At its April 2018 meeting, the Toronto Police Services Board (Board) approved the establishment of the Anti-Racism Advisory Panel (ARAP). ARAP’s work was initially intended to focus only on the establishment of a monitoring framework – that is, key benchmarks and performance indicators – for the Board to use in assessing the response to and implementation of each of the recommendations from the inquest into the death of Andrew Loku.

Following the release of the Ontario Human Rights Commission’s interim report, “A Collective Impact: Interim report on the inquiry into racial profiling and racial discrimination of Black persons by the Toronto Police Service”, the Board determined it was appropriate to expand ARAP’s mandate to include the development of a mandatory race-based data collection policy for the TPS.

To this end, the committee has met monthly since February 2019 and spent a significant amount of time having detailed discussions on all matters related to the collection of race-based data. Additionally, ARAP has received a number of presentations by subject matter experts (ie. Ontario Human Rights Commission, the Anti-Racism Directorate, etc), as well as undertaken independent research on international best practices on race-based data collection, analysis and reporting in order to inform this draft policy.

Given the significant policy and historical issues related to race-based data collection by police services, ARAP emphasized the importance of conducting consultations on the draft policy with interested stakeholders and experts. The Board and ARAP appreciate the time you are taking to be part of this consultative process. At the conclusion of the consultations, a draft policy will be submitted to the Toronto Police Services Board for formal consideration in the Fall of 2019.

Please review the Policy prior to filling out the survey

This survey contains a summary review of each section of the draft policy and is meant to facilitate your input, feedback and/or recommendations. For clarity on any section, please refer back to the draft policy.

SURVEY ON RACE-BASED DATA COLLECTION, ANALYSIS AND PUBLIC REPORTING DRAFT POLICY

Guiding Principles

This section outlines the guiding principles for the policy, including the Board’s commitment to:

  • Ensuring that TPS provides professional service delivery;
  • Ensuring that these services are delivered in a unbiased way and without discrimination;
  • Creating a policy that recognizes community concerns with respect to policing within racialized and Indigenous communities; and,
  • Creating a policy that is rooted in transparency and public accountability.

Purpose of Policy

This section outlines the purpose of the policy, focusing on the following:

  • Preserving the dignity of individuals and communities;
  • Enhancing measures of accountability;
  • Advancing the delivery of police services that are not discriminatory or contrary to law;
  • Identifying disparities in service through the analysis of data and public reporting;
  • Protecting and being respectful of sensitive information, so as to not stigmatize or stereotype any communities;
  • Building on the Province of Ontario’s Anti-Racism Data Standards; and,
  • Establishing a clear policy that directs the Chief of the TPS to:
    o Create a procedure for the mandatory collection, analysis and public reporting of race-based data, which incorporates the use of Service Members’ perception data, as well as self-identification data with respect to race; and,
    o In developing these procedure(s), use only the following racial categories (which are the same categories listed in Ontario’s Anti-Racism Data Standards), as follows:
    a. Black
    b. East/Southeast Asian
    c. Indigenous
    d. Latino
    e. Middle Eastern
    f. South Asian
    g. White
    h. Another race category
    i. Prefer not to answer (applicable only to self-identification data collection)

Analysis, Development of Action Plans and Reporting to the Board and the Public

This section outlines how the procedure, which the Chief of the TPS is required to create, should be developed. More specifically, the Chief’s procedure must be developed having taken into consideration:

  • The expert advice of a diverse Community Advisory Working Group; and,
  • A framework that is developed and implemented for TPS to analyze and publicly report on the race-based data that is collected.
    This framework must enable TPS, on a qualitative and quantitative basis, to:
  • Conduct its own intersectional analysis1 (including and incorporating race, age, gender identity, but also demographic, census, and deployment data) where possible;
  • Develop appropriate contextual benchmarks that can help in identifying bias, data trends, racial disproportionalities and/or disparities, and community safety outcomes2
  • Regularly consult with the Community Advisory Working Group to evaluate compliance with the Board’s policy and the Chief’s procedure, provide feedback and analysis on training needs, identify key performance indicators in monitoring interactions, and create action plans to address any issues that arise;
  • Report to the Board on all matters identified in the policy in a form appropriate for publication, as well as include de-identified data collected on TPS’s Public Safety Data Portal; and,
  • Enter into a partnership with an independent organization (academic/public/private), which will conduct analysis and reporting on de-identified race-based data collected in the context of demographics, census information, and deployment strategies, to identify trends.

1 On the Ontario Human Rights Commission’s website, intersectional analysis is defined as “intersectional oppression [that] arises out of the combination of various oppressions which, together, produce something unique and distinct from any one form of discrimination standing alone....” To read the full explanation, visit http://www.ohrc.on.ca/en/intersectional-approach-discrimination-addressing-multiple-grounds-human-rights-claims/introduction-intersectional-approach#fn6

2 An integral component of “The Transformational Taskforce: Action Plan” is the scorecard which tracks community safety outcomes such as a decrease in crimes against persons, calls for service, and traffic collisions. To read the full scorecard, visit http://torontopolice.on.ca/scorecard

Monitoring Compliance with Policy and Procedure

This section outlines that compliance with the policy and relevant procedure should be regularly monitored. It also establishes that there should be regular reporting to the Board on compliance with the policy.

Training and Ongoing Support and Development

This section of the policy outlines the training objectives of the policy. More specifically, TPS is directed to:

  • Develop a robust training course, in consultation with the community, utilizing adult education approaches, experiential learning, and realistic scenario-based training, consistent with all related provincial training;
  • Create additional, ongoing learning and development supports and opportunities for reinforced learning; and,
  • Ensure that this training is subject to regular external and independent evaluation.
    This training should include information about:
  • Bias awareness, discrimination, racism, the impact of historical events on police-community relations;
  • How to collect race-based data in a way that promotes transparency, accountability and positive police-community relations; and,
  • The general impact of this policy and procedure(s) on the communities served.

Communications

This section outlines the policy’s communications requirements, and establishes that there must be:

  • A comprehensive internal and external communications strategy which will be accessible and widely shared across social media platforms; and,
  • A plan to consult with members of communities in the development of these strategies.

Resources

This section briefly reflects on the need to have the appropriate resources in place so that the policy can be effectively implemented by the TPS.

Phased Implementation of Policy

This section outlines how the policy will be piloted in a phased in approach over a specific time period, and also that it only apply to instances of Use of Force during the first phase. At the conclusion of the first phase, the Board will assess how this policy can be implemented more broadly across the Service through additional phases and timelines. Lastly, this section includes the Board’s recommended timeline to review the policy and propose any changes.

General Feedback & Commentary

Thank you for taking the time to fill out this survey. Please include your contact information below if you would like updates as this policy develops.

1 On the Ontario Human Rights Commission’s website, intersectional analysis is defined as “intersectional oppression [that] arises out of the combination of various oppressions which, together, produce something unique and distinct from any one form of discrimination standing alone....” To read the full explanation, visit http://www.ohrc.on.ca/en/intersectional-approach-discrimination-addressing-multiple-grounds-human-rights-claims/introduction-intersectional-approach#fn6

2 An integral component of “The Transformational Taskforce: Action Plan” is the scorecard which tracks community safety outcomes such as a decrease in crimes against persons, calls for service, and traffic collisions. To read the full scorecard, visit http://torontopolice.on.ca/scorecard