George Duncan•10 months ago After reading the document, it is clear that very little has been done to modernize the content of this document.It is written as though it will go to the printing press rather than being online based. There are broken links contained within the policy and reference to the government website often does not coincide with relevant details such as permit types. On the government website, there is one page with nearly all of the applications that exist but within the policy, there are no links to simplify the application process.This particular point solidifies the lack of effort taken to modernize processes and service times.The policy has information that is VERY wordy and difficult to follow and many similar sections are spaced all over the policy itself. For example, anything to do with money, payments, refunds should be all together.Instead of trying to dazzle the reader with fancy words, it has been proven that layout of the same information in tables is more effective at conveying a message.Some solutions:Write the document in chronological order.Write it with less words and more links to the actual content.Make the government website coincide with the policy. Right now the government website is out of whack and this confuses the public.The document needs to be translated into a couple languages.List all work permits instead of instructing readers to use the search bar. The way that the government website is set up results in irrelvant search results when the google function produces results. I have tried it again today and it still provides irrelevant and in some cases old information. If the reader of the document does not type and exact/narrow term, a broad result ensues.Typing 'work permit' in the search bar vs. 'work permits' produces a contrasting result causing the reader to navigate an already complex website.This implies that the document cannot be amended in the electronic sense which is counterproductive.The content of the document does not allow for the reader to have access to a simplified version and it is not written with the end user in mind. It is written with very little static support. In other words, it is heavily reliant on paper documents and physical staff to repeatedly answer FAQs.A little research was done via persons familiar with immigration policy versus what actually happens in day to day procedures and the result was that the policy is not accurate and ministerial decisions are not conveyed to the public when ad hoc changes are made unless, on an individual basis, applicants are informed of changes, or, the public complains enough and immigration or the minister listens.A robust, but digitized version of the policy would lessen the occurrences of this.If you have read this far, bravo!Back to the chronological order theme:The first section of the document talks about appeals. It then goes to penalties and compliance.Appeals should appear after you get through applications, guidance for applications, fees, decisions.There is very little reference to what penalties actually exist other than for working without a permit which is briefly mentioned but poorly conveyed. There have been a few high profile cases of educators at multiple institutions in local media who have provided false documents in the Royal Gazette. What is the penalty for that when there were qualified Bermudians who were overlooked. These arw thw typea of ploicy content that needs to be included instaef of the word salad contained in the current draft document. Proper links to actual legislation is another topic for correction. The immigration laws are all electronic. Place links to matters related to compliance with the legislation instead of direction the reader to first find the legislation themselves. A link would suffice.This is the same for the obscure applications like spousal rights for divorcees and landing permits. Place links to the applications within the policy itself and update it accordingly when changes are made.Same for complaints - the link in the document is broken!To keep this short, the document needs to be written over, rearranged and more onus placed on the applicants both employers and employees to follow a set standard and not unwritten rules. The only way to achieve this is to establish a robust set of policies that is well documented, well advertised, with the public being routinely reminded with short but effective social media blurbs that were evident during covid and expertly rolled out by the health department as an example.This submission is quite the antithesis to its own suggestions but the policy being rolled out in July has all the signs of not leaving room for revisions and leaning towards this consultation being a performative exercise to placate the public.Industry partners who do not have the benefit of the concierge service at cabinet office will likely be at the receiving end of no improvement tothe processes contained within policy version 2025.