This entry is part 30 of 30 in the series Canada Summer Jobs.

Canada Summer Jobs (CSJ) applications for 2022 are open. Applications are due January 25, 2022. As in previous years, we fully recognize that charity leaders need to make up their own minds as to whether they are comfortable with the terms and conditions attached to CSJ funding. To help you decide, we’ll look at the requirements for 2022 as set out in the Applicant Guide and the Articles of Agreement.

Key Dates

  • January 25 – deadline to apply
  • April 25 – earliest job start date
  • July 24 – latest job start date
  • September 3 – latest job end date

Funding confirmation will be sent to employers starting in April 2022.

What’s Different?

No COVID-related flexibility

Last year CSJ was adjusted due to COVID-19. These temporary measures are no longer in effect. That means:

  • Jobs need to end by September 3
  • Jobs need to be a minimum of 30 hours/week
  • Jobs need to last at least 6 weeks

Last year the subsidy was higher for private sector employers, part time jobs were allowed, and the allowable employment period was much longer.

Allowing for remote work

The Applicant Guide notes that remote work may be a necessity. Remote work is defined as “a flexible arrangement” that allows employees to carry out some or all of their work duties from a telework place.” Where work is performed remotely, employers are responsible for ensuring that:

  • The location respects provincial laws and municipal by-laws
  • There is continued and adequate supervision, mentoring, and safety provisions
  • The location is within Canada

National Priorities

Applications are assessed using a variety of criteria. One of those is whether the job/project supports a national priority. For 2022 the national priorities are:

  • Youth who are early leavers of high school, not in employment, education or training
  • Black and other racialized youth
  • Youth with disabilities
  • Indigenous youth; and
  • Small business and not-for-profit organizations that self-report as having leadership from groups that are underrepresented in the labour market

This is a change from the 2021 national priorities, which were:

  • Youth who self-identify as being part of an underrepresented group or having additional barriers to entering or staying in the labour market (new immigrants or refugees, Indigenous youth, not completed high school, visible minorities, LGBTQ, women in STEM, youth for whom this would be their first job)
  • Organizations that provide services to people with disabilities or intend to hire youth with disabilities
  • Opportunities in rural areas, remote communities or official language minority communities
  • Organizations that focus on protecting and conserving the environment
  • Employers impacted by COVID-19

Local priorities are also used to assess applications. Those vary from constituency to constituency.

Application Process

You can save it!

If you’re using the online application, you’ll be able to save and access your application at a later date. To save your draft application, you have to provide your email address and create a password. You then have 48 hours to complete and submit the application. Your password cannot be reset, so make sure you don’t forget. Otherwise, all of your draft work will be lost!

You’ve got 20 minutes.

If you leave the online application inactive for 20 minutes, it will become unavailable. If you need more time, you’ll probably want to save a draft and come back to you so you don’t lose your work.

The paper version of the application has been formatted differently so that it’s easier to use.

Fine Print

In the Articles of Agreement, there are a few new sections of fine print for 2022. This includes:

  • Notices – it sets out how notice is given to parties, whether by mail or email or courier, and when the recipient is deemed to have received that notice
  • Severability – if a part of the Agreement is held void or unenforceable by a court or tribunal, the rest of it is still enforceable
  • Waiver – failing to exercise a right, power or remedy under the agreement is not a waiver of those rights

The “Access to Information” section from the 2021 Articles of Agreement has been removed. It explained that all information pertaining to the Agreement was public information and could be disclosed to third parties who make requests under the Access to Information Act. That section largely duplicated an existing section about “Access to Information and Proactive Disclosure” which is maintained in the 2022 Articles of Agreement.

What’s the Same?

Attestation

The attestation remains the same as 2021 and 2020. It requires that “any funding under the Canada Summer Jobs program will not be used to undermine or restrict the exercise of rights legally protected in Canada.”

Ineligible Projects

Similarly, the description of ineligible projects remains the same as 2021 and 2020. Ineligible projects and job activities are those 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.

Definitions of “Project”, “Advocate”, and “Undermine or Restrict”

These terms are all defined the same as in 2021 and 2020:

  • Project means the “hiring, administration of, job activities, and organization’s activities as described in the Application Agreement”
  • Advocate means “to promote, foster, or actively support intolerance, discrimination, and/or prejudice”
  • 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”

Program Objectives

The three CSJ program objectives remain the same as in 2021 and 2020:

  1. Provide quality work experiences for youth
  2. Respond to national and local priorities to improve access to the labour market for youth who face unique barriers
  3. Provide opportunities for youth to develop and improve their skills

These objectives fall within the same broad aim of ensuring that all the CSJ opportunities “take place in safe, inclusive and healthy work environments free from harassment and discrimination.”

List of Mandatory Workplace Policies

Employers have to show that they have implemented Health & Safety practices and policies and practices to create a work environment free of harassment and discrimination. In 2021, the format changed to a check-box, with a list of policies or practices for each of those categories. The list included a number of new policies for 2021. The list remains the same for 2022, with the exception that COVID-19 policies are not included. Instead the Applicant Guide reminds employers that they’re responsible for staying informed of and following all applicable COVID-19-related guidance.

15-Point Eligibility Criteria

  1. Meet the deadline
  2. Check the attestation
  3. Complete the application
  4. Employer is eligible
  5. Project is eligible
  6. Job duration of 6–16 consecutive weeks *this is the norm after a temporary COVID-related change for 2021
  7. Job hours of 30–40/week *this is the norm after a temporary COVID-related change for 2021
  8. Declare other sources of funding
  9. Salary respects minimum wage requirements
  10. Declare any money owed to the government
  11. Health and safety
  12. Hiring practices and work environment
  13. Supervision – describe the plan
  14. Mentoring – describe the plan
  15. How your organization has done in the past

How Applications are Assessed

It’s the same, but it bears repeating: the Department reviews all files associated with your organization to verify if there is evidence from previous agreements that would make your application ineligible. The Department may also review:

  • Information in the public domain, including your website and media articles
  • Previous applications
  • All previous correspondence, including responses to requests for missing information or clarification
  • Past financial irregularities, noted in consultation with CRA

What Will Happen this Year?

That’s not a question we can really answer. But if we look at past years, we can see that faith-based organizations’ applications were rejected for a variety of reasons. For example, statements of faith that adhere to a biblical definition of marriage, because all staff agree to sign statements of faith, or for other similar reasons. On that basis, we shouldn’t be surprised to see more of the same this year. However, we also have several court decisions relating to the CSJ program.

In Toronto Right to Life, the organization challenged the 2018 Attestation. The court held that the Minister had the authority to add the Attestation. Even though it was a form of coerced speech and did engage both free expression and religious freedom, the limit was justified and proportional. It was a one-time impact on potential, but not certain, funding.

However, earlier this year the Federal Court found that the government CSJ process was unfair to religious applicants. If an organization could establish that officials discriminated against faith-based institutions because of their religious beliefs, it may well result in a Charter violation.

Hopefully the court’s caution will give the government pause before rejecting applicants on the basis of statements of faith or other manifestations of sincere religious beliefs.

What to do?

Over the past three years, CCCC encouraged Christian charities to apply for funding since applicants were no longer required to attest to their agreement with government ideology on abortion and matters of sexuality.

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.

In the end, we arrive at the same conclusion as last year. Namely, that the phrase “undermining, or restricting” ought not deny the right of religious organizations to speak or teach or live their religious views, even if that doesn’t align with the government’s worldview. It is not contrary to applicable laws for faith-based organizations to hire in accordance with their faith. Therefore, we would again encourage Christian charities to apply for funding in 2022.

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Noteworthy is provided for general information purposes and does not constitute legal or professional advice. Every organization’s circumstances are unique. Before acting on the basis of information contained in this blog, readers should consult with a qualified lawyer for advice specific to their situation.

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