Cover Letter
October 19, 2006
Mr. David Langtry
Commissioner
Canadian Human Rights Commission
Ottawa, Ontario K1A 1E1
Dear Mr. Langtry:
It is my pleasure to report to you on the status of our efforts to enhance the accessibility of government communications for people who are Deaf, deafened, hard-of-hearing, or have a speech impairment as per our commitment as outlined in the Memorandum of Understanding signed on February 24, 2006.
I am pleased to report that our collaboration was, and continues to be extremely fruitful. I would note, as illustration, that your Commission has advised the Canadian Hearing Society and others in the community that "the Commission is very pleased with the constructive and forward thinking approach adopted by TBS on behalf of the Government of Canada". This communicates the message that both organizations share the vision of a comprehensive approach that weaves accessibility into the fabric of Government. Within this context, meeting the needs of Canadians who are Deaf, deafened, hard-of-hearing, or have a speech impairment is a component in the overall strategy of meeting the needs of all Canadians regardless of disability. CHRC’s continuing support and encouragement, for example, to deploy accessibility services onto the "Personal Services on Demand" infrastructure being developed will also help to enhance cost effectiveness, robustness, flexibility and quality of interactions that Canadians with disabilities have with their government.
I look forward to continuing our collaboration as we move forward on this important agenda.
Yours sincerely,
Wayne G. Wouters
Secretary of the Treasury Board
Treasury Board of Canada
Encl.
Progress Report
Report to the Canadian Human Rights Commission (CHRC) in response to Commitments in the Memorandum of Understanding between the Treasury Board Secretariat and CHRC on the Accessibility of the Government Teletypewriter System
"Within six months of signing this Memorandum, the Secretary of the Treasury Board will write to the Chief Commissioner outlining the commitments, including time frames, for the implementation of a comprehensive strategy and other recommendations in the report" (MOU TBS – CHRC February 2006)
Since the signing of the Memorandum of Understanding (MOU) on February 24, 2006, the Treasury Board Secretariat (TBS) has honoured the commitments made in the MOU with the Canadian Human Rights Commission (CHRC) and continues to work to improve accessibility broadly, and specifically the provision of telecommunications services for people who are Deaf, deafened, hard-of-hearing or who have a speech impairment.
This report on commitments is organized in three sections:
The lessons learned in the provision of improved accessibility services to this community, such as captioning and sign language interpretation, along with strengthened management processes, such as monitoring the impacts of new technologies on persons with disabilities, will serve as a model for other groups, as benefits are broadened more widely.
Agreements in the Memorandum of Understanding
1) The TBS will include, as part of its comprehensive accessibility framework and strategy, a component that addresses the provision of telephonic communication services for people who are Deaf, deafened, hard-of-hearing or who have a speech impairment consistent with the recommendations and analysis contained in No Answer.
TBS is addressing the provision of telephonic communications services for people who are Deaf, deafened, hard-of-hearing or who have a speech impairment in part by explicitly updating its suite of "Personas" 2 to ensure that telephonic communications services are included and documented. This will help to inform the development of improved services and processes.
2) The Commission undertakes to consult with TBS, as required on the development of the strategy and other accessibility issues.
This is a CHRC commitment. Note that CHRC and TBS consult regularly on respective activities and strategies.
3) The Commission and TBS will convene a meeting with key organizations representing the interests of people who are Deaf, deafened or hard-of-hearing to brief them on steps being taken to implement the recommendations in No Answer and to seek their input.
TBS is currently in the process of organizing consultative workshops to solicit the views, input and feedback of individuals and organizations representing the interests of people who are Deaf, deafened, hard-of-hearing and who have a speech impairment.
4) Within six months of the signing of this Memorandum the Secretary of the Treasury Board will write to the Chief Commissioner outlining the commitments, including time frames, for the implementation of a comprehensive strategy and other recommendations in the report.
This report represents this commitment.
5) Recognizing that the issues identified in No Answer are illustrative of broader issues with regard to accessibility of Government of Canada program, services and employment to persons with a variety of disabilities, the Commission and the Treasury Board Secretariat agree to developing an on-going collaborative relationship to address such issues to the extent possible consistent with their statutory duties and responsibilities.
TBS maintains its commitment to continue its collaborative relationship with CHRC.
Plans and Timelines
The following chart outlines TBS’ planned actions, time frames, and the MOU commitments associated with each.
Action Item | Timeframe | TBS MOU Commitments | Comments |
| | Report plan to CHRC | Strategy Component | Brief & Consult | CHRC Collaboration | |
Report on plans to CHRC | 06/07 - Qtr 2 | X | | | X | This document fulfils the commitment. |
Engage contractor & develop consultative workshops | 06/07 - Qtr 2 | | | | X | Statement of Work has been drafted. |
Conduct consultative workshops | 06/07 - Qtr 3 & 4 | | | X | X | At least two workshops for assistance to model, prioritize and design requirements, services and management processes: - Solicit input
- Solicit feedback
|
Update Persona(s) | 06/07 - Qtr 4 | | X | | X | "Personas" model the needs of persons with disabilities for design purposes. An initial model currently exists but will be updated based on workshop consultations |
Plan Accessibility Services (Mapping, Gap Analysis, Prioritizing & Planning) | 06/07 - Qtr 4 | | X | | X | "Accessibility Services" refer to those identified in the No Answer report and during consultations that serve clients directly (e.g. TTY access, real time captioning, directory service) |
Plan Management Processes (Defining, Detailing, Prioritizing & Planning) | 06/07 - Qtr 4 | | X | | X | "Management Processes" refer to the ten components of the TBS’ Management Accountability Framework (e.g. monitoring the impacts of new technologies on persons with disabilities is an example of Risk Management) |
Develop and make available TBS’ strategy for providing services to target group | 06/07 - Qtr 4 | | X | | X | Based on results of workshops, persona updates, and planned services and management processes |
Implement Initial Set of Accessibility Services & Management Services | 07/08 - Qtr 1 & 2 | | X | | X | These refer to the initial set of accessibility services and management processes determined to be of the highest priority. |
Integrate Personas into GSRM | 07/08 - Qtr 1 & 2 | | X | | X | Once fully developed, personas will be integrated into the Governments of Canada Strategic Reference Model for use by departments when developing policies, programs, services and systems |
Reference: Recommendations from No Answer
As noted in the MOU, a component of TBS’ accessibility strategy is addressing this community. The recommendations below and the consultation workshops will inform the determination and modeling of needs, as well helping to determine the most effective strategy for designing and deploying processes and services. The results of this process, along with a forward strategy will be made available by March 31, 2007.
Although it is expected that some, if not all of the following recommendations will be incorporated into the final product, it is not TBS’ intention to predetermine the outcomes of consultation. As a result, the final plan may or may not include all of the following recommendations.
1. Comprehensive Strategy
It is recommended that:
a) the Government of Canada develop a comprehensive strategy on the provision of telephonic communications services to people who are Deaf, deafened or hard-of-hearing, or have a speech impediment and that this strategy be announced by March 31, 20063;
b) each federal organization develop an internal policy on the provision of telephonic communications services that will comply with and complement the strategy;
c) the strategy include specific reference to the duty to accommodate short of undue hardship as provided under the Canadian Human Rights Act;
d) Treasury Board Secretariat, or such other federal organization as may be appropriate, develop model standards or guidelines with regard to the provision of telephonic communications services; and
e) in developing policies, procedures and guidelines, and in purchasing equipment, relevant federal organizations consult people who have a hearing loss or speech impediment, and the manufacturers of, and experts on, assistive technologies.
2. TTY directory
It is recommended that the Government of Canada publish a yearly directory of the TTY numbers of all federal organizations, that the directory be updated regularly, and that it include a TTY number to call to report inaccurate numbers or inadequate service.
3. New technology
It is recommended that the Government of Canada constantly assess new developments in communications technology to determine how they might improve telephonic communications services for people who cannot use the regular telephone system. In particular, the process of replacing land telephone lines with a Voice-over-Internet Protocol (VoIP) system should include, from the design stage, provisions for assistive technologies, such as computer-mounted TTY systems.
4. Other issues
It is recommended that the Government of Canada review other federal communications issues identified during this study, such as the availability of American Sign Language/langue des signes québécoise (ASL/LSQ) services, provision of real-time captioning at federal meetings and consultations, consideration of the special needs of hard of hearing people, and captioning of federally sponsored television feeds, videos and the audio portions of Web sites. It is also recommended that the government review these issues by establishing a group of experts similar to the 2001 Task Force on Access to Information for Print-Disabled Canadians.
1. No Answer: A Review of Government of Canada Telephonic Communication with People Who Are Deaf, Deafened, Hard of Hearing, or Have a Speech Impediment - Canadian Human Rights Commission (June 2005)
2. The suite of personas, first developed in TBS’ Accessibility Architecture, models the needs of persons with disabilities in a way that clarifies and facilitates the design of accessible programs, services and systems.
3. The CHRC Report was issued in June 2005; thus the target date in that report for response was March 31, 2006. It is anticipated that the strategy, to be designed through target group workshops, will be prepared by March 31, 2007.