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Home > Resources > Publications > Publications by subject > Discrimination Prevention > A Place for All > PART 3: Procedures Guide
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Proactive Disclosure
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This part of the Guide is intended to help employers set up procedures for analyzing corporate programs and activities. The objective of such an analysis is to find out if a program or activity will give rise to discriminatory barriers and then remove or nullify those barriers.
To do the analysis, an employer needs a tool or strategy (another word is "lens"). A tool could be a series of questions to determine the effect of a policy or activity. A tool could also be a specific checklist, such as a list of technical specifications for designing a page that is accessible to a visually impaired person.
A number of tools or lenses are already available. Others are being developed. (For details on where to obtain these tools, see Appendix C — List of Useful Resources.)
The following are the four essential elements of a procedure for doing the analysis.
1. Identifying tools for analysis of corporate programs and activities2. Responsibility for analysis3. Communication and consultation4. Reporting
| 1. Identifying tools for analysis of corporate programs and activities |
| Question: | Do the procedures identify who is responsible for maintaining an up-to-date database on existing analytical tools or “lenses” to analyse corporate programs and activities? |
| Comment: | It is recommended that one person have overall general responsibility for ensuring the employer has access to all relevant tools. |
| Sample: | The [Manager of Human Resources or Other Designated Employer Representative] is responsible for ensuring that [Everyone’s Workplace Inc.] has access to all current analytical tools or lenses. |
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| 2. Responsibility for analysis |
| Question: | Do the procedures identify who is responsible and accountable for analyzing specific corporate activities? |
| Comment: | Responsibility for approving new policies, practices, procurements and operations will vary within an organization. It is important for employers to identify who has responsibility for final decision-making in order to establish a clear line of accountability. |
| Sample: | The person responsible for developing any proposal which results in corporate activity is responsible for ensuring appropriate lenses are applied. The [Manager of Human Resources or Designated Employer Representative] is responsible for ensuring that all proposed corporate activities have been analysed to identify possible discriminatory barriers, and that all problems identified in that analysis have been addressed prior to the action being finalised, unless doing so would result in an undue hardship. |
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| 3. Communication and consultation |
| Question: | Do the procedures allow for consultation with employees and unions in appropriate situations? |
| Comment: | While not every corporate program or activity needs to be subject to extensive consultation, there will on occasion be activities that have broad consequences, such as the purchase of a new computer software system or a decision to move from one building to another. Employees and their representatives should have an opportunity to study the potential consequences of these activities. |
| Sample: | Where appropriate, the responsible person will ensure, through the Employment Equity Committee or an appropriate labour management consultation forum, that staff and bargaining agents are advised of the proposed action and provided with sufficient information and an opportunity to make comments about any employment equity concerns. |
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| 4. Reporting |
| Question: | Do the procedures include a mechanism for checking that an analysis of corporate activities has been undertaken before action is taken, and recording details of the analysis and outcome? |
| Comment: | While operational activities may be the sole responsibility of operational managers, their decisions may have implications for the human resource side of the organization, which will have to deal with any requests for accommodation or any complaints of discrimination from employees. It is appropriate, therefore, for human resource personnel to monitor all corporate activities that may give rise to discriminatory barriers. |
| Sample: | A report describing action taken to ensure corporate activities do not create discriminatory barriers will be forwarded to the [Manager of Human Resources] before implementation. The report will particularly note any discriminatory barriers identified but not addressed. The [Head of Organization] will be responsible for final decisions about whether or not to proceed with a proposal if discriminatory barriers have been identified as likely to arise, and no modification to remove this potential has been proposed. The [Manager of Human Resources] is responsible for preparing an annual summary of activities in this area to be provided to the [Head of Organization], who will, in turn, provide this information as required in external reports. |