CAEFS further recommends that the Commission propose that s. 82 similarly apply to the Deputy Commissioner for Women, as well as the regional/institutional heads, and that she have a duty to report on a regular basis and issue a written report annually to the Solicitor General and the Parliamentary Standing Committee on Justice and Human Rights.

Pursuant to the foregoing, CAEFS further urges the Commission to recommends that regional advisory committees, similar in composition to that proposed for the national body, be established for each of the new regional women's prisons, including the Okimaw Ohci Healing Lodge and the new prison for women in the Pacific Region that replaces the Burnaby Correctional Centre for Women.

CAEFS also urges the Commission to recommend that the wardens of the regional prisons for women be held accountable for institutional adherence to the provisions of the CCRA, and that rates of conditional release and availability of relevant institutional and community programming to achieve successful community integration, be included as key variables in the evaluative process.

c) Access to Justice Issues

Overall cuts to legal aid resources have only exacerbated the challenges for federally sentenced women who attempt to access resources in order to protect their human rights and/or address violations of human, Charter and CCRA protected rights and entitlements. Accordingly, CAEFS urges the Commission to recommend the establishment of federal government fund designed to promote the access of women in prison to legal aid services to address issues related to their conditions of imprisonment and conditional release.

Adequate legal aid coverage is required throughout the country and legal clinics should be established specifically for prisoners, preferably staffed by experienced lawyers, as opposed to reliance upon student-staffed clinics alone. CAEFS is of the view that a similar fund to the Court Challenges Fund needs to be established for prisoners, such that the Prisoner Challenge Program funds may be accessed by those who are in prison and who may otherwise not be able to avail themselves of legal representation and assistance in order to ensure that their rights and entitlements are realized.

Pursuant to the issues raised by Professor Patricia Monture-Angus in her research for CAEFS, the federal government’s breach of its fiduciary obligations to federally sentenced women, particularly Aboriginal women and women with disabilities, creates an obvious need for financial compensation. As such CAEFS encourages the CHRC to recommend a mechanism similar to the type established for victim compensation schemes be required in order to enable women prisoners and former prisoners to actually access compensation. Access to legal counsel and other advocacy assistance would also be imperative to a successful compensation strategy.

Submission of the Canadian Association of Elizabeth Fry Societies (CAEFS) to the Canadian Human Rights Commission for the Special Report on the Discrimination on the Basis of Sex, Race and Disability Faced by Federally Sentenced Women