poverty reduction by entrenching the types of economic and social responses to COVID-19 into permanent solutions that will once and for all protect the well-being of everyone in our province.

As you know, one in seven Ontarians live in poverty. Certain groups identified by grounds in Ontario’s Human Rights Code disproportionately experience poverty together with poor health, lower education, precarious work and other social and economic inequalities. Particularly affected are women (especially single mothers and older women), Indigenous peoples, racialized communities including newcomers, persons with disabilities, adults living alone and other populations.

Social and economic crises, especially a health pandemic like COVID-19, exacerbate existing inequalities for vulnerable populations. Poorer response for these groups undermines the overall response and everyone’s well-being.

As Ontario’s Poverty Reduction Act recognizes, data monitoring is key to addressing poverty. Without good data to identify, plan for and respond to unequal impacts, we risk poorer health and other outcomes for vulnerable populations, and could possibly trigger the resurgence of a crisis and undermine Ontario’s overall social and economic condition.

Implementing permanent solutions to poverty, like a guaranteed universal basic income and monitoring comprehensive data for negative impacts, will help protect the health, housing and food security of all Ontarians, not just vulnerable groups, during and after any crisis.

The OHRC identified these and other important principles and actions in its recently released Policy statement on a human rights-based approach to managing the COVID-19 pandemic.

Adding recognition of everyone’s right to an adequate standard of living in the Poverty Reduction Act and taking a human rights-based approach are fundamental to the success of Ontario’s next Strategy. Doing so will also help Ontario meet its legal obligations under domestic and international human rights laws.

We are all connected. Ensuring we have the best strategies that meet the needs of the most vulnerable groups is also about fairness, not just human rights, and about helping protect everyone in the worst and best of times.

Poverty, discrimination and human rights law

Ontario’s Poverty Reduction Act and the Human Rights Code share a common vision: a province where every person has an equal opportunity to contribute to and take part in a prosperous and healthy community. Both laws also recognize that certain groups are more vulnerable to inequality.

This common legislative intent is important and is elevated by the Code’s referral to the United Nation’s Universal Declaration of Human Rights (UDHR). The UDHR recognizes that everyone has the right to an adequate standard of living. Canada, its provinces and territories have legal obligations to respect, protect and fulfill this right under the International Covenant on Economic, Social and Cultural Rights (ICESCR) and related human rights treaties. Under the ICESCR, the right to an adequate standard of living includes adequate food, clothing and housing. The ICESCR also recognizes the right to health, work, education and social security, rights that are interdependent with the right to an adequate standard of living.

People who experience poverty in Ontario are rights holders under our international and domestic human rights laws. They should be treated equally with dignity and respect, and without discrimination. Yet, according to a 2017 Environics opinion poll commissioned by the OHRC, only a minority of Ontario respondents surveyed (39%) felt positive towards people who receive social assistance, and a majority (62%) thought landlords should be concerned about renting to them.

Too many Ontarians experience poverty, especially groups vulnerable to discrimination contrary to the Code. Nearly two million people or 14% of Ontarians have low incomes, at or below half of the median household income, according to the 2016 Census. Rates are much higher for people with disabilities (23.5%), Indigenous peoples (23.7%), Black persons (24.1%), female-led families (29.8%), immigrants arriving between 2001 and 2016, 35.6%), and Arab persons (40.6%).

Poverty and systemic discrimination are interconnected and produce compounding effects in health care, employment, housing and other areas. Inequality and discrimination in these areas, in turn, undermine the security and social and economic condition of marginalized groups and the broader community.

Living in poverty limits people’s ability to redress discrimination, improve their circumstances and realize their rights to health, housing and employment. Vulnerable groups have poorer health, are forced into precarious low-wage employment, have disproportionate contact with the criminal justice system, and are at higher risk of homelessness, making them more vulnerable to further discrimination and inequality.

Recommendations for a human rights-based approach to Ontario’s next Poverty Reduction Strategy

In the OHRC’s 2017–22 Strategic Plan, we committed to using our mandate and powers to “bring a human rights lens to government and community strategies aimed at addressing poverty, homelessness, and hunger.”

The OHRC believes fundamental change will only happen when governments and society at all levels acknowledge that freedom from poverty is a human right and work together on permanent solutions to ensure this right.

In 2019, the federal government advanced human rights by recognizing a human rights-based approach in new legislation, including referring to the ICESCR in Canada’s Poverty Reduction Act and National Housing Strategy Act. This recognition was also in the bilateral agreement between Ontario and Canada on Canada’s National Housing Strategy.

Ontario’s Human Rights Code, the province’s highest law, states that, “it is desirable to revise and extend the protection of human rights in Ontario.” With this aim in mind, the OHRC makes the following recommendations for amending Ontario’s Poverty Reduction Act and taking a human rights-based approach to framing and implementing the next Poverty Reduction Strategy:

  1. Explicitly recognize in the Act and Strategy the right to an adequate standard of living, including adequate food, clothing and housing, as recognized in international law
  2. Refer to the International Covenant on Economic, Social and Cultural Rights, the UN Declaration on the Rights of Indigenous Peoples and other international human rights treaties that address freedom from poverty
  3. Clearly identify that poverty reduction contributes to meeting the obligation of all levels of government to progressively implement the right to an adequate standard of living in a timely way. More specifically, identify the obligation and ensure that local and regional governments have the capacity and accountability to realize the right to an adequate standard of living
  4. While the Act already recognizes the need to establish supports and eliminate barriers for persons who face discrimination based on the Code grounds of race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, sexual orientation, age, marital status, family status or disability, amend the Act to also include the Code ground of gender identity
  5. Recognizing the common vision shared between the Act and the Code, and as the OHRC has long called for in submissions and other statements, amend the Code to include the right to be free from discrimination on the ground of social condition in all enumerated social areas
  6. While the Act requires setting a poverty reduction target as well as indicators to measure the success of the Strategy linked to determinants of poverty, including health, education, health, housing, income and standard of living:
    1. Set a poverty reduction target that aligns with or exceeds the federal poverty reduction target (a 20% reduction in poverty by 2020 and a 50% reduction in poverty by 2030, relative to 2015 levels)
    2. Set a poverty reduction target to eliminate extreme poverty and homelessness within five years
    3. Expand and align Ontario’s poverty-related indictors with Statistics Canada’s dimensions of poverty, or similar comprehensive poverty indicators, including indictors and data for Ontario on Canada’s Official Poverty Line, deep economic poverty, unmet housing needs and chronic homelessness, unmet health needs, food insecurity, youth engagement, literacy, minimum wage and low-paid work, among other indicators
    4. Include indicators for
      1. Health status, including health conditions, access to services, including virus immunization, mortality rates, etc. (not just birth weights)
      2. Access to health food and food bank use
      3. Yearly cost of poverty to Ontario and its effect on the economy
    5. Provide poverty-related data for all ages (not just children)
    6. Disaggregate all poverty-related indicators (not just income measures) by vulnerable groups identified in the Act and grounds in the Code who are at heightened risk of poverty and discrimination, including LGBTSQ2 youth and transgender Ontarians
    7. As one of the aims of the Act is to break inter-generational poverty, and the 2016 Census shows Indigenous and racialized communities disproportionately experience intergenerational poverty in Ontario, include an indicator for intergenerational poverty disaggregated by Indigenous ancestry, racialized status and any other warranted Code ground
    8. Report on available data for all indicators in the annual reports the Act requires, including data showing the status of the specific poverty reduction target that the Act requires be set in the Strategy
  7. Recognize that poverty reduction includes good health and take this approach in strategies and plans
  8. Consult and include people with lived experience during poverty reduction consultations and when implementing strategies and plans
  9. Improve social assistance and employment supports to help meet the target of eliminating extreme poverty and homelessness within five years
  10. Commit to permanent solutions to poverty, like a guaranteed universal basic income, that will also help protect the health, housing and food security of all Ontarians, not just vulnerable groups, during and after any crisis
  11. Amend the Act to provide for robust, independent monitoring of progress by a body with jurisdiction to conduct research, consult the public, provide advice and oversight, and report publicly to hold Ontario accountable
  12. Amend the Act to provide for an accessible, effective public process for hearing, adjudicating and remedying systemic issues related to poverty
  13. Commit to and begin the process of developing a separate Indigenous poverty reduction strategy, including an urban Indigenous poverty reduction strategy, in partnership with Indigenous leaders, service providers and community organizations.

Recognizing the right to an adequate standard of living and taking a human rights-based approach in Ontario’s next Strategy would help make this province a leading jurisdiction with a transformative vision for poverty reduction.

As always, the OHRC would welcome an opportunity to meet and discuss how best to take a human rights-based approach to reducing and eliminating poverty and related discrimination in Ontario.


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

Copy   Hon. Greg Rickford, Minister of Indigenous Affairs
           Hon. Christine Elliott, Minister of Health
           Hon. Doug Downey, Attorney General
           OHRC Commissioners