Date of Publishing:

Message from the members

The National Security and Intelligence Review Agency (NSIRA, Review Agency) is pleased to present its 2024 Annual Report, highlighting key achievements, progress, and our direction for coming years.

2024 Key Highlights

In 2024, NSIRA observed a notable increase in the number of complaint investigations linked to immigration security screening delays.

Additionally, NSIRA has released its first Section 40 public interest report this year, marking an important milestone in its mandate. This report underscores NSIRA’s dedication to transparency and accountability in national security matters.

NSIRA’s 2024–2027 Strategic Plan

After five years of operation, NSIRA has developed its triennial strategic plan for 2024-2027, which will guide the Review Agency’s efforts in the coming years. The strategic plan focuses on NSIRA’s commitment to enhancing review; investigating complaints in a timely, fair, and efficient manner; fostering transparency; and strengthening public trust in NSIRA’s rigorous, fully independent review approach to Canada’s national security and intelligence activities.

NSIRA’s Role on the International Stage

NSIRA continues to strengthen its international partnerships, ensuring its work remains informed by, and a contributor to, global best practices in review. By engaging with international counterparts, NSIRA positions Canada as an active leader in upholding democratic values on the global stage.

We would like to thank the staff of NSIRA’s Secretariat for their expertise, efforts and resilience throughout this ambitious year and for their innovation, energy and commitment for the year ahead.

Executive summary

Without specialized national security review, much security service conduct would be immunized from scrutiny by reason of national security secrecy. The National Security and Intelligence Review Agency (NSIRA)’s raison d’être is to ensure that there is no such immunity. NSIRA has two mandates: conducting national security reviews of security or intelligence activities and conducting investigations of complaints from the public brought against a subset of national security and intelligence services.

In five years of existence, NSIRA has become a robust and professional reviewbody that conducts reviews and investigates public complaints, which reflect thehighest standards and core values of Canadian society: democracy, transparencyand the rule of law.

This 2024 Annual Report outlines the multiple spheres of activity through which NSIRA has contributed meaningfully to shaping the landscape of national security and intelligence review. This work is central to strengthening public trust, ensuring democratic oversight, and safeguarding the rights and freedoms of all Canadians.

Reviews

The Reviews section of this report provides a summary of each of the nine review reports that were approved by Members during 2024, including the Review of the Dissemination of Intelligence on People’s Republic of China Political Foreign Interference, which resulted in NSIRA’s first special report tabled under section 40 of the NSIRA Act, where NSIRA determined that releasing the report and its conclusions to Parliament was in the public interest. The review reports that NSIRA presented to the relevant departments and agencies in 2024 contain 67 findings and 45 recommendations.

Complaint Investigations

During the last five months of 2024, NSIRA observed a significant increase of public complaints against CSIS, alleging process delays in immigration or citizenship security screening which resulted in NSIRA ingesting an unprecedented number of new complaints.

NSIRA in Context

1.1 About NSIRA

The National Security and Intelligence Review Agency (NSIRA, the Review Agency) is an independent entity that reviews and investigates public complaints related to national security or intelligence activities to assess their lawfulness, reasonableness, and necessity. NSIRA may have up to seven Members, supported by a Secretariat with expertise in law, technology and national security, and led by an Executive Director appointed by the Governor-in-Council.

NSIRA has two mandates: reviewing Government of Canada national security or intelligence activities and investigating public complaints related to those activities.

NSIRA’s approach in managing its review process is innovative. Review teams are comprised of individuals with diverse skill sets. They execute reviews under the direction of a designated NSIRA member and relevant Secretariat management personnel. Similarly, NSIRA’s model for investigations of complaints relies on an NSIRA Member serving in a quasi-judicial investigative role, supported by legal, registry, and research staff.

1.2 NSIRA’s Vision and Mission

1.3 Unique Functions of NSIRA

NSIRA holds a unique and pivotal position within Canada’s national security accountability framework. With a mandate spanning the entire federal government, NSIRA can review any national security or intelligence activity, irrespective of the department or agency involved. This extensive jurisdiction enables NSIRA to carry out comprehensive, integrated, in-depth reviews of sensitive operations.

NSIRA also functions as a complaint investigation body, primarily examining national security-related allegations against the Canadian Security Intelligence Service (CSIS) or the Communications Security Establishment (CSE), activities of the Royal Canadian Mounted Police (RCMP) closely related to national security, and denials of security clearance by federal departments. These public complaints often involve serious allegations, and NSIRA’s capacity to address them enhances access to justice and the protection of individual rights.

With access to classified and legally privileged information, NSIRA is uniquely equipped to examine whether national security powers are exercised incompliance with Canadian law.

1.4 NSIRA’s Domestic Partnerships

As part of Canada’s national security and intelligence accountability framework, NSIRA and the National Security and Intelligence Committee of Parliamentarians (NSICOP) serve complementary yet distinct roles. While both play crucial roles in ensuring accountability, they differ in structure and mandate.

NSICOP is a committee of parliamentarians and focuses its reviews on the effectiveness of the national security and intelligence agencies. It is impacted by events such as elections or dissolutions. NSICOP’s makeup makes it uniquely well positioned to examine both the efficacy of the national security and intelligence community, in particular, its legal frameworks, and broad strategic trends across the national security landscape.

NSIRA operates year-round and maintains consistent engagement regardless of the Parliamentary schedule. Its mandate is to focus on the legality and legal compliance of national security and intelligence activities through in-depth reviews that dig down vertically into the operational events conducted on the ground. To deliver on its mandate to investigate complaints, NSIRA’s continuous operations are essential to ensuring that investigations are conducted without delay.

NSIRA and NSICOP both enhance transparency and accountability in national security via their distinct mandates, which ensures a complete approach to independent review. They actively coordinate efforts and avoid duplication. The respective secretariats have established a strong working relationship. Together, NSICOP and NSIRA form a complementary system supporting democratic accountability and continuous legal scrutiny.

NSIRA is committed to working within a system of partnerships with key actors. It is part of a larger network of federal review and accountability bodies and regularly engages with the Civilian Review and Complaints Commission, the Office of the Intelligence Commissioner, the Office of the Auditor General, and the Office of the Privacy Commissioner (OPC). These collaborations are about best practices, ensuring aligned mandates, minimizing redundancy, and reinforcing a broader framework of transparency.

1.5 Sustaining an Independent Review Body

NSIRA’s independence is the cornerstone of its credibility and effectiveness as a national security review body. Operating independently from the executive branch, NSIRA conducts impartial and expert reviews of Canada’s most sensitive security and intelligence activities. This institutional autonomy is not just a privilege, it is an attitudinal necessity and a responsibility that NSIRA takes seriously. It’s vital for preserving the integrity of its operations and cultivating public trust.

The NSIRA Act grants access to all information held by reviewed departments, including classified and legally protected information, except for Cabinet confidences. This access allows NSIRA to independently review the legality, necessity, and proportionality of government actions.

NSIRA’s reports, findings, and recommendations are not subject to any editorial control from the prime minister or any other minister, nor are they subject to any editorial control from senior officials. This approach preserves NSIRA’s voice and commitment to transparency and accountability.

To uphold this independence, NSIRA invests in secure digital systems, enhances internal governance, and develops expertise through targeted hiring and training. These initiatives improve the professionalism and integrity of NSIRA’s work.

1.6 Protecting Democracy and Freedoms

NSIRA ensures Canada’s national security activities align with the rule of law and the Canadian Charter of Rights and Freedoms, enhancing public confidence in Canada’s national security framework. NSIRA’s role is vital in upholding a national security system based on legality and democratic accountability.

In 2024, NSIRA’s reviews tackled foreign interference, bulk data, and technology-enabled intelligence activities. NSIRA’s findings led to recommendations to keep these powers within legal and ethical limits. By reviewing the extraordinary powers of the national security community, NSIRA plays a vital role in preserving the integrity of the rule of law in Canada.

1.7 Transparency and Engagement

Transparency is a core value at NSIRA, shaping how the Review Agency conducts its work. Increasing public understanding of NSIRA’s work and its findings and recommendations is a fundamental value of the organization. NSIRA aims to ensure that Parliamentarians, media, civil society, academia, and the broader Canadian public remain engaged in its work, enabling them to form their independent views on national security or intelligence issues and to hold government accountable.

In the challenging context of national security operations, absolute public transparency could unfortunately provide adversaries and threat actors with information that might harm Canada’s security interests, as well as those of its allies. NSIRA applies a rigorous balanced approach to release as much information as possible about its work in its commitment to transparency and openness, while safeguarding genuinely injurious national security information.

In 2024, NSIRA enhanced its public reporting efforts by announcing on social media each time a report was submitted to a Minister and by informing the public that reports can be accessed under the Access to Information Act. NSIRA also began publishing backgrounders to provide Canadians with greater clarity on the context of its reviews. As part of its commitment to openness, the Agency launched an updated and more accessible website.

Additionally, in 2024, NSIRA expanded its outreach initiatives to enhance public awareness and understanding of its mandate. NSIRA hosted new events with civil society, media, and academia. These initiatives aimed to deepen the understanding of NSIRA’s role and to foster informed dialogue about NSIRA’s work.

1.8 NSIRA’s Role on the World Stage

NSIRA’s partnerships extend beyond Canada’s borders through its active role in the Five Eyes Intelligence Oversight and Review Council (FIORC). As a permanent member, NSIRA actively collaborates with review agencies from Australia, New Zealand, the United Kingdom and the United States, fostering robust collaboration and knowledge exchange.

NSIRA has established strong partnerships with European counterparts, including agencies involved in the Intelligence Oversight Working Group made up of Belgium, Denmark, the Netherlands, Norway, Sweden, Switzerland, and the United Kingdom. These partnerships transcend routine collaboration, enabling collective learning on review methodologies and facilitating coordinated knowledge exchange on the development of international review best practices.

NSIRA has also been an active collaborator in some initiatives led by certain United Nations divisions that aim to improve global partnerships in the review and oversight sector. This has led to engagement with new international partners, delivery on online training modules, and new contributions to global standards in review.

Through these international engagements, NSIRA plays an active role in shaping a global community of practice that promotes the values of rigorous independent review of national security or intelligence activities.

Highlights on Key Initiatives

2.1 Reviewee Responsiveness

Access to information is fundamental to NSIRA’s ability to conduct effective reviews and investigations. In 2024, NSIRA observed encouraging progress in the responsiveness of several reviewees, particularly regarding the timeliness and completeness of their responses.

Despite these improvements, frustrations persist: overbroad, unsubstantiated or excessive demands for redactions in access to information consultations a reoccurring in every file, inconsistent disclosures in response to requests for information are routine, institutional resistance to NSIRA’s access rights occurs, and outdated departmental information systems at times impede NSIRA’s ability to conduct its work. NSIRA raises these issues with senior departmental officials and escalates to the Minister when necessary, with mixed results. While responsiveness performance varies across departments, it is fair to say that the status quo is one where process challenges regularly challenge NSIRA’s ability to deliver on its mandate. NSIRA is looking at ways to provide better real-time public awareness of its responsiveness challenges so that relevant departments can be held accountable.

2.2 Follow-Up on Recommendations

Monitoring the execution of recommendations is pivotal to NSIRA’s commitment to facilitate systemic improvement. In 2024, NSIRA strengthened its follow-up practices by initiating dedicated review cycles designed to evaluate the implementation of prior recommendations. The timeliness and comprehensiveness of recommendation responses differ among departments and agencies.

To facilitate this endeavour, NSIRA is in the process of developing internal tracking tools and protocols to assist in ensuring more consistent awareness, follow-up, and public communications about institutional responses and progress on NSIRA’s recommendations. NSIRA will continue to make advances in the years to come on this significant initiative.

2.3 Investigations: Volume Increase and Streamlining Processes

In 2024, NSIRA addressed a surge of CSIS-related complaints from the public tied to delays in immigration and citizenship screening. More than half of the new complaints related to such delays. Several of those new complaints resulted in informal resolutions.

NSIRA advanced initiatives to improve and streamline its investigative processes and procedures, as detailed in this report’s Complaint Investigations section.

2.4 Three-Year Strategic Plan

In 2024, NSIRA finalized its 2024-2027 Strategic Plan, setting a clear direction for its priorities over the next three years. The plan reaffirms NSIRA’s core values —Independence, Professionalism, Transparency, and Inclusiveness — and serves as a foundation for continuous improvement. It positions both NSIRA and its Secretariat to deliver effective, forward-looking review and investigations of public complaints. NSIRA aims to maintain the highest standards by focusing on contemporary issues, applying rigorous methodologies, delivering on its mandates with impartiality and efficiency, and continuing to modernize NSIRA’s processes and leverage new technologies to accomplish improved outcomes for Canadians.

To support NSIRA’s mission, the strategic plan invests in sustainable corporate infrastructure. This includes fostering a culture of continuous learning and maintaining high standards in information management, security, and human resources. The NSIRA Secretariat strives to be an agile and efficient workplace that attracts and retains top talent.

NSIRA also emphasizes its continued collaboration with domestic and international partners to strengthen its review and investigative capabilities. NSIRA aspires to be a globally recognized centre of excellence and a hub for a professional community dedicated to national security accountability. Through this strategic vision, NSIRA reaffirms its role as the trusted eyes and ears of Canadians in an evolving security landscape.

2.5 New Offices Built to High Standards

Between 2021 and 2024, NSIRA’s Secretariat led the planning, development, and delivery of a new office space for its staff. This complex undertaking involved meeting the highest standards of security, functionality, and design, all while supporting NSIRA’s growing operational needs. Despite tight timelines and evolving requirements, the Secretariat successfully transitioned into the new space efficiently, securely, and with minimal disruption to NSIRA’s core mandate.

Reviews

3.1 Overview

NSIRA’s review mandate is outlined in subsection 8(1) NSIRA Act and includes reviewing national security or intelligence activities of CSE and CSIS, as well as those of any other federal departments and agencies.

The review reports presented in 2024 to the relevant departments and agencies contain 67 findings, and NSIRA issued 45 recommendations.

Table 1 lists the reviews that gave rise to the reports produced and submitted to the responsible minister(s) by NSIRA, in 2024.

**Status as of the writing of this report. A review is marked as “Submitted” when the review report has been approved by NSIRA members and sent to the relevant minister(s).

3.2 CSIS Reviews

22-07—Review of the Lifecycle of CSIS’s Warranted Information

NSIRA examined CSIS’s lifecycle management of data resulting from a specific and novel technical capability used to execute a Federal Court warrant. NSIRA inspected CSIS’s primary collection and processing system to directly observe how data was collected, processed, and managed.

CSIS introduced heightened non-compliance risks when deploying the technical capability with inadequate operational policies and procedures, inadequate data stewardship practices, and inadequate technical systems to handle the resulting data. Consequently, CSIS retained information without a clearly articulated authority.

CSIS did not consult with Public Safety Canada as required by the Ministerial Direction prior to using the novel technology under review. CSIS’s failure to consult may not have been in compliance with the CSIS Act. CSIS mischaracterized the novel technology as an extension of an existing CSIS technology and failed to inform Public Safety Canada in a timely manner. CSIS did not advise the Federal Court of this novel technology.

These shortcomings raised concerns about CSIS’s readiness to assess, prepare for and deploy other novel technologies.

23-05—Annual Review of Select CSIS Activities (ARSCA-CSIS)

In 2024, NSIRA launched a process called the Annual Review of Select CSIS Activities (ARSCA-CSIS). This review covers a range of operational categories which are either routinely communicated to NSIRA by CSIS under a standalone statutory obligation or are of unique interest to NSIRA due to high legal risks or findings of prior reviews. In previous years, NSIRA conducted annual reviews of CSIS Activities that were primarily focused on NSIRA’s requirement to report annually to the Minister of Public Safety. However, these reviews did not culminate in a final report with findings and recommendations issued pursuant to section 34 of the NSIRA Act. The work completed this year as part of the ARSCA-CSIS is being captured in a final report with findings and recommendations, thereby aligning with NSIRA’s other thematic reviews. The report, which starting this year will be completed annually, will also contain the results of NSIRA’s efforts in reviewing an aspect of the CSIS Threat Reduction Regime. The ARSCA-CSIS report that will provide a high level overview of CSIS activities during the 2024 calendar year has been completed in 2025. Its findings and recommendations will appear in NSIRA’s public annual report for the calendar year 2025.

3.3 CSE Reviews

23-02—Annual Review of Select CSE Activities (ARSCA-CSE)

In 2024, NSIRA launched a process called the Annual Review of Select CSE Activities (ARSCA-CSE). This review covers a range of operational categories which are either routinely communicated to NSIRA by CSE under a standalone statutory obligation, or are of unique interest to NSIRA due to high legal risks or findings of prior reviews. In previous years, NSIRA conducted Annual Reviews of CSE Activities that were primarily focused on NSIRA’s requirement to report annually to the Minister of National Defence. However, these reviews did not culminate in a final report with findings and recommendations issued pursuant to section 34 of the NSIRA Act. The work completed this year as part of the ARSCA-CSE is being captured in a final report with findings and recommendations, thereby aligning with NSIRA’s other thematic reviews. The ARSCA-CSE report that will provide a high level overview of CSE activities during the 2024 calendar year has been completed in 2025. Its findings and recommendations will appear in NSIRA’s public annual report for the calendar year 2025.

23-10—CSE’s Equities Management Framework

NSIRA review of CSE’s Equities Management Framework (EMF) resulted in ten findings and seven recommendations that relate to two areas of concern, as well as several shortcomings related to governance and practices. However, at the time of writing, the full report remains heavily classified. As such, more information regarding this review, along with the related findings and recommendations, will be made available at a later date.

3.4 Other Department Reviews

21-20—RCMP’s Human Source Program

This review was conducted alongside reviews of similar programs at the Canada Border Services Agency and the Department of National Defence/Canadian Armed Forces.

NSIRA’s review focused on three areas: risk management, duty of care to human sources, and ministerial direction accountability. NSIRA found that risk assessments were inconsistently applied, leading to varied assessments on source suitability. The RCMP was overly reliant on confidentiality promises and failed to fully consider risks to sources. Risk assessments often prioritized investigative outcomes over the safety of informants and lacked proper documentation.

Additionally, NSIRA found that the RCMP did not exercise the required “special care” when sources operated in sensitive sectors. There were no mechanisms to assess the cumulative impact of such operations. Anecdotal evidence suggested these practices negatively affected both investigations and Canadian society. In addition, at the time of writing, NSIRA was still awaiting responses from departments to its recommendations.

3.5 Multi-Departmental Reviews

22-12— Public Safety and Canadian Security Intelligence Service Accountability Mechanisms (CSIS, GAC, PS, DOJ)

Following a September 2022 referral by the former Minister of Public Safety (PS), NSIRA reviewed whether CSIS’s risk assessment model, Ministerial Direction, and information-sharing mechanisms supported the Minister’s discharge of their responsibilities for CSIS.

Directions to CSIS coming from political level actors—rather than the Minister or the CSIS Director—during an active operation created unnecessary danger for the CSIS team and caused harm to Canada’s international reputation.

CSIS and PS failed to provide timely and accurate information to the Minister, which may result from PS’s dependence on CSIS to identify and receive relevant information. This would inhibit PS’s ability to prepare independent advice to the Minister.

Certain Ministerial Directions to CSIS are subject to inconsistent and contradictory interpretation, which affects their implementation. The report raises a number of issues with the pillars of risk evaluated: operational, legal, foreign policy, and reputational.

Ultimately, the Minister of Public Safety may not be consistently supported and briefed about pertinent CSIS operations, which raises concerns about the possible erosion of ministerial accountability for the CSIS.

23-11— Review of Government of Canada Institutions’ Disclosures of Information Under the Security of Canada Information Disclosure Act in 2023 (PS, CSE, CSIS, GAC, RCMP, CBSA, IRCC)

The purpose of this review was to determine whether Government of Canada (GC) institutions complied with the Security of Canada Information Disclosure Act (SCIDA)’s requirements for disclosure and record keeping in 2023. For the first time in SCIDA’s history, NSIRA has found full compliance with the Act, but NSIRA made seven recommendations to mitigate the risks of non-compliance.

Albeit compliant with the SCIDA, some IRCC disclosures presented a risk of non-compliance with SCIDA’s contribution and proportionality tests. The disclosing institution must be satisfied that both tests are met before making a disclosure under the SCIDA. Yet, four disclosures raised concerns with regard to the amount of personal information that IRCC disclosed.

At times, CSIS request letters were unclear, which hindered IRCC’s effort to conclude that the disclosure was authorized. The departments are required to provide information on the accuracy and reliability of the manner the disclosed information was obtained. However, NSIRA found that IRCC provided template statements on accuracy and reliability that were not always relevant.

CBSA’s record of disclosure form contradicts the SCIDA by suggesting that the provision of information on accuracy and reliability is optional.

24-03—Review of Departmental Implementation of the Avoiding Complicity in Mistreatment by Foreign Entities Act for 2023: Mitigation and Armed Conflict (CBSA, CSIS, CSE, DND/CAF, GAC, RCMP)

This review assessed departments’ compliance with the Avoiding Complicity in Mistreatment by Foreign Entities Act (ACA) and their implementation of the ACA’s associated directions (ACA Directions) during the 2023 calendar year. It focused on how departments mitigated a substantial risk of mistreatment when sharing information with foreign entities.

NSIRA reviewed a number of cases concerning disclosures to foreign entities engaged in armed conflict and considered how armed conflict affected departments’ ability to mitigate.

Three departments that shared with foreign entities engaged in armed conflict may not have been compliant with the ACA Directions.

A foreign country’s involvement in armed conflict created challenges for departments in meeting their mitigation obligations under the ACA Directions. NSIRA further observed challenges related to disclosures contemplated to serve humanitarian objectives. NSIRA noted that the circumstances of armed conflict left few options for departments pursuing humanitarian objectives to mitigate the risks resulting from sharing.

NSIRA directed departments to conduct a study of information-sharing with the foreign entities of countries engaged in armed conflict to analyze challenges incompliance with the ACA Directions and gaps in the ACA regime. In addition, at the time of writing, NSIRA was still awaiting responses from departments to its recommendations.

23-07—Review of the Dissemination of Intelligence on People’s Republic of China Political Foreign Interference, 2018-2023 (CSIS, RCMP, GAC, CSE, PS, PCO)

This review evaluated processes regarding how collected information was shared and escalated to relevant decision-makers, and indicated that there were significant disagreements in the national security and intelligence community as to whether, when, and how to share relevant information.

Three basic schisms existed: CSIS struggled to reconcile competing imperatives given the unique sensitivities of political foreign interference; the Security and Intelligence Threats to Elections (SITE) Task Force and the Critical Election Incident Public Protocol (CEIPP) Panel were geared toward broad, systematic interference and therefore could not adequately address riding-by-riding interference. PCO and CSIS analysts produced overviews of what they considered to be PRC foreign interference activities, but which the Prime Minister’s National Security and Intelligence Advisor (NSIA) saw as recounting standard diplomatic activity.

This challenging situation prompts us to ask how to address the so-called grey zone whereby political foreign interference may stand in close proximity to typical political or diplomatic activity. NSIRA saw evidence of this challenge across the activities under review. NSIRA’s eight recommendations address these deficiencies. In addition, at the time of writing, NSIRA was still awaiting responses from departments to its recommendations.

Complaint Investigations

4.1 Overview

NSIRA is responsible for investigating complaints from members of the public related to national security. These investigations are carried out with consistency, fairness, and timeliness.

NSIRA’s jurisdiction covers complaints regarding activities conducted by CSIS or CSE, national security-related complaints against the RCMP, complaints in relations to security clearance denials and, referrals from the Canadian Human Rights Commission (CHRC) or under the Citizenship Act.

In 2024, NSIRA continued to investigate a wide range of complaints from previous years, successfully bringing several to a conclusion. NSIRA also initiated many new investigations, including with respect to a large increase in public complaints against CSIS regarding immigration and citizenship security screening, as detailed further below.

Finally, NSIRA continues to implement several initiatives aimed at enhancing and streamlining its processes and procedures.

Increase of complaints against CSIS regarding delays in immigration or citizenship security screening

From August to December 2024, NSIRA observed a significant increase of complaints against CSIS filed pursuant to section 16 of the NSIRA Act, alleging process delays in immigration or citizenship security screening. Out of 79 complaints received pursuant to s.16 of the NSIRA Act in 2024, 52 (66%) related to such delays. Of note, under ss. 14 and 15 of the CSIS Act, CSIS provides security advice to IRCC and CBSA regarding immigration or citizenship applicants. CSIS has advised NSIRA that the time it takes to provide security advice is influenced by several factors, including the prioritization of files, resource limitations, and priorities established by the Government of Canada, such as special immigration measures and humanitarian initiatives in response to crises around the world.

As depicted by the statistics found at the end of the current section, several of these complaints have resulted in informal resolutions. More specifically, upon completion of CSIS’s security screening of a complainant’s citizenship or immigration application, CSIS provides a letter that can be shared with the complainant which indicates that the advice has been provided to the requesting client, and that CSIS’s role is now complete. The complainant may then elect to continue with their complaint or informally resolve it.

4.2 Ongoing Initiatives

NSIRA’s Rules of Procedure govern the process for complaint investigations. While respecting the classified nature of the proceedings, they ensure that parties have the fullest opportunity to participate and make representations, and that all proceedings are conducted as informally and expeditiously as possible.

In 2024, NSIRA continued its internal review of the Rules of Procedure to identify issues and develop proposals for future revisions. The review aims to ensure that all investigations remain accessible, efficient, and procedurally fair.

Specifically, NSIRA also created a new rule on accessibility and accommodations. The rule will enable NSIRA to meet its commitment to identify, remove, and prevent barriers to accessibility to the greatest extent possible. This will help to ensure that those with disabilities can continue to fully participate in the complaint investigation process.

NSIRA also began developing another new rule to create a streamlined process for simplified investigations of non-complex complaints.

4.3 Investigation Report Summaries

Final Reports Issued

Harassment allegations against the Royal Canadian Mounted Police

(NSIRA File 07-407-13)

The Complainant alleged that RCMP members had shown up unannounced and without a warrant at their home. The Complainant alleged harassment by the said RCMP members during that unexpected visit. The RCMP members went to the Complainant’s home following an anonymous report, according to which the Complainant had made threats against the Prime Minister.

The interaction between the RCMP members and the Complainant was filmed by the bodycam worn by a municipal police officer. The video was submitted as evidence by the RMCP in the NSIRA investigation.

Following a review of the documentary evidence submitted by the RCMP and the Complainant, as well as an investigative interview with the latter, NSIRA found that under the implicit invitation provided by Common Law, the RCMP members had the right to go unannounced and without a warrant to the Complainant’s house to have a discussion with the said Complainant. The purpose of the RCMP members ’visit was to determine whether the Complainant posed a threat to the public and to the Prime Minister, not to substantiate any accusations against the said Complainant or to make an arrest.

NSIRA also found that the RCMP members had not harassed the Complainant during the interaction.

NSIRA found the Complainant’s allegations to be unsubstantiated.

Allegations against the Department of National Defence for denial of Top Secret security clearance and revocation of reliability status

(NSIRA File 07-404-30)

The Complainant alleged that, based on their voluntary disclosure during security interviews, they were denied a Top Secret security clearance and had their reliability status revoked, which resulted in their release from the Canadian Forces. NSIRA found that it had no jurisdiction to make findings and recommendations regarding revocation of reliability status and confined its discussion to matters implicating the security clearance decision only.

The Complainant alleged that the Vice Chief of the Defence Staff’s (VCDS) security clearance decision was flawed for several reasons, including that the Complainant’s sexuality influenced the VCDS decision; the VCDS did not take into account the Complainant’s mental health situation and failed to inquire about amental health nexus in their case and provide accommodation; the decision did not meet DND’s security screening standards; the decision was inconsistent with the recommendation offered by the Complainant’s commanding officer; and the decision did not acknowledge a number of considerations that might mitigate the seriousness of the adverse information against the Complainant.

NSIRA found the Complainant’s allegations to be unsubstantiated. Specifically, NSIRA found that the VCDS decision was not motivated by a concern or consideration of the Complainant’s sexuality or sexual orientation; that in the circumstances, no duty to accommodate was triggered for the purposes of the VCDS decision based on the Complainants mental health situation; that were unsubstantiated the allegations that the VCDS failed to meet security screening standards and that DND failed to properly review the surrounding circumstances; that the assertion that the VCDS decision was improper because it was inconsistent with the Complainant’s commanding officer’s recommendation was unsubstantiated; and that the Complainant’s other allegations, including those with respect to considerations that might mitigate the seriousness of the adverse information against them, did not individually or collectively render the decision unreasonable. In addition, NSIRA found no violation of procedural fairness.

However, NSIRA observed that certain exculpatory information was excluded from the Threat and Risk Assessment (TRA) before the decision-maker and recommended that this practice be rectified in the future. However, this omission did not amount to a breach of procedural fairness in the circumstances.

Allegations against CSIS for racial profiling, interrogation and harassment, information-sharing with foreign agencies, travel difficulties, and citizenship issues

(NSIRA File 07-403-05)

The Complainant alleged that CSIS had been racially profiling them; that CSIS agents harassed and interrogated them on multiple occasions; that CSIS shared information about them with foreign countries, leading to them having travel difficulties; that CSIS was responsible for their travel difficulties; and that CSIS put their citizenship application on hold.

SIRC took jurisdiction of this complaint in 2018, and when NSIRA came into force in2019, this investigation was deemed to be continued before NSIRA.

In the investigative report, NSIRA provided clarity on the standard of review in section 16 complaints — namely, that NSIRA is charged with making findings and recommendations with respect to legality, reasonableness, and necessity in the exercise of CSIS’s powers. In gauging reasonableness and necessity, the Member adopted an objective standard: would a reasonable person charged with exercising CSIS’s mandates and apprised fully of the facts, as were available to CSIS, conclude that CSIS’s exercise of its powers was necessary and proportional?

On the facts of this investigation, NSIRA found that the allegations were unsubstantiated, but made several recommendations. The recommendations addressed observations concerning how CSIS manages the aftermath of section 12 investigations and the circumstances in which CSIS should retract or correct information that it shared with foreign agencies.

Allegations against CSIS for conspiracy, electronic surveillance, travel difficulties, information sharing, and unlawful conduct

(NSIRA File 07-403-69)

The Complainant alleged that CSIS directed an unlawful seizure of their property in 2011; unlawfully shared information with Canadian and foreign authorities; conspired with government departments; harassed, surveilled, targeted, and intercepted their phone calls; acted unlawfully and breached their human or Charter rights. In addition, the Complainant alleged that they had issues reentering Canada after the impugned seizure took place due to CSIS’s activities. NSIRA found that the allegations were unsubstantiated.

Allegations against CSE for breach of consent and procedural fairness as part of security screening and hiring processes

(NSIRA File 07-406-04)

The Complainant alleged that, as part of their security screening and hiring processes at CSE, CSE breached their consent and procedural fairness; squandered government resources; failed to use approved security screening tools that have been approved by TBS and undergone the required Privacy Impact Assessment; received verbal disclosures or slander from the Complainant’s former employer regarding their character; harassed them; denied them a security clearance; and cited suitability concerns as a technique to circumvent NSIRA’s jurisdiction under section 18 of the NSIRA Act with respect to complaints related to denials of security clearances.

NSIRA concluded that the Complainant’s first allegation that CSE had breached their consent, and more specifically that CSE improperly used information the Complainant disclosed during their security interview for human resources and suitability purposes, was supported. The consent form signed by the Complainant in preparation for the security interview only contemplated the collection of information for the purpose of obtaining a security clearance. The evidence before NSIRA revealed that the Complainant was not advised prior to the security interview that the information collected could have been subsequently used for other purposes, including to assess their suitability for employment. Accordingly, NSIRA found that CSE had not complied with section 7 of the Privacy Act.

With respect to the Complainant’s remaining allegations against CSE, NSIRA found that they were unsubstantiated by the evidence.

In its Final Report, NSIRA issued two recommendations:

• That CSE review the consent form that is presented to and signed by candidates prior to a security interview as part of the security screening process, and amend it accordingly; and
• That CSE consider undertaking a Privacy Impact Assessment of its security interview questionnaire if one has not been conducted yet.

Allegations against CSIS for racism/racial profiling, harassment, slander, information-sharing with foreign agencies, travel difficulties

(NSIRA File 07-403-12)

The Complainant alleged that CSIS subjected them to harassment, racial profiling, and slander. The Complainant suggests that they were targeted because of their racial or ethnic background, legitimate political opinions, and due to their work as a confidential police informant. They suggested that, due to CSIS’s conduct, they had social, psychological and financial hardship, and difficulty travelling.

SIRC took jurisdiction of this complaint in January 2019, and when NSIRA came into force in July 2019, this investigation was deemed to be continued before NSIRA.

NSIRA found the Complainant’s allegations to be unsubstantiated. Specifically, it found that CSIS did not unlawfully investigate the Complainant or engage in racial profiling; did not target the Complainant because of their activities as a confidential police informant; did not slander or defame the Complainant, damage their reputation or sabotage their relationships; did not harass the Complainant or conduct interviews with them in an unlawful or unreasonable manner; did not unlawfully or unreasonably share information about the Complainant with foreign agencies or collude with them to interfere with their travel; did not breach the Complainant’s privacy rights under the Charter; and did not unlawfully retain personal information.

4.4 Other Outcomes

Allegations against CSIS’s role in delaying security assessment regarding immigration or citizenship applications

(NSIRA Files 07-403-98, 07-403-100, 07-403- 101, 07-403-105, 07-403-106, 07-403-110, 07-403-113, 07-403-118, 07-403-124, 07- 403-125, 07-403-126, 07-403-127, 07-403-129, 07-403-131, 07-403-132, 07-403-133, 07-403-135, 07-403-136, 07-403-151, 07-403-155)

A number of Complainants filed complaints against CSIS alleging that CSIS caused a significant delay in providing security screening advice for their immigration or citizenship applications. CSIS provided letters to NSIRA that could be shared with the Complainants advising them that CSIS had provided its advice to the requesting client and that CSIS’s role in the security screening process was complete. As the Complainants’ main allegations against CSIS were in relation to the delay in the security screening, NSIRA inquired with the Complainants as to whether they wished to resolve their complaints in light of the update received. In the above-referenced files, the Complainants informed NSIRA that they did not wish to proceed with an investigation into their respective complaints against CSIS. As such, the matters were informally resolved in accordance with Rule 10.10 of NSIRA’s Rules of Procedure or withdrawn.

Deemed abandonment of complaint against a government department for denial of security clearance resulting rescinded job offer

(NSIRA File 07-404-25)

The Complainant alleged that, after being offered employment by a Government of Canada department conditional upon obtaining a Reliability and Secret clearance, they were denied said clearance because of a residency issue. The Complainant alleged that this was an inaccurate application of clearance policies, and that the employment offer was rescinded after the Complainant indicated that they would pursue the matter further.

NSIRA found the complaint to be deemed abandoned according to Rule 15.02 of NSIRA’s Rules of Procedure, following its reasonable attempts to communicate with the Complainant who refrained from participating in the process.

Informal resolution of a complaint regarding the denial of a security clearance

(NSIRA File 07-404-37)

The Complainant alleged that they were denied employment with an agency in the Government of Canada due to the denial of the required Top Secret security clearance. The Complaint alleged that the decision was based on inaccurate information and that the agency disregarded exculpatory information that the Complainant provided to correct the inaccuracies. The Complainant also alleged that they had a pending Secret security clearance application with another department that was unreasonably delayed.

Following an informal resolution meeting facilitated by NSIRA and attended by the Complainant and responding government agency, the parties asked NSIRA to place the investigation into abeyance pending the outcome of the Complainant’s Secret security clearance application. NSIRA granted the request. The Complainant subsequently informed NSIRA that they received their Secret security clearance and no longer wished to proceed with the complaint. NSIRA accepted the informal resolution.

4.5 Statistics on Complaint Investigations

Looking Ahead

5.1 Advancing NSIRA’s Vision

NSIRA’s vision — an accountable, transparent, and effective national security and intelligence community that upholds the rule of law — has guided every aspect of the Review Agency’s work in 2024. Through expanded transparency initiatives, timely public reporting, and continuous methodological refinement, NSIRA has demonstrated its commitment to achieving this vision. Whether through public-facing communications, the release of unclassified/redacted materials, or the ongoing enhancement of its website, NSIRA has remained focused on building public trust.

With the finalization of its 2024-2027 Strategic Plan, NSIRA has established a clear framework for advancing its mandate in the years ahead. The coming year will focus on strengthening the Review Agency’s core activities by enhancing review capacity and output, deepening subject-matter expertise, and expanding on the agility of complaint investigations.

Guided by its strategic priorities, NSIRA will place greater emphasis on proactive engagement. This includes increased outreach to the media, academic, civil society, parliamentarians, and domestic oversight bodies such as Agents of Parliament. NSIRA also aims to strengthen its relationships with international counterparts to continue sharing best practices and contribute to global efforts in national security accountability. These initiatives will support NSIRA’s continued evolution as a modern, transparent, and effective review body well positioned to meet the challenges of 2025 and beyond.

Annexes

Annex A: Abbreviations

Annex B: Statistics and Data

The statistics and data below are provided as per NSIRA’s historical practice of including general data received annually from CSIS and CSE. NSIRA has not independently verified or assessed the numbers. Starting next year, such statistical data will be reproduced with the value added of NSIRA analysis and commentary as part of the summaries of the ARSCA-CSIS and ARSCA-CSE review reports.

CSIS Statistics and Data

Total Number of Approved and Executed Threat Reduction Measures 2019-2024

Total Number of CSIS Targets, 2019-2024

Evaluation and Retention of Publicly Available, Canadian, and Foreign Datasets by CSIS, 2019-2024

Authorizations, Commissions, and Directions Under CSIS’s Justification Framework, 2019-2024

Total Number of Non-Compliance Incidents Processed by CSIS, 2019-2024

Ministerial Authorizations

Ministerial Orders

Canadian Identifying Information

Privacy Incidents

Technical and Operational Assistance