That’s a page from the Campus Conservatives’ internship program FAQ.That’s what jumps out first. The $100 fee. Here it is zoomed in:
The reason I’m looking at that page is that I’m attending a roundtable discussion on internships in Ottawa this week. It’s my field of expertise, my company manages 30 internship programs for private schools and colleges across Canada and the US; and I’ve been involved in private regulation of internships in Canada.
Right off the top, from what I understand, political parties operate free of federal and provincial employment standards – so I’m not trying to imply they’re doing something illegal. I’m saying that if anyone else did it, they would get in trouble from the future bureaucrats this Tory internship program is spitting out.
First off the fee. Almost every school that operates a coop program charges a coop fee (ex 1, 2, 3, 4 ) . Those fees pay for things like monitoring, student support, regulatory compliance, and quality control. After paying those fees, and completing assignments, the universities who were paid the fees give the student academic credit that gets them closer to graduation. That’s not the case with the Tories’ fee though. They say it’s to cover their internal administrative costs.
Nowhere in Canada that I know of, can an employer charge an employee an administrative fee for hiring them. If an intern couldn’t pay that fee – would they be allowed to do their internship? It appears not.
But it’s an internship, so it’s largely exempt from labour/employment standards, right?
Well if it’s paid minimum wage, then it’s not an unpaid internship, and the ESAs/LSAs apply. So, is this paid minimum wage?
It doesn’t say ‘yes’, the website just gives a number – $1700 per month. Is that enough for minimum wage? Depends where and how much you work.
The website says the internship program is in Ottawa. And here is how they describe the work load:
So we start with a baseline of 40 hours per week. Plus weekend seminars and intensive political training, and a group project. These seminars are mandatory – don’t go and you could be fired:
So let’s be small-c conservative and say these seminars add only an extra 3 hours per week to the workload. That gives us a work week of 43 hours – based on the principle that mandatory training is typically paid. Again, these internships are in Ottawa where the minimum wage is $11 per hour. Over 4 weeks, with no overtime pay of course, that gives us $1892.
Interns are paid $1700 so that means that it’s less than minimum wage. In which case, my bad, maybe the $100 fee to participate is OK.
Being less than minimum wage though, that makes this an unpaid internship with an honorarium. And Ontario takes a dim view of honorariums. My staff have spent time talking to Ontario employment standards people, and back in July, 2013 they told us that if the student is not doing the internship as a requirement of their studies, it’s very tricky to offer an honorarium. Specifically what they said was: “if you advertise an honorarium, then the letter of the law states that that person would be informed of remuneration and would thus be considered an employee. Thus, they would be entitled to minimum wage”. If you want to offer one, you can do so after the intern starts, but you can’t do it as an inducement to get them to join the internship program, it can’t be offered up front.
If I were a private company offering this honorarium to recent graduates in Ontario, I’d be on the receiving end of some tsk-tsk’ing in the Star, and possibly a fine. Not so for the Tories.
Now for the last point, and possibly the most important. Internships should be for students only. Looking at the screenshots above, you’ll notice that to join this program you in fact do need to be a student:
However, you’ll also notice there’s no requirement that says you have to be a student who is doing this internship for academic credit. In some places, that’s a problem.
In BC or Alberta for example, that would get you in trouble with employment standards. To be exempt from minimum wage in BC, the internship (there, called a Practicum):
[must be] required by the curriculum, and will result in a certificate or diploma. It is not considered to be “work” for the purposes of the Act.
It’s not a big hurdle – there are a lot of internship and coop students in this country. But even that small restriction is too much for the Tories – that bare minimum student requirement for them is flexible:
Now it occurs to me that if you’re graduating in April, then in May you’re not a student. However that doesn’t bother the Tories as much. In BC, or Alberta, or Quebec – if you were a private company and tried that, it wouldn’t work out as well for you.
You know if it were anyone else, other than a political party, offering this internship in Ontario they’d have to worry about getting in trouble. If they were in BC, Alberta or Quebec, they’d know they’d get in trouble. But like I said above, political parties don’t have to follow the rules, they just have to enforce them on others.
One last, last thing. Because it’s from the Campus Conservatives, you might think this internship program is under the radar of MP’s and the Party itself. As you can, that is not the case: