The 2020 Canada Summer Jobs application is open! You have until February 24, 2020 to submit your application.

No doubt you’re asking, “what is the attestation this year?” and “can we in good conscience apply?” As with past CSJ applications, we fully recognize that charity leaders must make up their own minds as to whether they are comfortable with the terms and conditions (the strings) attached to funding. To help you decide, we’ll look at the requirements for 2020 as set out in the Applicant Guide and the Articles of Agreement.

What’s the Same?

The Attestation is word for word the same as last year. It remains “any funding under the Canada Summer Jobs program will not be used to undermine or restrict the exercise of rights legally protected in Canada.”

The 15-point eligibility criteria also remain the same. The 15 requirements include the obvious items:

1. Meet the deadline
2. Check the attestation
3. Complete the application

…some seemingly redundant items:

4. Employer is eligible
5. Project is eligible

…job timing:

6. Duration of 6-16 consecutive weeks
7. Full time hours (30-40/week)

…money considerations:

8. Identify other sources of funding
9. Salary respects minimum wage requirements
10. Organization declares any money owed to the government

…plans and policies:

11. Health and safety – demonstrate measures have been implemented that relate to the type of work environment, job type, and job activities
12. Hiring practices and work environment – hiring policies and work environment policies to ensure no harassment or discrimination
13. Supervision – describe the plan
14. Mentoring – describe the plan

…and lastly:

15. How your organization has done in the past.

Here the government will review “all files associated with your organization” for “documented evidence” that would make the 2020 application ineligible. What would that documentation be? It includes – but is not limited to – financial irregularities, health and safety concerns or past project results. This was new in 2019 and has been carried over into 2020.

The objectives to provide quality work experiences for youth, respond to local and national priorities to improve access to the labour market for youth who face unique barriers, and provide skills-development opportunities to youth, all remain the same.

There is a lot of emphasis on safe, healthy work environments free of harassment and discrimination. It should be self-evident that faith-based organizations ought to be promoting and ensuring safety and health, and striving for workplaces free of harassment and discrimination. But as we know, the term discrimination is often used in an indiscriminate way. So let’s take a look at what’s new for 2020.

What’s Different?

There are a few changes that we need to note.

First, the aim.

In 2019 the aim was to “ensure that youth job opportunities funded by the program take place in an environment that respects the rights of all Canadians.” In 2020 the aim is to “ensure that youth job opportunities funded by the program take place in safe, inclusive and healthy work environments free from harassment and discrimination.”

Second, the description of what makes a quality job placement.

In 2019 the starting point for quality job placements was a safe, inclusive and healthy work environment, along with other specific characteristics:

• Paying above minimum wage
• Retaining the youth as an employee beyond the CSJ period
• Providing short and long-term support for success – supervision & mentoring plans
• Provide skills-development opportunities
• A safe, inclusive work environment as demonstrated by detailed health and safety practices

In 2020, all of these factors still apply with two small changes. First, the starting point is broader; it is a safe, inclusive and healthy work environment free from harassment and discrimination. Second, health and safety practices are separate and distinct from work environment policies and practices. Employers need to have implemented measures to provide a work environment free from harassment and discrimination, including non-discriminatory hiring practices.

Third, there is a heightened emphasis on hiring policies in the eligibility requirements.

In 2019, employers had to demonstrate that hiring practices and work environments were free of harassment and discrimination by implementing measures such as raising awareness and prevention activities.

In 2020, employers must demonstrate that they have implemented measures to ensure their hiring practices and work environment are free of harassment and discrimination.

This is a subtle shift in language, and perhaps it is nothing more than a refinement of the Guide. More on this below.

Fourth, the employer information required.

In 2019, organizations had to describe measures to ensure hiring practices and a work environment were free of harassment and discrimination.

In 2020, organizations must identify and describe the work environment policies and practices that have been implemented. It is mandatory to provide such an environment, and organizations must identify and describe the following:

• Hiring policies & practices
• Harassment policies & practices
• Conflict resolution policies
• Employee and/or management training
• Other: any additional practices that demonstrate concrete efforts to create an inclusive work environment.

Here, applicants are reminded that the project cannot consist of projects or activities that

• restrict access to programs or, services, or employment, or otherwise discriminate, contrary to applicable laws, on the basis of prohibited grounds, including sex, genetic characteristics, religion, race, national or ethnic origin, colour, mental or physical disability, sexual orientation, or gender identity or expression
• advocate intolerance, discrimination and/or prejudice, or
• actively work to undermine or restrict a woman’s access to sexual and reproductive health services.

These restrictions as well as the definition of “project”,[1] “advocate”,[2] and “undermine or restrict”[3] remain the same as last year. They have been moved from the description of project eligibility in 2019 to the employer information section in 2020.

Do the changes mean anything?

Well, it depends.

It depends on how the hiring policies are examined. It depends on whether the right of organizations to hire based on shared religious beliefs is respected (the attestation prohibits only projects that discriminate “contrary to applicable laws”). It depends on whether the government adheres to its duty of state neutrality in how it evaluates applications.

As in 2019 we find ourselves in the position of uncertainty as to how the government will interpret its 2020 requirements. We can be certain that hiring policies will be scrutinized to a much greater degree. But how that translates into approvals or rejections is unclear.

We can see that hiring policies are more important in the application process this year. And we know that last year, organizations that were asked to provide additional documentation about these policies were often not approved. It is possible that we may not see much change from last year, but it would also not come as a surprise to see more organizations rejected on the basis of hiring policies that, though perfectly legal and falling within human rights code protections for faith-based organizations, are unpalatable to our governing elites.

Where does CCCC land?

In 2019, CCCC encouraged all Christian charities to apply for funding since applicants were no longer required to attest to their agreement with government ideology on abortion and sexual issues. As noted at the outset, we respect the view that merely applying for CSJ funding is to acquiesce to the government’s position on “sexual and reproductive health services” including abortion. And each charity must reach its own conclusion.

However, we at CCCC arrive at the same conclusion as last year. Namely, that the phrase “undermining, or restricting” does not deny the right of religious organisations to speak or teach or live their religious views in opposition to the government’s worldview, as this is not “contrary to applicable laws.” Nor is it contrary to applicable laws for faith-based organizations to hire in accordance to their faith. Therefore, we would again encourage Christian charities to apply for funding in 2020.

[1] Project means the “hiring, administration of, job activities, and organization’s activities as described in the Application Agreement.”

[2] Advocate means “to promote, foster, or actively support intolerance, discrimination, and/or prejudice.”

[3] Undermine or restrict means “to weaken or limit a woman’s ability to access sexual and reproductive health services. The Government of Canada defines sexual and reproductive health services as including comprehensive sexuality education, family planning, prevention and response to sexual and gender-based violence, safe and legal abortion, and post-abortion care.”

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