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Outgoing Letters and Public Statements

December 16, 2016

The Hon. Ralph Goodale
Minister of Public Safety and Emergency Preparedness
269 Laurier Avenue West
Ottawa, Ontario K1A 0P8

Dear Minister Goodale,

We are writing with respect to the Consultation on the Review of Record Suspensions.

Earlier this month, Prime Minister Justin Trudeau recommitted to finding solutions that prevent future acts of violence against women and girls, investing in education and prevention efforts, and helping those who have been targeted by gender-based violence.

The Evangelical Fellowship of Canada (EFC) is the national association of evangelical Christians in Canada. The EFC has long expressed concern for those who are prostituted based on biblical principles that compel care for the vulnerable and inform the duty of care we owe one another as human beings. One of the EFC’s goals is the elimination of all forms of sexual exploitation.

The vast majority of those who are prostituted enter by force, coercion, or as a result of constrained choice and last resort. Both research and anecdotal evidence tell us that between 88-96% of women in prostitution are not there by choice, and say they would get out if they felt they had a viable alternative.*

Prostitution is inherently dangerous, and a form of systemic exploitation of our society’s most vulnerable women, children and men. Issues such as poverty, addiction, mental illness and racialization are key contributing factors to individuals entering prostitution or being vulnerable to exploitation.

As such, prostituted persons tend to be limited in their ability to exit prostitution and find alternative means of making a living, creating a revolving door of abuse, marginalization and neglect for a vulnerable population.

Criminalization of those who are prostituted creates significant barriers to their exit from prostitution. We know, for example, that prostitution-related offences on a criminal record often act as a barrier for women to gaining housing or securing employment.

The Protection of Communities and Exploited Persons Act (PCEPA) represented a paradigm shift in law and policy related to prostitution. It recognizes that the vast majority of individuals in prostitution are not there by way of free and fully informed choice, and that most of those who are prostituted are vulnerable and have been victimized.

This was a shift that the EFC had advocated for, and believes is critical to achieving real success in successfully reducing – and ultimately eliminating – sexual exploitation.

The framing of the legislation made it clear that in the spirit and intent of the law, individuals who are prostituted are to be seen as vulnerable, as victims of exploitation, and are therefore afforded immunity from criminal prosecution, except under certain specific circumstances. This is a positive shift in law that leads to a far more just situation for exploited persons. However, the shift is not retroactive, and does not help those whose prostitution-related charges were incurred prior to the adoption of the Protection of Communities and Exploited Persons Act.

Therefore, as you review the issue of record suspensions, we encourage you to allow prostitution-related charges to be expunged from the criminal records of prostituted persons. Many states in the U.S. allow convictions related to sex trafficking to be removed from the records of former prostitutes.

We note also that the current user fee to apply for a record suspension is likely to be prohibitively expensive for prostituted persons who are trying to exit exploitive situations. We ask you to consider whether the new start of a clear criminal record for prostituted women is an investment in helping those who have been subject to violence and exploitation.


Julia Beazley, Director, Public Policy
The Evangelical Fellowship of Canada

* In a study of 854 people in prostitution from nine countries, 89% said they wanted to escape prostitution. See Melissa Farley, et al., “Prostitution and Trafficking in Nine Countries: An Update on Violence and Posttraumatic Stress Disorder,” Journal of Trauma Practice 2, no. 3/4 (Philadelphia: Haworth Press, 2003), 56, Similarly, in a study of 100 prostituted women in Vancouver, 95% said they wanted to leave prostitution. See Melissa Farley, et al., “Prostitution in Vancouver: Violence and the Colonization of First Nations Women,” Transcultural Psychiatry 42, no. 2 (June 2005), 242,

Outgoing Letters


EFC President Bruce J. Clemenger writes regular commentaries about public policy issues. The EFC magazine Faith Today often publishes articles and essays that examine such issues.

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