Section 10 - Compliance and Enforcement |
The immigration system enables people to enter and stay in the country for their benefit and the benefit of New Zealand. At the same time, it enables the government to ensure the safety and security of New Zealand in a challenging global environment. One of the greatest challenges is ensuring that appropriate risk management and enforcement of immigration laws are not at the expense of facilitating genuine migrants and visitors.
New Zealand needs to be able to manage the immigration system in a fair, efficient and effective way. We need to be able to facilitate entry to New Zealand and the ability of people to undertake certain activities, such as work or study. At the same time, migrants and visitors must obtain their permit legitimately and must comply with the rules of their permit. They must abide by New Zealand law (just as any New Zealander must) and leave before their temporary permit expires.
As outlined in Section 3: Purpose and principles, the government needs to be able to maintain the integrity of the immigration system. There are clear expectations that the Department of Labour will be able to:
This section considers the powers needed to enable the government to meet the expectations of managing a fair, efficient and effective immigration system. It looks specifically at how to ensure that non-citizens comply with their responsibilities. To achieve these objectives, the new legislation must do the following:
Access to information, especially address information, is essential for monitoring immigration compliance. This subsection considers:
This subsection considers three scenarios concerning locating and investigating people who may be liable for expulsion because they:
The Privacy Act 1993 generally requires that personal information should only be disclosed to another person or agency in certain circumstances. In particular, it allows information to be disclosed to maintain the law.
The Privacy Act 1993 allows information held by a government agency to be disclosed to another government agency where necessary to avoid prejudice to maintenance of the law. It therefore allows information to be given to the Department of Labour for investigations into people who may not be fulfilling their immigration responsibilities.
The Immigration Act gives immigration officers the power to require information from organisations (not limited to government departments) listed in Schedule 1 of the Act. The information that can be required is limited to information about:
This power is exercised on a case-by-case basis in relation to people suspected of being in New Zealand unlawfully. The Immigration Act also gives immigration officers the power to inspect:
Schedule 1 sets out the following organisations that may be required to provide immigration officers with information when requested:
The information that may be required includes:
Officers do not have any powers to require information to assist them to locate a person here lawfully, but who may have obtained that status through fraud or misrepresentation. In order to investigate such cases, the officer must generally first locate the person and give them an opportunity to respond.
Schedule 1 of the Immigration Act is useful if the agency holds information about the person being located. Immigration officers also rely on information supplied in immigration applications and by informants to detect and locate people who are not complying with their immigration responsibilities.
Current enforcement work by the Department of Labour results in approximately 1,200 people being removed from New Zealand each year, and a further 1,200 (approximately) leaving voluntarily each year. These are people who are in New Zealand unlawfully. Their permits may have expired, or their permit may have been revoked for breaching their permit conditions (for example, they may be working without an entitlement to work).
In immigration investigations regarding possible fraud, giving a person the opportunity to respond to a case against them ensures that immigration investigations are balanced and fair. It supports the principle of a fair immigration system and incorporates natural justice protections into the process. It also allows officers to make effective decisions based on all the facts and information available.
Immigration officers have the power to require only basic contact details from the organisations listed in Schedule 1 of the Immigration Act. This limitation restricts the pool of information available. A number of industries that may hold information about individuals are not represented in the list in Schedule 1. For example, the list does not include insurance organisations, Clear Communications no longer exists, and other telecommunication companies, such as Vodafone, are not on the list.
From time to time, government agencies are unclear as to whether the Privacy Act allows them to disclose information to the Department of Labour. There is an opportunity to consider adding further government departments to the list currently in Schedule 1 to provide that clarity.
Further, while immigration officers may access wage and time records when investigating employment, there is no right to access or copy additional material that relates to a person's employment activity. The inability to access and retain useful information means that often investigations are unable to proceed.
Difficulties such as these reduce the ability of the Department of Labour to take timely and appropriate action against those who do not fulfil their immigration responsibilities. They create incentives for people to not comply with the requirements of their permit.
Locating people who are subject to investigations for immigration fraud is also very difficult without a power to obtain address information. When a person cannot be located, the process of undertaking a balanced and fair investigation is undermined. It makes it difficult to ensure a person's rights to natural justice are protected. The Department of Labour can be aware of cases of immigration fraud but can be unable to investigate thoroughly. The ability to locate people that are the subject of immigration investigations would better support the integrity of the immigration system.
The numbers of permit revocations as a result of immigration investigations each year are very small (only eight in 2004/05). They do not reflect the number of cases where the Department of Labour has evidence of people failing to comply with their immigration responsibilities or committing fraud. Being unable to investigate immigration offences undermines the ability of the Department of Labour to support a fair immigration system that works for New Zealand's benefit.
In Australia, immigration officers have the power to require private sector groups to provide information (such as address or contact information) and documents that assist in locating an unlawful non-citizen. In addition, Australia's legislation provides for the granting of an entry and search warrant to allow officers to find information related to the whereabouts of unlawful non-citizens.
Australian immigration officials do not investigate immigration fraud cases. Such investigations are left to Police, who have wide ranging powers. Australian legislation specifically excludes the ability of immigration officers to require information about non-citizens lawfully present in Australia.
The United Kingdom (UK) has various search, entry and arrest powers for immigration officers locating individuals who are overstaying the length of a valid permit, or are otherwise in breach of immigration law. The legislation enables immigration officers to search for and seize personnel records following the arrest of a suspected immigration offender.
In Canada, immigration officers can apply for warrants to obtain information on the location of people wanted on an immigration arrest warrant. They can also request warrants to find information relating to an inadmissibility investigation.
Individual privacy is an important value that is protected by the Privacy Act and recognised in common law. The Privacy Act sets out that importance of protecting individual privacy may be outweighed by the need to uphold New Zealand's law.
For the reasons noted above, the status quo is not considered adequate. The approach presented below is based on making improvements to existing powers and is preferred.
The new Immigration Act would provide for officers to require address information, or information on non-compliance with permit conditions, to locate and investigate people who may be liable for expulsion because they:
Organisations that may be required to provide address information would be better targeted to include:
Some government agencies could also be included, to provide clarity and transparency about when it is acceptable to disclose an individual's information. In practice, immigration officers would contact the minimum number of agencies required to locate the person.
Employers may also be required to provide:
This would allow an officer to require a broader range of information than the wage and time records. The legislation would require that information be sought only where there is a reasonable suspicion that an individual is not complying with their immigration responsibilities. The power could not be used to indiscriminately investigate people. The powers would have to be exercised in a manner that is consistent with the New Zealand Bill of Rights Act, and exercise of the powers would be subject to judicial scrutiny.
This approach is likely to improve the ability of immigration officers to locate people unlawfully in New Zealand. It will allow officers to require information about people who are not fulfilling their immigration responsibilities or who have obtained their permit through fraud or misrepresentation. The approach would allow the Department of Labour to better maintain the integrity of the immigration system to the benefit of all New Zealanders.
Extending the current powers to require information to cover more organisations would improve access to relevant up-to-date information on the location of people unlawfully in New Zealand. This would increase the likelihood of rapid detection and reduce incentives for a person to remain in breach of their permit conditions. The ability to require information, where there is a reasonable suspicion that an immigration offence has been committed, would increase the ability of officers to conclude investigations efficiently and effectively.
This proposal would allow officers to locate more people who are the subject of an immigration misrepresentation or fraud investigation. This approach would see more cases successfully proceeding through the existing investigation processes.
This approach would help ensure the person being investigated could be located and given the opportunity to respond to potentially prejudicial information. It would allow officers to conduct investigations and make decisions effectively and efficiently, and it would support the principles of a fair immigration system.
Widening the power to require information may increase the number of organisations incurring compliance costs. The cost incurred is likely to be very small, for example, the cost of staff time to answer a phone call and query a computer database.
Requiring some government agencies to provide address or compliance information on request would address concerns held by some agencies around their ability to release information under the Privacy Act. Careful consideration about the agencies included would be necessary. There is a risk that the requirement to provide information may prevent effective service delivery in some government agencies.
Health and education agencies and the Department of Internal Affairs' Birth Registry information are not currently being considered. The integrity of the birth register may be at risk if the Department of Internal Affairs was required to provide information from the register. People unlawfully in New Zealand may fail to register the birth of their children if they think the information will be used to find them. This may have a significant adverse consequence for the child and it is not the intention of the government. Similarly, access to education and health records may have undesired consequences (such as denying children access to education and healthcare).
According to Department of Labour records, Ms A has overstayed her permit. Ms A no longer lives at the address held by the department. The department requests her address from Telecom and a number of power companies, but they have no record of her. Under the status quo, the investigation would stop because the immigration officer has no further power to request address information. Under the proposal, the immigration officer requests her address from three additional organisations. The third additional organisation is able to provide her current address and Ms A is located.
An officer is investigating a refugee who officers have a reasonable suspicion may have used fraud to obtain refugee status. Under the status quo, the officer may not require address information from any organisation. Under the proposal, they could require address information from a range of organisations that may have this person's current address. This would allow the officer to locate the person and present them with the case.
Alternative options to this approach would be to:
The potential increase in information that may come from information matching is likely to be unmanageable. For example, an information matching scheme may bring up 5,000 names in one hit. The scale of the intrusion into the privacy of those people is unlikely to be warranted if the department cannot actually use the information. The Department of Labour would prefer to continue to collect information in relation to an individual who is actually being investigated.
The need for a power to require information from all organisations or agencies has been dismissed. Some government agencies have this power (for example, under the Social Security 1964 and the Tax Administration Act 1994). The Department of Labour does not believe it requires the ability to access information from all organisations or agencies to efficiently and effectively conduct investigations in relation to unlawful employment or non-compliance with permit conditions.
10.1.1 Key questions
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This subsection considers the possibility of creating a power to allow immigration and Customs officers to detain a person while they wait for Police to arrive. Further provisions on detention are discussed in Section 12:Detention.
Immigration officers may currently require that a person be detained or arrested by Police on their behalf for a number of immigration reasons. For example, a person may be detained while their removal from New Zealand is being arranged. A person could also be detained if they were refused entry to New Zealand at the airport and were waiting to depart.
Immigration officers do not themselves have the power to detain people or to make arrests for immigration reasons. Rather, under the Immigration Act, the New Zealand Police (Police) undertake these duties on behalf of immigration officers. Police regularly undertake detention and arrest where people are in New Zealand unlawfully and have been served with a removal order.
The New Zealand Customs Service (Customs) also regularly exercises its own authority to detain persons for Customs purposes at the airport. However, Customs does not have authority to detain persons for immigration purposes.
The use of Police to detain or to make an arrest for immigration purposes is desirable where feasible. Police have clear, well-exercised and proven powers of arrest. Police have the training and technical and logistical support for their powers.
Decisions to detain are made after careful consideration of the circumstances and an evaluation of the risk that the person may abscond.
Police are seldom present at the exact time a decision is made by an immigration officer to detain a person. Under the Immigration Act, an immigration or Customs officer has no power to detain the person until Police arrive.
There may be a period of time during which the immigration officer cannot prevent the person from leaving. At an international airport, this period of time may be short.
There may also be longer periods of time, for example, at a port, where it takes time for Police to come and assist immigration officers. The length of time may mean that the person who may be detained has time to leave.
It is impractical and unrealistic to expect Police to be immediately present for all immigration officer decisions, in all locations throughout New Zealand. A reasonable period of delay between making the determination that detention is required and the arrival of Police to undertake detention or make an arrest would vary from minutes in the airport environment to, potentially, hours in more remote locations.
Both the United States and Canada respectively have a single agency charged with immigration and Customs border duties. Officers of these agencies have the power of arrest and detention.
Australian immigration officers, Customs officers and Police officers have powers to immediately detain a person who is present in Australia unlawfully. An important difference to note between Australia and New Zealand is that Australia has a mandatory detention regime for all people unlawfully in the country.
In the UK, immigration officers have the power to arrest a person who is liable for detention or removal from the UK for a variety of reasons. For example, immigration officers can arrest a person who is, or is reasonably suspected to be, an illegal entrant. A warrant is not required for these arrests.
Two options are presented here. Option A would maintain the status quo. Option B would provide certain delegated immigration and Customs officers with a limited power to detain a person pending the arrival of Police, and is preferred.
The current provisions where only Police have powers to detain people for immigration purposes would be retained.
Maintaining the status quo would ensure that detention is managed by those with current proven expertise, facilities and support. However, where Police are unable to respond immediately, people would be free to leave the area in order to avoid detention or arrest. This situation undermines the integrity of the immigration system. It reduces the effectiveness of the government's ability to make decisions about who may enter and stay in New Zealand.
The legislation would enable certain delegated immigration officers and Customs officers, having determined the need for an individual to be detained for immigration purposes, to detain a person until a Police officer can arrive. The purpose of this power of detention would only be to prevent the person leaving the area prior to the arrival of Police.
The power of detention would be limited. The conditions in place would include that:
Procedural guidelines would establish the situations where a delegated officer could use their power to detain. Limiting the use of this power to exceptional circumstances, where Police were not immediately available to assist, would recognise the benefits of the status quo (where detention is done by people with proven expertise and support) and build on them.
Training would ensure the rights of the person to be detained were protected and that the health and safety of the person and the officer were of primary importance. The Immigration Act could provide for delegated officers to use reasonable force only if it was safe and necessary to do so.
The power of detention would only be used for the purpose of preventing the person from leaving the area. The power would not be used for the purpose of building or completing an immigration investigation, or for questioning the person who would be subject to the detention.
This power of detention would align with similar powers accorded to other government officials. For example, it would be similar to Corrections officers' powers of detention under the Corrections Act 2004.
An immigration officer has been given information that Mr B is flying from Auckland to Christchurch this afternoon. Mr B has lived in New Zealand unlawfully on a number of occasions in the past and under different identities. This person has evaded removal for a long time.
The immigration officer arranges for Police to come to Auckland airport at the appropriate time so that Mr B may be detained. Mr B does not arrive, however, and Police have to leave. As the immigration officer is leaving, he meets Mr B.
Under the status quo, the immigration officer has to contact airport Police to ask them to detain Mr B. It is a busy time at the airport and, by the time Police arrive, Mr B has left the airport. Under Option B, the immigration officer could hold Mr B until Police arrive.
Immigration officers have located an overstayer in a rural area who has lived in New Zealand unlawfully on a number of occasions in the past and under different identities. This person has evaded removal for a long time.
Under the status quo, the immigration officers have to wait for Police to arrive and risk the individual taking flight. Under Option B, the immigration officers are able to take the person to the nearest Police station.
This option would ensure that a person who has been determined to require detention would not leave the area if Police were not immediately available. Guidance and training on how to manage people who are being detained and on the protection of their rights would be undertaken by immigration and Customs officers delegated with the power to detain people.
Customs already operates a temporary detention power under the Customs and Excise Act 1996 and has existing procedures and training around this type of provision which could be adapted.
This option would enable the Department of Labour to regulate more effectively the removal of people from New Zealand in New Zealand's interests. It would contribute to the principle of efficient processes and effective decision-making.
10.1.2 Key question
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This subsection considers extending to immigration officers the powers of entry and search that are currently given to Police and Customs officers undertaking immigration duties.
The Immigration Act confers powers of entry and search on Police and Customs officers undertaking immigration duties. No such powers are granted to immigration officers.
The Immigration Act gives Police powers to enter any building or premises for the purpose of serving or executing a removal or deportation order, or to serve notice of a change in expiry date for a limited purpose permit.
Under the Immigration Act, Police and Customs can enter and search any aircraft, ship or other form of sea-borne vessel for the purpose of detecting an immigration offence.
Police and Customs officers have the expertise to enter and search premises to undertake immigration duties. When they are available, the current system is desirable.
While both Police and immigration officers are granted the power to serve removal or deportation orders, only Police officers may enter a premises to do so. This limits the effectiveness of immigration officers carrying out legitimate immigration duties.
Department of Labour and Police resources are not being used effectively or efficiently in this situation. There may be a considerable period where the immigration officer is waiting for Police to arrive to enter premises. Police may also have other priorities which prevent them from arriving quickly.
Police and Customs officers currently have powers to search aircraft or ships for stowaways, or to detect or prevent an immigration offence. Immigration officers do not have these powers.
Search for stowaways and ship-jumpers, and for the documentation they may carry in their cabins and luggage, must occur swiftly if it is to be effective. It does not take long for people to destroy documentation or to leave a ship or sea port.
Police and Customs resources are increasingly being stretched by competing demands for officers' time. Officers of both agencies have their own functions to fulfil and cannot always give priority to immigration duties.
The time between an immigration officer requiring the search or entry of an aircraft or ship and the arrival of Police or Customs means that the immigration system and the immigration officers are not always working efficiently and effectively.
In the United States, an appropriately trained and designated immigration officer can enter and search an aircraft, ship or other carrier without a search warrant. They can also search private land up to 40 km from the border.
The UK allows immigration officers to enter and search premises under warrant for the purpose of locating either a person illegally present in the UK or a person who may be harbouring such a person.
Australian immigration law empowers the Secretary of the Department of Immigration and Multicultural Affairs to grant search warrants that allow immigration officers to enter and search aircraft, ships or other carriers along with private land and property. They have the power to use reasonable force as necessary to conduct the entry and search.
Canadian immigration law allows immigration officers to obtain a warrant to search and enter a place for immigration investigations. The safety of the immigration officer and other parties is considered in all entry and search operations and clear operational policy and guidelines support entry and search powers.
Two options are presented here. Option A would maintain the status quo. Option B would provide immigration officers with the same powers of entry and search that Police and Customs officers have for immigration purposes. It is the preferred option.
The presence of Police (or, in certain situations, Customs) would continue to be required at all immigration operations requiring entry and search.
Maintaining the status quo would recognise the expertise of Police and Customs in undertaking lawful entry and search of premises. At times, immigration operations will continue to be given low priority by Police. This means that, in many circumstances, the ability of immigration officers to issue removal orders would be hindered and inefficient. In some circumstances, immigration officers may not be able to carry out their duties successfully.
The status quo would continue to compromise the Department of Labour's ability to maintain the integrity of the immigration system. It would continue to hinder effective decision-making and prevent efficient process being built into the immigration system.
The legislation would allow immigration officers to exercise the powers of entry and search currently available to Police and Customs in carrying out specific immigration duties. This power could only be used to:
In the first circumstance, an immigration officer would need to have a reasonable belief that the person who is the subject of a removal order was at a particular place. This 'reasonable belief' would bear the same burden of proof that is currently required for Police to attend a place to enter and search. Immigration officers would not be able to enter and search a place without good reason. The entry and search would only be carried out by immigration officers where it was considered appropriate and safe to do so.
In the second circumstance, the immigration officer would need to have a reasonable belief that an immigration offence had been or was about to be committed, before entering and searching an aircraft or ship. They would only enter and conduct a search when Police and/or Customs officials were unavailable to respond quickly and the suspected offence required a rapid response from New Zealand authorities.
In both cases, clear operational guidelines and training on the use of the entry and search power would be established. Guidelines and training would ensure that the power was used appropriately and effectively by immigration officers.
Option B builds on the status quo that recognises the expertise of Police and Customs in undertaking lawful entry and search of premises. In addition to the limited new powers for immigration officers, Police and Customs would retain their existing powers.
This power would not be used routinely. For example, where an immigration officer was intending to serve a removal order and knew the person was likely to be at a particular address, they would arrange for Police to attend.
This power could be used where an immigration officer is presented with an unexpected opportunity to uphold compliance with New Zealand's immigration laws. For example, immigration officers at a sea port are informed that a number of ship passengers are about to destroy their documentation and falsely claim asylum in New Zealand.
Police and Customs officers are unavailable to enter and search the ship. Under the status quo, the documents would be destroyed. Under Option B, the immigration officers may be able to enter the ship and prevent the documents from being destroyed.
If immigration officers were able to use the entry and search powers that Police and Customs have in the current Immigration Act, they would have greater ability to uphold the integrity of the immigration system. Their decision-making powers would be effectively supported, and more efficient processes could be developed.
Not having to rely on Police availability could result in an increase in the number of entry and search operations undertaken by immigration officers. This may see a corresponding increase in the level of effective action taken against those who are in breach of their permit conditions. The entry and search power could be used in situations where a delay may mean that an offence is committed or remains undetected. This option would support an immigration system that works for New Zealand's interests and contributes to efficient processes and effective decision-making.
In addition, this option would provide consistency in the legislation on who may undertake immigration functions. Entry, search and detention powers are already available to both Police and Customs officers undertaking immigration duties. The approach outlined above would allow immigration officers to undertake all the compliance work until Police could become involved.
10.1.3 Key question
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This subsection considers what powers are required to deal with the immigration status of a person who is in New Zealand. The general requirement that a person must be lawfully present in New Zealand to apply for a permit ensures that New Zealand is able to regulate entry and stay. However, discretionary ability to waive this requirement is also useful. It ensures that New Zealand can allow a person to stay where this is in New Zealand's interests.
A person must be lawfully present in the country to be able to apply for a permit. The current Immigration Act provides the Minister of Immigration (and delegated immigration officers) with the discretion to grant a permit of any type to a person here unlawfully. Individuals have no right to apply for such a permit, and the Minister of Immigration and immigration officers are not required to consider a request or to give reasons for a refusal.
This discretion is not bound by policy. Whether a person meets current policy is relevant, but not a deciding factor. The individual merits of any case are considered against the public interest.
This provision provides a positive incentive for well-settled people who are in New Zealand unlawfully to seek lawful status. It allows for discretionary decisions to ensure immigration outcomes that meet New Zealand's needs. It works in the bests interests of New Zealanders and migrants.
This discretionary power enables people who may have genuinely forgotten to renew their permit before it expired to regain lawful status. For example, in 2004/05, this power was used to issue over 16,000 permits. These included:
The core ability for the Minister of Immigration and delegated immigration officials to grant permits to people in New Zealand unlawfully allows people to remain in New Zealand, where this is in New Zealand's interests, and there are no proposals to change it.
Some people have a valid permit when they lodge an application for a further permit, but the permit expires while their application is being considered. This situation presents a number of difficulties including:
Australia has a range of 'bridging visas' available, depending on how a person becomes unlawful. Examples include the following:
An automatic visa for people who arrived lawfully and apply for a subsequent visa. If their visa expires while their application is being decided, they are automatically issued a bridging visa. Travel and work rights are available.
A visa for people who self-identify their unlawful status (generally within 28 days of becoming unlawful), provided that they originally arrived lawfully. They have no entitlement to travel and it is difficult to get work rights.
Canada can grant a temporary resident permit where 'justified in the circumstances'. Examples include where people who have inadvertently become unlawful have a good student record. Temporary residence permits have specific conditions attached and can be cancelled at any time.
Two options are presented here. Option A would maintain the discretionary ability to grant a permit to a person unlawfully in New Zealand, which is regarded as a minimum requirement to meet the objectives of the review. Option B also retains this core discretion to grant a permit to a person unlawfully in New Zealand. In addition, it would allow automatic permit extensions, in cases where a permit expires while an application for a further permit is being considered. Option B further contributes to the objectives of this review and is preferred.
The Minister of Immigration and delegated immigration officers would continue to be able to grant permits to any person unlawfully in New Zealand on a case-by-case basis. People whose permit expires while their application for a further permit is being considered would be granted a permit (or not) under normal provisions.
The status quo provides flexibility to deal with unlawful status. The discretionary ability to grant a permit to a person unlawfully in New Zealand is useful. There will always be instances where the unexpected occurs, and it is impossible to cover all scenarios through policy. It is also 'future proofed', in that it can be used to accommodate government objectives at any given time. This provision is not policy bound and does not create rights for those who may potentially benefit from it. This has the benefit of limiting the risk of judicial action against the Department of Labour.
Option B retains the discretionary power for the Minister of Immigration and delegated officials to grant a permit to a person in New Zealand unlawfully.
In addition, Option B allows permits to be extended where a person lawfully in New Zealand lodges an application for a further permit. The original permit would only be extended until the date the new application is decided. At that point, if the application is declined, the person would become unlawfully present in the country. The power to extend a permit would be discretionary to ensure that immigration officers could refuse any frivolous or delaying applications.
This option would contribute to the principle of fairness in the immigration system as well as ensuring efficient processes for dealing with this situation. Permit extensions would prevent a person from being unlawfully in New Zealand while a new application is processed. It would not predetermine the outcome of their new application. This would be similar to Australia's approach.
This option would retain all the benefits of the status quo. It would also introduce a new measure to help create an immigration system that is more effective and efficient. It would better facilitate the stay in New Zealand of tourists, workers and students who can contribute to growing New Zealand's economy and building strong communities.
This option would eliminate the problems outlined in paragraph 713 for those people who become unlawful while their application for a new permit is considered. In many cases, this issue is caused by delays in processing applications for which the applicant should not be unfairly penalised.
The risks of this option include reduced incentives to apply for further temporary permits in a timely manner, the lodging of frivolous applications to extend a person's stay and the granting of extensions to people who may no longer meet policy criteria such as character requirements. These risks could be mitigated by:
10.2 Key questions
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