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OHRC letter regarding second Poverty Reduction Strategy consultation

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October 11, 2013

Hon. Teresa Piruzza
Minister of Children and Youth Services
Co-Chair of the Cabinet Committee on Poverty Reduction

Hon. Ted McMeekin
Minister of Community and Social Services
Co-Chair, Cabinet Committee on Poverty Reduction

C/O Breaking the Cycle
56 Wellesley St W, 14th Floor
Toronto, Ontario M5S 2S3

Dear Ministers,

In accordance with the Ontario Human Rights Commission’s (the OHRC’s) mandate under section 29 of the Ontario Human Rights Code, I am writing in response to the government’s public consultation on Ontario’s next Poverty Reduction Strategy.

Specifically, question two of your on-line survey states that Ontario’s first Poverty Reduction Strategy focused on children and their families. Identifying a number of groups[1] the question then asks which are most vulnerable to poverty and where should the government focus its resources.

The Poverty Reduction Act, 2009 acknowledges the link between poverty and human rights. Section 2(2) of the Act states, “That not all groups of people share the same level of risk of poverty. 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.”[2]

Section 2(3) of the Act requires that “every new or modified poverty reduction strategy is to include… Indicators to measure the success of the strategy that are linked to the determinants of poverty, including but not limited to income, education, health, housing and standard of living”.

The government’s annual reports on the Poverty Reduction Strategy identify eight indicators and results for measuring the impact of the strategy: school readiness, high school graduation rates, educational progress, birth weights, low income measure (LIM), depth of poverty, standard of living and an Ontario housing measure. Some of this data is broken down by gender.

Given sections 2(2) and 2(3) of the Act, the OHRC recommends as part of the next Poverty Reduction Strategy that, where possible, the government breakdown the eight indictors to show the impact of the Strategy on immigrants, women, single mothers, people with disabilities, Aboriginal peoples and racialized groups who disproportionally experience poverty.[3]

The OHRC’s guide, Count me in! Collecting human rights-based data (2009), recognizes the important role such data can play to help public and private sector organizations create effective human rights-based strategies.

The OHRC has raised other concerns in a number of its submissions, reports and other interventions over the years about the link between poverty, housing, nutrition, education, work and inequality experienced by groups identified under Ontario’s Human Rights Code including Aboriginal people, people with disabilities including mental health illness and addiction, newcomers, single mothers, women who experience domestic violence, older people especially women, and others:[4]

These documents are available on the OHRC’s website at

I would like to acknowledge the important work being done under the Poverty Reduction Strategy as outlined in the government’s annual reports to date. I look forward to reviewing the government’s next Poverty Reduction Strategy. In the meantime, feel free to contact me if you have any questions or comments.

Yours truly,



Barbara Hall, B.A., LL.B, Ph.D (hon.)
Chief Commissioner

[1] Children, youth, single parents, seniors, newcomers to Canada, women, people with disabilities, families, First Nations, Métis, Inuit peoples and racialized groups

[2] Canada also recognizes the link between adequate income, housing, food, education, work and equality in accordance with its obligations as a signatory to the International Covenant on Economic, Social and Cultural Rights.

[3] For example: The Canadian Human Rights Commission’s Equality Rights Data Report on Aboriginal People (2013) shows that the proportion of Aboriginal adults with low-income is much higher than that of non-Aboriginal adults. The CHRC’s Report on Equality Rights of People with Disabilities (2012) also shows that a proportion of adults with disabilities have low-income compared to adults without disabilities.

[4] The connection between membership in a group identified under the Code and the likelihood of having low income was recognized by the Board of Inquiry in Kearney v. Bramalea ((1998) 34 C.H.R.R. D/1; upheld (2001), 39 C.H.R.R. D/111 (Ont. Sup.Ct.)) when it ruled that rent-to-income criteria have a discriminatory effect. Measures that disadvantage those who are low-income are likely to disproportionately disadvantage members of Code-identified groups.