A submission by the Citizens Information Board to the Department of Justice and Equality (May 2014) Introduction



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Migration Integration Strategy
A Submission by the Citizens Information Board to the Department of Justice and Equality (May 2014)

Introduction
The review of migrant integration policy with the purpose of providing the basis for a new and updated overall integration strategy is welcomed by the Citizens Information Board (CIB). The Board also welcomes the establishment of the Cross Departmental Group on Integration which it is hoped will make a necessary contribution to the development and implementation of a whole of government policy geared towards the fuller integration of migrants into Irish society.

The CIB has over the years drawn attention to the need for better integration across government departments and other agencies (statutory and NGO) providing services and supports to migrants. Of particular importance in this regard is the integrated provision of accessible information on services, entitlements and rights. The CIB has been aware over the past decade of the need to make our own services accessible to migrants and has adapted the citizens’ information website www.citizensinformation.ie for this purpose. Citizens Information Services (CISs) are widely used by the migrant population and some 20% of clients nationally1 come from this population group. A number of CISs specifically target migrants through outreach services and a number have recruited migrants and people from diverse ethnic backgrounds as members of their service delivery teams. The CIB supports the Immigrant Council of Ireland to provide a specialist back-up service to CISs and the Citizens Information Phone Service in respect of immigration-related queries. Funding support is also provided by the Board to the Integration Centre and to the New Communities Partnership (the latter in respect of providing the Citizenship Application Support Service (CASS)2)

The CIB notes that overall responsibility for the promotion and coordination of integration measures for legally resident immigrants rests with the Office for the Promotion of Migrant Integration. The cross-departmental role of the Office “to develop, drive and co-ordinate integration policy across other Government Departments, agencies and services” is crucially important. However, given that the actual delivery of integration services is the responsibility of mainstream Government Departments, it will only be effective if the integration agenda is reflected and prioritised by all departments and agencies in the allocation of budgets.

Contextual Points
It is important to note at the outset that the migrant community has been playing an increasingly important role in Irish society. While some migrants are already well integrated into the community at both local and national levels, there are many who for various reasons remain outside of the mainstream. It is this latter group who need proactive integration strategies and programmes to enable them to feel included.

The CIB notes that much work has already been done over the years in respect of putting a Migrant Integration Strategy in place. There are some valuable initiatives already in existence which can be built upon. However, it may be the case that in more recent years, the focus on the integration of migrants in Ireland lost some of its impetus in the face of major economic concerns and the related lessening of focus on a social inclusion infrastructure for migrants.



What is required now is a new impetus and the clear formulation of an approach which will:

  • Build on good integration practice to date and identify and address deficits in our response to the needs of migrant communities


  • Cater for the multi-faceted needs of those who remain excluded, including in particular, people who are undocumented, people who have been unable to get Irish citizenship and asylum seekers


  • Be capable of responding to the current and likely future challenges which an increasingly diverse society present


  • Promote social inclusion and the full participation of migrants in the economic, social, political and cultural life of the country


  • Reflect the core components of active citizenship, in particular, feelings of belonging in the broad sense of national identity, and in the everyday sense of identifying with the local neighbourhood and the community as a whole.



  • Optimise access to the wealth of skills and experience of migrants some of which has hitherto remained untapped due to language, cultural and attitudinal barriers


  • Promote and facilitate education and public information campaigns to combat racism


  • Provide additional mechanisms for responding to the specific needs of ethnic minorities and asylum seekers

The Migrant Population
There is no one source that provides a complete picture of immigration and the number of non-Irish nationals living in Ireland on an up-to-date basis because migrants who are nationals of an EEA country do not have to register when they come to live in Ireland and there is no up-to-date register of immigrants entering and leaving the country. According to Census 2011, 12% of the total population were of non-Irish nationality (this compares to 10.1% in Census 2006). EU nationals represented 386,764 (71%) of the non-Irish national total.3 The fact that many migrants would have had no previous connection with Ireland and that they are here for the longer-term points to the importance of having a comprehensive Migrant Integration Strategy.

Migrant-related Issues
Central to any assessment of the success of integration policies in Ireland is the question of whether there exist barriers to migrants' full participation in society based on status, country of origin, race, ethnicity, educational achievement or cultural background. There are some deficits that have been identified which need to be taken on board in the Strategy.

Access to Education
The Roadmap to Integration 20134, compiled by the Integration Centre, pointed to positive policy changes in the education sector:

  • The abolishment of waiting lists in schools which put newcomer students at a disadvantage in urban areas

  • The requirement of schools to develop an anti-bullying policy which includes identity-based (racial) bullying

  • The possibility for non-EU students to change their fee status if they receive citizenship during their studies

On the negative side, the Roadmap pointed to schools giving preferential treatment to students on the basis of their religion. The Integration Centre has called for amendments to both the Equal Status Act 2000 and the Employment Equality Act 1998. Section 7.3 (c) of the Equal Status Act 2000 allows schools to refuse students entry if "refusal is essential to maintain the ethos of the school". Section 37 of the Employment Equality Act allows favourable treatment on grounds of religion to an employee or prospective employee.

Racism
A 2011 research report, prepared for the Immigrant Council of Ireland, documents experiences of racism in neighbourhoods, workplaces and on the streets of Dublin and concluded that much work needed to be done in this important area. In particular, the report highlighted the need to address:

  • The under-reporting of incidences of racism

  • The provision of clear guidelines covering the sentencing of racially motivated crimes

  • The speedier offer of alternative accommodation from their local authority to people living in an environment of racist harassment

  • The wider availability of support and clear advice at local level to victims of racist violence, harassment and anti-social behaviour

  • More inter-agency collaboration to support victims of racism and challenge racially motivated anti-social behaviour

  • The adoption by all schools of anti-racism policies that identify the steps that will be taken to address racist bullying when it occurs

  • Funding for information, advice, advocacy and outreach services that support victims of racist discrimination, violence, harassment anti-social behaviour.

The ICI noted that since the closure of the NCCRI and the end of the Know Racism campaign, there has been a policy leadership vacuum in institutional responses to racism at a national level. Hitherto, such bodies worked with organisations such as An Garda Síochána to facilitate the development of diversity strategies and other measures aimed at addressing racism.
Asylum seekers in ‘Direct Provision’
At the start of 2014, there were 4,360 people in direct provision. The system of direct provision has been justified on the basis that without such a system ‘pull’ factors would predominate. There have been numerous reports from NGOs, the Irish Human Rights Commission, the Ombudsman for Children, and the Special Rapporteur for Children, on the significant damage direct provision is causing its residents. It has been noted (Kinlen 2013) that, despite the recognition by many that asylum seeker children enjoy lower levels of entitlements than children in general, the issue has not yet become dominant in the mainstream public children’s policy agenda. The Minister for Justice has recognised “the length of time that residents spend in direct provision is an issue to be addressed . . .” 5(March 12th 2014)
Non-EEA Family Reunification

In December 2013, the Irish Naturalisation and Immigration Service (Department of Justice and Equality) published a Policy Document on Non-EEA Family Reunification

The document recognises that more comprehensive and transparent guidelines are necessary to assist applicants and decision makers in this area.  The policies outlined will apply to all decision making in the immigration system in relation to family reunification cases in a harmonised way, incorporating both visa applications and the various leave to remain processes. The document has been criticised by NASC (The Irish Immigrant Support Centre) on the basis that there is no obligation to reunite the family where a decision is made by family members to voluntarily separate and does not reflect a modern global society where immigration for work purposes is increasingly common.
Undocumented Migrants

The issue of regularisation for undocumented migrants in Ireland which affects thousands of non-EEA immigrants, has been highlighted over the years. The recently published Employment Permits (Amendment) Bill 2014 appears to address many of the problems identified by Citizens Information Services (CISs) and the Citizens Information Phone Service (CIPS) and by other NGOs over the years relating to migrant workers. Among other provisions, the Bill will allow undocumented workers who previously held a work permit and became undocumented through no fault of their own to get a work permit again and will allow undocumented workers to take legal action against exploitative employers for back payments and compensation.


Formulating the Strategy

Building on Work Already Undertaken
In formulating the Strategy, it will be important to build on the foundations that are already in place in both policy thinking and various initiatives at both local and national levels that have emerged during the past decade. For example, in 2007, the Oireachtas Joint Committee on European Affairs pointed to the need for a fundamental shift in attitudes, structures and services. “It is not just a matter of making public services more user-friendly for migrants but of the nature of the relationship between the migrants and Irish society in general and the nature of governance” (p.5). The 2008 Dublin City Integration Framework6 document notes that “access for immigrants to institutions, as well as to public and private goods and services, on a basis equal to national citizens and in a non-discriminatory way is a critical foundation for better integration” (p.37).It is likely that these points remain valid in 2014.

The 2005 - 2008 National Action Plan Against Racism (NAPAR) was designed to provide strategic direction to combat racism and develop a more inclusive and intercultural society in Ireland. Under the Plan, support was provided towards the development of a number of national and local strategies promoting greater integration in the workplace, in the police service, the health service, in our education system, in the arts and within local authorities. National strategies were developed, e.g., the Intercultural Education Strategy and the Inter-cultural Health Strategy developed by the HSE at national level and, also, by some regional HSEs.

Under the NAPAR, funding was provided to a number of Local Authorities towards the development of Anti-Racism and Diversity Plans with the aim of fostering a coordinated approach at local city/county level towards the planning, development and implementation of anti-racism and integration strategies. The importance of allowing adequate flexibility to suit local circumstances was stressed. A partnership approach was encouraged in that local authorities, key service providers, local development agencies, and community groups representing and working with minority ethnic groups and social partner bodies were to be involved in developing and implementing such plans.

The key principles identified in the 2008 Government Statement on Integration Strategy and Diversity Management (Migration Nation)7 as informing and underpinning integration policy remain both valid and important. These were:





  • A partnership approach between the Government and non-governmental organisations, as well as civil society bodies, to deepen and enhance the opportunities for integration



  • A strong link between integration policy and wider state social inclusion measures, strategies and initiatives



  • A mainstream approach to service delivery to migrants



  • A commitment to effective local delivery mechanisms that align services to migrants with those for indigenous communities.


Migration Nation identified four key areas that were then seen as critical to integration and emphasized a need to establish appropriate strategic directions as early as possible to ensure effective progress to successful outcomes for migrants:

  • English language training for legally resident adult immigrants

  • Interpretation and translation facilities

  • Funding arrangements for ethnic minorities and

  • Housing policy

While some progress has been made in these areas in the intervening period, particularly in relation to English language training and interpretation and translation facilities, key challenges remain in relation to housing policy and to ensuring that ethnic minorities are provided with supports in accordance with their specific needs.

Key Factors to be taken into account in the Strategy

Defining Integration
There is a need for clarity as to what is understood by integration and for a commonly shared vision accordingly. The CIB identifies the following as some of the core components of integration:

  • Facilitating diversity in all its manifestations – nationality, culture, race, religion and ethnicity

  • Integrated service provision (where this provides easier access for the user)8

  • Equality of access to social services and related information on rights and entitlements

  • Cultural integration

Role of Information
It is widely acknowledged that information plays a key role in promoting integration by enhancing people’s access to services and entitlements and their ability to assert their rights. Adequate and accessible information provision to immigrants also promotes equality and fairness in access to services. In response to the National Action Plan Against Racism (NAPAR), a number of local authorities, in consultation with Area Partnerships, HSE, CISs and other NGOS developed Anti-Racism and Diversity (ARD) Strategies which to a greater or lesser extent incorporated an information component. For example, Dublin City Integration Framework, referenced above, referred to the need to prioritise the provision of information in a range of languages and to develop strategies to address access to information for immigrant communities.

In general, access to information varies according to the information need, the starting point in the information search, the immigration status of the individual, and the responses of the intermediaries or service providers approached in the first instance. While quality information frequently exists, the ability of migrants to access information and supports can be limited because of language difficulties (including understanding written documentation)) or poor signposting or inadequate referral processes. Some migrants’ capacity to acquire information may be diminished by their personal circumstances and histories. For example, some people may be mistrustful of governmental institutions and may, therefore, be reluctant to approach service providers and “official” information providers. Also, some people will require additional support to access information and to use it to their advantage, which may not always be available.

Of particular importance in respect of integrated information provision are already established local initiatives (of which there are currently many throughout the country) – those developed by local authorities, by the HSE, by Area Partnerships, by CISs and by other NGOs as part of Intercultural and Anti-Racism Strategies. Any new approaches to meeting the information needs of immigrants should build on existing networks, including CISs, NGOs and various initiatives already put in place by statutory agencies.

Initiatives at Local Level
There were a number of development and social inclusion programmes operating at local level during the past decade which included migrants among their target groups - the Community Development Projects (CDP), the Family Resource Centres Programme (FRC), Area Partnerships, the Local Development and Social Inclusion Programme (LDSIP) and the Social Inclusion Measures Committees (SIM). It is of crucial importance that these initiatives are consolidated as part of any Migration Integration Strategy. The Local Government Reform Act 2014 provides a timely opportunity to allocate explicit responsibility for integration to the new Local Community Development Committees and, thereby, provide ongoing impetus to existing collaborative initiatives and facilitate the local-level, long-term approach to integration planning that is required.

Other Points to be Addressed in the Strategy


  1. There is scope for much greater co-operation between the various statutory agencies taking full cognisance of the need for simpler and fully transparent structures and processes;



  2. The long-promised revised Immigration, Residence and Protection Bill should be expedited in that it will be an important component of the Integration Strategy;



  3. The importance local communities play in promoting integration cannot be overestimated. Integration is most effective at the local level and therefore the Irish Government encourages the Local Strategies and Plans;



  4. Smaller local NGOs and migrant led organisations need ongoing support in dealing with the significant challenges in terms of capacity building, role, recognition and funding;



  5. Policies and structures should cater for the diverse needs of minority ethnic groups in Ireland, and which promote social inclusion, equality, diversity and the participation of immigrants in the economic, social, political and cultural life of their communities;



  6. Promoting integration and living with diversity is the responsibility of all citizens and not just that of the arms of the State;


Cross Departmental Committee on Integration

The committee is representative9 of the Departments and Offices with a significant role in integration and is being chaired by a senior official from the Department of Justice and Equality. The CIB believes that, given the central role of information and related advice and advocacy, in supporting integration and the significant involvement of its delivery partner services in this role, there would be merit in the Board having representation on the Committee.




1 Where country of origin was known, 20% of callers to CISs in 2013 were recorded as non Irish. Nationality was recorded for 65% of callers (over 416,000). 12% were EU nationals and 8% were from non-EU countries.

2 CASS works with a number of CISs dealing with citizenship queries and operates from nine locations nationwide.

3 The most frequently listed countries for non-Irish nationality were Poland (22.5%); UK (20.6%); Lithuania (6.7%); Latvia (3.8%); Nigeria (3.2%); Romania (3.2%); India (3.1%); Germany (2.1%); USA (2%).

4The Roadmap has been compiled for the past three years as a monitoring tool for policy and practice relevant to integration, inclusion and anti-discrimination.


5 There are more than 1,600 people who have spent five or more years in direct provision (Irish Times 3rd April 2014)

6 Dublin City Council (2008), Towards Integration A City Framework.

7 Office of the Minister for Integration (2008), Migration Nation, The Stationery Office.

8 This may involve geographical integration (where services provided by different bodies are available at one location); institutional integration (where two bodies are merged to form one entity delivering as seamless service); and service integration (where services previously supplied by two or more bodies become the sole responsibility of one).

9 In addition to the Department of Justice and Equality, the following are represented on the Group: Department of the Taoiseach; Department of Public Expenditure and Reform; Department of Education and Skills; Department of Environment, Community and Local Government; Department of Jobs, Enterprise and Innovation; Department of Health and The Health Service Executive; Department of Children and Youth Affairs; Department of Social Protection; Department of Arts, Heritage and Gaeltacht Affairs; Department of Transport, Tourism and Sport; Department of Defence; Central Statistics Office; Garda Síochána; County and City Managers Association.





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