Accessibility Plan at Indigenous Services Canada (ISC)

Internal Engagement

ISC employees with disabilities shared their feedback on the main areas for action listed under the ACA.

With respect to all areas, training was highlighted to support accommodation and the review of existing infrastructure, supports and services against accessibility standards.

External Engagement

Indigenous partners representing clients with disabilities shared their feedback on the design and delivery of programs and services area. They shared that an accessibility lens is needed, as well as a greater understanding of the reality faced by clients with disabilities and their accessibility needs. It is important for these programs and services to be supported by a feedback mechanism so clients can make suggestions to improve programs, supports and services.

The next steps for this Plan include a more fulsome engagement across the organization and with partners, completing a cost analysis to address resource and capacity needs both internal and external, in support of First Nations, Inuit and Métis Nation partners. Examples underway are: the co-development of recommendations for a continuum of long-term care with Indigenous partners; the reform of the First Nations On-Reserve Income Assistance Program; and the Jordan's Principle long-term reform approach.

Specific information about this area of action

The Human Resources and Workplace Services Branch's (HRWSB) goal is to provide efficient, effective and high-quality services. These human resource services are shared between ISC and Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC). Employee networks and departmental champions are actively involved in promoting diversity, inclusion and anti-racism and support HRWSB in fulfilling this mandate. The Director General of Individual Affairs is the ISC Champion. ISC has funded a full-time coordinator to support this role.

Vision of accessible employment

In 2040, ISC is recognized as an employer of choice for persons with disabilities, with an important focus on Indigenous employees. The Department provides welcoming language and barrier-free processes, accessible job postings, equitable and culturally-informed selection mechanisms, and inclusive career development, leading to increased retention. In addition, accommodation requests made by persons with disabilities are implemented quickly. Managers, procurement officers, business units and everyone else who has a role to play in addressing accessibility and accommodation needs are invested in this responsibility and make it their priority. Our hospitality and employee services are accessible by default.

What we heard in consultations

Consultations related to the employment area of action generated lots of feedback and suggestions from the employees consulted. Highlights from the consultations include:

• 46.6% of people living with a disability have discussed their disability with a supervisor or manager, while 22.3% do not feel comfortable discussing it.
• 25.8% of total respondents feel they have experienced attitudinal barriers at work, and 17.0% of respondents have observed co-workers experiencing such barriers.
• There are difficulties in applying the Passport, which is a document that allows people with disabilities to register their accommodation needs and not have to reapply when they change positions or departments. In fact, 77.3% of respondents with disabilities were not aware of the Accessibility Passport, while 1.7% of respondents have already implemented one.
• Regarding requests for accommodation, 50% of people living with disabilities who have requested accommodation in the past two years have received their accommodation, 5.0% have been refused, and 37.5% indicated that their request was in progress. Finally, 7.5% received a measure, but did not receive the specific accommodation requested.
• 16.1% of those living with disabilities felt very satisfied with the ergonomic or adaptive equipment provided to them to do their work, while 31.6% felt satisfied, 7.7% not very satisfied, and 11% very dissatisfied (33.6% answered "Not Applicable").
• Respondents to the various consultations identified a significant need for resources for staff with disabilities, as well as training for managers on how to accommodate individuals within their teams. Employees with disabilities also reported that they found the processes of requesting and obtaining workplace accommodations difficult, or that they were not aware of the existence of this service at all.
• Hiring targets for people with disabilities are needed to achieve a more diverse workforce.
• More emphasis needs to be placed on consultation with other employment equity groups, such as Indigenous employee groups living with disabilities.
• It is hoped that more staff with different types of disabilities will be hired which would provide a greater diversity of people with different types of disabilities within ISC More emphasis needs to be placed on equal opportunity for employees with disabilities in job postings.

Barriers and actions

Specific information about this area of action

With respect to office buildings, ISC is a tenant of PSPC and occupies space in both Crown and commercially leased buildings. The National Accommodations sector provides a shared service to ISC and CIRNAC. When changes are made to the buildings, ISC works in partnership with PSPC and the companies that manage the buildings to ensure that the properties exceed minimum industry standards.

Vision regarding accessibility in the built environment

In 2040, ISC provides accessible workspaces for persons with disabilities. Our built environments are barrier-free.

As one of the dimensions of the ISC Modern Workplace strategy, the department built environment is being designed to be accessible, flexible, inclusive and culturally safe, taking into consideration diversity, including gender diversity as well as Indigenous culture.

As part of the modernization of its offices across the country, ISC, in partnership with PSPC has implemented and will continue to implement many of the best practices featured by Accessibility Standards Canada including but not limited to:

• Doors with power door operators;
• Sliding doors in boardrooms;
• Accessible, universal washrooms with emergency button;
• Lower height counters in kitchens and bathrooms;
• Height accessible equipment locations;
• Light alarms that complement Sound alarms for emergency evacuations.

ISC will continue its partnership with PSPC to incorporate Indigenous design in its office modernization projects to reflect and be representative of Indigenous cultures by:

1. facilitating Indigenous inclusion and engagement in the workplace, both before and after occupancy, and
2. celebrating the inherent emphasis on health and well-being and environmental sustainability within Indigenous cultures and values.

What we heard in consultations

Consultation on the built environment area for action generated some feedback and recommendations from employees with disabilities. Highlights from these consultations include:

• 17.3% of those living with a disability indicated that their current office building was fully accessible, 18.8% indicated that it was very accessible, 24.8% indicated that it was somewhat accessible, and 9.8% indicated that it was not accessible (29.3% answered "Not Applicable").
• Employees indicated that existing workplace design infrastructure was inconsistent. For example, there is a lack of automatic doors in buildings, ramps that are not always accessible due to obstructions, and it is difficult for employees with disabilities with mobility issues to move between or around workplaces. It was mentioned that working from home has mitigated many of these issues.

Barriers and actions

Specific information about this area of action

The Information and Communication Technology (ICT) Branch provides Information Management and Information Technology (IM-IT) products and services on a shared service basis to ISC and CIRNAC. It focuses on helping stakeholders and customers achieve their business objectives through the reliable, secure and cost-effective use of IM-IT tools. It is comprised of eight business sectors, as well as the Office of the Chief Information Officer.

The eight business sectors are:

1. Enterprise IM-IT Strategic Services,
2. Benefits Modernization and Transformation,
3. Corporate Information Management,
4. Enterprise Data and Analytics Services,
5. Enterprise IT Infrastructure Services,
6. Enterprise IT Service Delivery,
7. Enterprise IT Support and Operations, and
8. Operations and Planning.

Vision regarding information and communication technology accessibility

In 2040, all employees have the electronic and software tools they need to do their jobs and the department is prepared to procure new equipment as needed in a timely manner. Accessibility is an integrated and expected component of IT processes and within the IT infrastructure (e.g., security, infrastructure, and application development). Accessibility is part of the standardized approaches. Employee needs are considered in the life cycle of software development, services, software and hardware purchases.

What we heard in consultations

The ICT policy area generated proposals from the employees consulted. Here are some highlights from these consultations:

• 27.9% of people living with disabilities felt well supported by IT specialists when they needed help using their accessible software and technologies, 16.3% of respondents said they did not feel supported but still managed, and 8.2% responded that they did not feel supported and did not know whom to ask (47,6% answered "Not Applicable").
• 84.1% of respondents felt that virtual meetings were fully accessible to them, 13% felt that these meetings were partially accessible, and 2.8% felt that these meetings were not accessible.
• Employees identified a need for adaptive computer technology in meetings, e.g., intelligent closed captioning software for virtual bilingual meetings.
• Employees indicated a need to increase awareness among new employees of the types of non-standard equipment that may be available when needed.
• There are difficulties and delays in selecting and receiving the adaptive technologies needed to perform their work.
• In addition, there is a lack of compatibility between Government of Canada intranet documents and accessibility software (these problems occur primarily when using screen reading software).

Barriers and actions

Specific information about this area of action

The Communications and Public Affairs sector is a shared service for ISC and CIRNAC. This sector is responsible for developing internal and external communications products. This includes content for public awareness campaigns, social media, web, Intranet, departmental news releases and statements, and speeches. The sector also creates images and videos and plans events.

Communications' Accessibility Vision

In 2040, the sector identifies and applies new and existing accessibility standards to create barrier-free communications and develop products that are accessible to all. To achieve this, Communications identifies training opportunities for employees, provides guidance and advice to employees, and develops and shares accessibility-related guidelines and tools. This will result in communication products that are accessible to all and will ensure that everyone is included.

What we heard in consultations

The communications action area has generated information and proposals from the employees consulted. Some highlights from these consultations include:

• 58.5% of survey respondents who identified themselves as people living with disabilities are always able to communicate/receive communications in their preferred method(s), 35.4% are sometimes able to do so, 1.5% are never able to do so, and 4.6% do not know.
• 63% of respondents feel they would benefit from training to make materials more accessible, 19.1% say they would not, and 17.9% are unsure.
• 45.7% of respondents felt that workplace communications are written in plain language, 11.3% felt that communications are not written in plain language, 38.5% felt that communications are sometimes written in plain language, and 4.5% did not know.
• Respondents identified a lack of plain language in external and internal documents.

Barriers and actions

Specific information about this area of action

Procurement services enables the delivery of high quality services to First Nations, Inuit and Metis clients by purchasing goods and services on behalf of sectors, branches and regions to ensure the best value for Canadians. The procurement processes are guided by the Government of Canada procurement guidelines This is described in the following documents Policy Notification PN-142, Directive on the Management of Procurement (article 4.2.7.1). Employees can also consult the Accessible Procurement: Inclusive by Design, Accessible by Default.

Procurement vision for accessibility

In 2040, procurement processes meet all legal obligations and standards on accessibility, including those under the Accessible Canada Act (ACA) and Accessibility Standards Canada. Procurement processes are centralized and prioritize assets related to accommodation requests from employees with disabilities.

Business owners, technical authorities and employees consider accessibility when specifying requirements for goods, services and facilities, and deliverables include features that make them accessible. Contracting officers challenge business owners, technical leads and employees about accessibility criteria. Preference is given to suppliers of services and goods that are inclusive of persons with disabilities.

ISC is committed to reconciliation with Indigenous peoples and will continue to explore all available avenues for increasing opportunities for Indigenous businesses to participate in federal procurement processes. The Departmental programs in collaboration with procurement are working on strengthening procurement policies and mechanisms in support of the Procurement Strategy for Indigenous Business.

ISC will ensure that the Accessibility measures planned to eliminate barriers in procurement are equally implemented under the departmental procurement strategy for Indigenous Business.

What we heard in consultations

In the employee questionnaire, there were no questions regarding the procurement area for action. However, comments regarding the need for improvement in the procurement process with respect to accommodation were raised by employees and are described under the employment area of action. Procurement subject matter experts identified accessibility-related improvements needed in their processes.

Barriers and actions

Specific information about this area of action

For the first Plan, ISC will review the level of accessibility of its programs and services for Indigenous individuals with disabilities to support planning, development and implementation of programs and services for these to be inclusive by design and accessible by default. ISC will also develop standards for accessibility that include best practices, tools, and training.

Design and delivery of programs and services vision for accessibility

In accordance with the Department of Indigenous Services Act, Indigenous Services Canada continues to work toward changing how it can better support the rights and priorities of Indigenous Peoples. As per Section 7(b) of the Act, the department will continue to "take the appropriate measures to give effect to the gradual transfer to Indigenous organizations of departmental responsibilities with respect to the development and provision of those services". In keeping with our transfer mandate, ISC will be increasingly working with Indigenous partners to ensure services are delivered independently by Indigenous partners to their communities. The transfer of services must be Indigenous-led, accessible, and affirm the right of self-determination.

In the interim, the design and delivery of programs and services provided by ISC are inclusive and accessible-by-design to meet the needs of Indigenous clients and employees. The department continues to work toward ensuring that service transfer arrangements protect and promote accessibility. Employees have the necessary tools and resources to design and deliver accessible programs and services to persons with disabilities. Our clients with disabilities are engaged on the design and delivery of programs and services, and participate in feedback processes that are inclusive, accessible, and open while protecting their privacy and confidentiality.

What we heard in consultations

For comments of what we heard regarding this area for action please refer to Annex B – Summary of findings from external client engagement.

Barriers and actions

Specific information about this area of action:

Despite holding internal and external consultations, no specific transportation barriers, were identified. However, potential transportation barriers remain a concern. ISC has been taking steps in recent years to reduce potential transportation barriers to access our services, considering that many Indigenous Canadians who access our services live in the North, in isolated and remote communities where transportation infrastructure is limited or non-existent.

Vision regarding accessible transportation:

ISC has been and will continue to increase points of service, so that Indigenous Canadians can access services directly in their communities or digitally, hence reducing barriers with respect to transportation. Funding will continue to be provided to communities to facilitate the purchase of accessible vehicles to transport community members with disabilities.

Given the importance that the Accessibility Plan is developed through consultation and feedback, it is integral that the organization further develops this pillar in consultation with the individuals who are experiencing the barriers, recognizing that a deeper understanding of existing or future potential barriers is required. As a result, ISC will be working in 2024 and 2025 to further explore the transportation area of action with stakeholders both internally and with Indigenous communities and organizations across Canada.

What we heard in consultations:

During some of the external consultations however, stories were shared of individuals with disabilities flying into and out of remote and isolated communities in the North, the challenges faced to get into and out of the plane and the impact to their dignity. ISC recognizes that while the department does not provide some of these transportation services directly, barriers in transportation do have an impact on individuals receiving services from our organization, as well as when employees travel for business related purposes on behalf of ISC.

As a result and as an immediate response, we will start with the following barrier and initial actions, while we further consult internally and externally.

Barrier 1: Travel services providers do not always treat travelers with disabilities with respect and dignity or provide satisfactory accommodation to meet the traveler’s needs.

Actions to address barrier 1:

• Action 1: Prepare new or amend existing communications to ensure that our clients are aware of how to request accommodation when they travel for medical or dental care.
  • Timelines: Completed by December 2024
  • Intended outcome: Increased client awareness of their right to be accommodated when traveling to receive non-insured health services and of the policies and processes that apply.
• Action 2: Prepare new or amend existing communications to ensure that employees with disabilities are aware that they have the right to be accommodated when traveling.
  • Timelines: Completed by April 2024
  • Intended outcome: Increased employee awareness of their right to be accommodated when traveling on government business and of the policies, processes and directives that apply.
• Action 3: Develop targeted feedback mechanisms related to travel and transportation to gather more information about the needs and experiences of ISC employees and clients.
  • Timelines: Completed by December 2025
  • Intended outcome: The information is used to address improvements with respect to travel services directly with the service providers.
• Action 4: Develop and provide training to employees with outward-facing, client interaction roles to ensure that there is an awareness of accessible services solutions available to assist clients with disabilities to access our services.
  • Timelines: Development completed and begin providing the training by December
  • Intended outcome: At all levels of the organization, there is an understanding and awareness of the accessible service solutions, and there is an active offer to accommodate when clients interact with employees of ISC to ensure accessibility needs are identified and that accommodation are offered, if requested.

Internal engagement

For internal engagements, the department started by creating an employee network on accessibility and disability in 2021. The Joint ISC/CIRNAC Accessibility and Persons with Disabilities Network has a membership of about 140 employees who have self-identified as persons with disabilities. This network generally meets on a monthly basis by videoconference and has a membership. The network provides a meaningful forum for discussion around accessibility and disabilities in the workplace, including barriers to accessibility and actions to address barriers.

The employee network held virtual working group sessions in 2021 to brainstorm on areas of Nothing Without Us: A Public Service Strategy on Accessibility. Then prepared an employee-led action plan that later informed the department on actions needed within the accessibility plan.

The department created an ACA Implementation Secretariat in 2022 to coordinate the development of the accessibility plan, which included consultations with employees with disabilities and collaborations with the sector leads. An approach to develop the accessibility plan was presented and discussed with the employee network members, and employees were encouraged to provide feedback through a generic email address during the process. The CIRNAC Senior Policy Advisor on accessibility was designated to receive feedback on behalf of ISC and CIRNAC.

The consultation approach included an employee questionnaire on accessibility for persons with disabilities in August 2022 to identify barriers to accessibility in the workplace. Extensive feedback was provided by employees with disabilities, managers, and other employees and partners without disabilities. A total of 302 people completed the questionnaire. Here is how the respondents identified themselves and the corresponding percentages:

• Person living with a disability: 38%;
• Ally of or employee of a person living with a disability: 32%;
• Supervisor or manager of a person living with a disability: 20%;
• None of the above: 10%.

The main results from this questionnaire are described within each of the areas of action.

Based on the feedback collected in the questionnaire, sector leads identified the top three to five barriers within each of the areas for action and identified concrete actions to address the barriers.

The Secretariat then held internal engagement sessions with the employee network in October and November 2022. Sessions were organized using a videoconferencing format with options for sign language. Each session focused on specific areas for action and ranged in duration from 45 minutes to an hour with an additional session being organized if needed.

During the sessions, sector leads presented the proposed actions and employees with disabilities provided their feedback. Employees were asked three questions:

1. Are these barriers the most important priorities for the next three years?
2. Will the proposed actions eliminate and prevent barriers? and
3. What do each of the priority areas look like in 2040 when all barriers are eliminated.

Employees with disabilities provided extensive feedback and a summary report is available in Annex A.

External engagement

For external engagement, the department completed preliminary engagement with regional and national Indigenous partners representing ISC and CIRNAC's external clients with disabilities. The input gathered from these sessions was used to identify the barriers and develop recommendations contained under the Design and delivery of programs and services area for action of the accessibility plan. A summary of external client engagement findings is available in Annex B.

The engagement process was designed to facilitate honest feedback and identify barriers to accessibility within the organization. In preparation for the interview sessions, participants received a background document with contextual information along with a document listing the programs and services offered by ISC and CIRNAC.

An interview guide, interview invitations and online survey to allow for additional options for external clients to participate were developed. External partners were contacted to coordinate and schedule virtual interviews and circulate a link to an online survey for those that indicated they preferred providing input through that mechanism. Follow-up emails were sent in cases where initial engagement invitations went unanswered. Interviews were conducted and a report was prepared that included a summary of findings and the barriers and recommendations suggested by the partners that were engaged.

External clients representing the following organizations were engaged with either through one-on-one interviews, or group meetings:

• Assembly of the First Nations (AFN);
• BC Aboriginal Network on Disability (BCANDS);
• Indigenous Disability Canada (IDC);
• Inuit Tapiriit Kanatami (ITK);
• Métis National Council (MNC).

External clients representing the following organizations were engaged through the circulation of an online survey:

• Nunavummi Disabilities Makinnasuaqtiit Society (NDMS);
• Native Women's Association of Canada;
• Canadian Roots Exchange.

The department acknowledged that the internal and external engagement was only the beginning as the conversation and collaborations will continue throughout the accessibility journey. Also, the implementation of the Plan will include broadening engagement and collaborations with other groups and networks to gain a better understanding of the intersectionality lens and how it impacts employees with disabilities.

Employment

A first session took place on October 31st, 2022, and a second session on November 24th, 2022 to allocate additional time for this area. Highlights of feedback included:

• There is a need to train managers and supervisors on accessibility, duty to accommodate and accommodation measures as soon as possible.
• Workplace Accessibility Passport (Passport) is long, repetitive, and confusing for those trying to create one. Managers are also unsure of how the system works, making the process more difficult for employees.
• It was suggested that the Passport also include an employee's strengths and abilities, rather than only focusing on accommodation needs. This could reduce stigma that employees with disabilities experienced from their manager.
• Development opportunities for employees with disabilities are critical to advance within the department, rather than staying in entry-level positions.
• Hiring targets to increase representation of persons with disabilities needs to include a variety of disabilities to be representative of all disabilities.
• There is a need for tools and resources for employees with invisible disabilities.
• The goals set out in the accessibility plan need to be measurable in order to track progress over time and pin-point which areas need improvement after the implementation of the initial plan.
• Greater accommodation is needed for individuals with learning disabilities in relation to language requirements and second-language education opportunities.
• Suggestions were made to include more internal and external groups to gain insights into intersectionality with persons with disabilities, including a need to include indigenous employee equity groups in consultations.

Information and Communications Technology

The session took place on November 3, 2022. Two key messages from this feedback included:

• There is a need for a videoconferencing software with intelligent bilingual captioning that is able to switch between languages. While MS Teams already has captioning software, this software is only able to provide captions in one language at a time. This is insufficient for staff who require captioning software in order to fully participate in videoconferences.
• Existing technologies need to be reviewed for accessibility, and accessibility needs to be considered when selecting new technologies moving forward.

Communication

The session took place on November 10, 2022. Highlights of feedback included:

• There is a need for an increase in departmental-wide use of plain language in all methods of communication. Also, it would be important to develop a process to review plain language documents.
• There is a need for training about how to write in plain language. This training would also cover how to make content accessible and inclusive (e.g., how to prepare documents that are accessible by screen readers).
• French captions for videoconferences could be improved.

Built Environment and Procurement

A joint session on built environment and procurement took place on November 22, 2022. Highlights of feedback included:

• With the return to work in the office, there is a need for accommodation measures. The office modernization does not meet all needs of employees with disabilities. Employees may have sensory issues or employees with anxiety may be unable to work in open areas. A possible solution is for employees with disabilities to request an accommodation measure of working remotely from their home office if this allows them to perform their work. Managers need to understand that this is a legal obligation related to the duty to accommodate.
• Emergency planning and management protocols were also identified as requiring an update, as the current directives are unclear for those with mobility impairments to be evacuated safely and promptly.
• An increase in the amount and ease of accessibility of braille signage in the workplace was also cited as necessary.
• Regarding procurement, there was a suggestion to have alternate formats for employees and vendors to submit requests or bids, such as through the use of video recordings.

Barriers Identified

Recommendations Identified

The following are the recommendations identified by partners to eliminate and prevent barriers to clients with disabilities:

• Employees who interact and support clients complete cultural awareness training and accessibility training to become better equipped to deliver programs and services to Indigenous people and persons with disabilities.
• ISC increases awareness of alternative formats that clients with disabilities can use in application processes. An example of this is for clients to receive assistance with the completion of forms or have someone else complete the form on their behalf.
• Client engagement questionnaires include accessibility specific questions.
• Online content is made accessible and available in multiple formats such as large font, braille, American Sign Language (ASL), and Langue des signes québécoise (LSQ) and Indigenous Sign Languages. Also, online videos would include sign language and closed captions.
• ISC expand and improve health related programs where possible to better support persons with disabilities so that they do not need to travel away from or reside outside of their communities in order to access health-related programs and services. For example, through the expansion of the Home Care program. It was also recommended that ISC increase the awareness and promotion of existing health related programs and services that either directly or indirectly support persons with disabilities.