application of international human rights standards found in the core human rights treaties, such as equality before the law, non-discrimination and an adequate standard of living. 34. It is unclear how many stateless persons are detained in Canada during an asylum determination procedure or pending removal. Detention of migrants is within the federal responsibility of the Canada Border Services Agency (CBSA). CBSA has the mandate to detain persons in provincial detention centres. CBSA does not define statelessness but does collect and record data on ‘unknown nationality’ and ‘statelessness’ separately.47 In 2015, CBSA reported that the total number of days in detention that stateless persons spent from 2003 – 2014 was 43,214.48 The total number of stateless detainees from 2003 – 2014 was 530.49 Based on the total number of detainees and total number of detention days for the period of 2003-2014, the average length of detention for a stateless individual was 81 days.50 As CBSA does not use a specific definition of statelessness, or have in place a statelessness determination procedure, contextualising these figures is challenging. 35. CBSA provided details on 189 records of removal orders issued from 2003 – 2014. There were 62 stateless individuals who were not detained at the time of removal, and 127 who were detained. There were 18 detained stateless individuals who were considered ‘contrary to the national interest’, and 171 detained stateless individuals who were not considered ‘contrary to the national interest’.51 CBSA does not record the legal status or detention of removed stateless persons in the countries to which they have been removed.52 36. Furthermore, as there does not exist a “stateless person status” in Canada, those who have applied for legal residence in Canada through a Humanitarian and Compassionate application , and who have been denied this status, consequently face the risk of indefinite detention while a removal order is being processed against them. Finally, the risk of repeated detention also remains. For example, when stateless persons or persons at risk of statelessness are released without legal residence status, they face the threat of being detained anew as an irregular migrant. 37. In general the Immigration and Refugee Protection Act (IRPA) authorizes the CBSA to detain foreign nationals and permanent residents where there are ‘reasonable grounds to believe’ that the individual in question is inadmissible to Canada, a danger to the public, or if s/he may be unlikely to appear for immigration processes (they are a flight risk).53 Detention of foreign nationals also arises where the identity of the foreign national is in question or for examination purposes.54 The IRPA also authorises the automatic detention of persons who are deemed ‘Designated Foreign Nationals’ and are subject to a security certificate.55 Stateless persons therefore may be subject to detention not only at the outset of 47 Canadian Centre on Statelessness. “Data Collection on Stateless Persons in Canada”. 2017, page 13. http://www.statelessness.ca/uploads/3/1/9/0/31903945/ccs_data_collection_2017.pdf. 48 CCS received two different sets of data from CBSA with different figures for the same period: 43,214 and 42,916 detention days for 2003-2014. Canadian Centre on Statelessness. “Data Collection on Stateless Persons in Canada”. 2017, page 14. http://www.statelessness.ca/uploads/3/1/9/0/31903945/ccs_data_collection_2017.pdf. 49 Ibid. 50 Ibid. Based on 43,214 figure. 51 Canadian Centre on Statelessness. “Data Collection on Stateless Persons in Canada”. 2017, page 16. http://www.statelessness.ca/uploads/3/1/9/0/31903945/ccs_data_collection_2017.pdf. 52 Canadian Centre on Statelessness. “Data Collection on Stateless Persons in Canada”. 2017, page 17. .http://www.statelessness.ca/uploads/3/1/9/0/31903945/ccs_data_collection_2017.pdf. 53 Section 55. Immigration and Refugee Protection Act, SC 2001, c 27. 54 Ibid, Section 55(2). 55 Ibid, Section 57.1. Designated Foreign Nationals are defined under s 20.1 of the IRPA. A person is designated as such by the Minister of Citizenship and Immigration due to their mode of arrival and is subject to immediate detention and different detention review rules. Persons subject to a security certificate are governed by Section 77(1) of the IRPA and are also subject to different review requirements as to their detention and monitoring by the CBSA. 8