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February 28, 2017

Most of us are familiar with Internal Administrative Circulars or “IACs”

As INZ’s knowledge base advises:

Internal Administration Circulars (IACs) are guidance given to staff around processing visa applications and administrative processes in offices. IACs do not have any legislative authority and are not a substitute for instructions.

However, some IACs are issued in accordance with the Act. For example, IAC 14/04 Prioritisation of the 2014/2016 Residence Programme and General Instructions is issued in accordance with section 26(4) of the Immigration Act 2009 which enables the chief executive to give instructions on the order and manner of processing any application or claim. Guidance such as this IAC must be signed off by the DCE – Immigration

There are also Visapack / Knowledge Base items to staff which are kept on the website. These tend to “one issue” or more specific to particular processes than AICs.

In fact IACs , until they all but petered out in 2015 were used for a wide range of issues including:

  • What INZ should do when applications come in from unlicensed advisers.
  • Alerts and obligations on staff who encountered them.
  • When refunds will be made.
  • How to deal with urgent disclosure requests.
  • Offshore versus on shore PPI obligations.
  • The Complaints process.
  • How and when AMS notes should be made.
  • Many practical aspects of visa processing.
  • And a host of other issues.

We have found IACs pre 2010 which are still in force. For clients with past concerns about processing which lead to character or other issues going onto their file old IACs can still be relevant.

Naturally we were concerned last week when we found but 3 IACs from 2015 missing from the website. Also missing was the link to the long delayed CCRP review which still awaits implementation from 2015. We asked if the de-linking of the detailed complaints guidence meant that the CCRP process had changed.

We raised this with the Manager: Immigration Resolutions Margaret Cantlon. We were encouraged at her detailed reply on 24 May which we reproduce in full for other advisers.

  • IACs – Publically available IACs dating back to 2004 are in the process of being uploaded to the new website. There are over 200 of them so this process will take a few days.
  • CCRP Review Report – a link to the report is now available on the new site.
  • CCRP detailed guidelines or principles of the process – we’ve rationalised the complaints material and these documents will not be added as links on the new site although the core content is still applicable. Note that the documents were somewhat out of date, e.g. with references to obsolete job titles. Copies in the attached email.
  • “The CCRP doesn’t review decisions about visa applications, unless there has been a clear process or service failure…” This isn’t new – indeed the old site had a section on ‘What if I’m unhappy with the decision’. So, it’s a reiteration that the CCRP is intended for service and process related complaints not as an avenue for having a decline decision reviewed. We are in the process of having a change made to make it clear that this also applies to s61 requests (it was clear on the old site).
  • Is the CCRP review still pending – INZ is progressing a business case to identify options and costs associated with implementing the review recommendations. Timing for roll out of the new system and supporting team is indicatively planned for early 2017. Please note that no timings can be finally confirmed until the Business Case is approved.

We are grateful for the prompt response. Watch for the IACs coming back onto the website in the near future.