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Accessibility Action Plan - ACOA

Approved by President: November 13, 2020

Overview – The Government of Canada’s Accessibility Strategy

Vision

To be the most accessible and inclusive public service in the world.

Guiding Principles

• Nothing without us: persons with disabilities are involved in the design and implementation of the strategy
• Collaboration: departments and agencies work in collaboration with each other, with bargaining agents, and with other public, private and not-for-profit organizations
• Sustainability: the strategy prioritizes actions that will have an enduring impact
• Transparency: the strategy is developed and implemented transparently, and departments and agencies will report openly and transparently on their efforts to remove barriers

Goals

Five goals are key to realizing the vision:

1. Employment – Improve recruitment, retention and promotion of persons with disabilities
2. Built environment – Enhance accessibility
3. Technology – Make information and communications technology usable by all
4. Services – Equip public servants to design and deliver accessible programs and services
5. Culture – Build an accessibility-confident public service

Summary

For too long, there have been barriers that block persons with disabilities from working and thriving in Canada’s public service. The time is right for a culture change. A better Canada could be built by including the knowledge and expertise of persons with disabilities in all aspects of our work.

The Government of Canada’s Accessibility Strategy sets out how the public service can identify, prevent and remove physical, systemic and cultural obstacles to the participation of persons with disabilities. This strategy aims to create an environment where persons with disabilities can flourish. When persons with disabilities in the public service can focus on their work and their service to Canadians, instead of combatting the systems and structures that keep them marginalized, all Canadians can benefit.

The goal from the outset has been simple but monumental: to make Canada’s public service the most inclusive public service in the world.

During federal consultations, public servants with disabilities said that:

• they often do not feel a sense of belonging in their workplace;
• their essential accommodations are too often ignored, overlooked or dismissed;
• they face extensive barriers to securing a public service job;
• they experience harassment and discrimination at higher rates than other public servants;
• they have significantly lower chances for promotion; and
• they frequently feel disrespected or marginalized where their voices would be critically helpful.

The public service should mirror the people it serves. Canadians with disabilities should see themselves reflected in the public service as policy-makers, researchers, analysts, providers of services, spokespeople and leaders.

The Accessible Canada Act,^{Footnote 1} which received Royal Assent in July 2019, seeks to:

• enforce the identification, removal and prevention of accessibility barriers for organizations under federal jurisdiction…; and
• ensure the full participation in society of persons with physical, mental, intellectual, learning, communication or sensory impairments.

Improved accessibility in the public service is also in line with Canada’s international obligations. As a party to the United Nations Convention on the Rights of Persons with Disabilities,^{Footnote 2} Canada has committed to “ensure the full and equal enjoyment of all human rights and fundamental freedoms by all persons with disabilities.” It has also recognized the central role that public service employment can play in fulfilling that commitment.

ACOA’s Duties under the Act

Under the Act, all regulated entities, such as ACOA, have the following duties:

Accessibility plans – An accessibility plan would need to be created in consultation with people with disabilities. The plan must outline the strategies for improving and meeting legal accessibility duties. These plans would have to be published publicly and updated every three years or sooner.

Feedback tools – There would need to be a system in place to receive and respond to feedback from employees or clients.

Progress reports – Reports outlining how accessibility plans will be/are being fulfilled must be created in consultation with people with disabilities and describe how they will address the main concerns of feedback received.

Future regulations would detail how regulated entities must implement these requirements. Details may include when and how accessibility plans and progress reports must be published.

Disability – What Is It?

Current Status

There are about 6.2 million Canadian adults with a disability.^{Footnote 3} That is one in five people who face one or more physical, social or economic barriers. These barriers can often keep them from being and/or feeling like equal members of society.

Many disabilities are not visible to the naked eye. We cannot see cognitive or learning disabilities, carpal tunnel syndrome, long-term effects from a concussion, or mental health issues.
Changing attitudes and removing barriers gives people with disabilities more job opportunities and the chance to thrive in the workplace.

Definitions

Disability is a complex, evolving matter. The term covers a broad range and degree of conditions. A disability may have been present at birth, caused by an accident, or developed over time. It may be physical, mental, psychiatric, social or economic. Here are some disability sub-categorizations:

1. Any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness.
2. A short-term physical impairment caused by an accident, such as a broken arm or a concussion.
3. A condition of mental impairment or a developmental or learning disability (e.g. ADHD, autism)
4. A mental health condition, whether short-term, episodic or chronic, such as depression, anxiety or bipolar disorder.

Accessibility means that people with and without disabilities can perceive, understand, navigate and interact with information, services and applications. The adoption of accessibility standards, guidelines and best practices ensures that systemic barriers are eliminated prior to individual accommodations.

Accommodation is a necessary measure taken to allow an employee to work to the best of their ability.

Barriers may be attitudinal, environmental or institutional. They may even be internalized.

ACOA’s Action Plan

The following section provides an overview of how ACOA plans to address the Government of Canada’s Accessibility Strategy and its five goals, and where the Agency expects to be vis-à-vis these goals in 2021.

To be noted, the five goals mentioned in the Government of Canada’s Accessibility Strategy above are presented as four key objectives for ACOA - as built environment and technology have been combined into the second objective, Infrastructure.

OBJECTIVE 1 – Employment

Where Government is as a whole

Statistics Canada’s 2017 Canadian Survey on Disability found that 15.6% of the Canadian workforce (aged 25 to 64) consists of persons with a disability. However, in the 2017-2018 fiscal year, only 5.3% of public servants self-identified as a person with a disability.

Where ACOA expects to be in 2021

• Employees with disabilities should notice an improvement to the adjustment process.
• Promotion rates for persons with disabilities will be increased, and separation rates will be decreased.
• Existing recruitment and development programs will have fully integrated accessibility.
• Employees with disabilities will report greater satisfaction at work.

How ACOA will get there

1. Advertise employment opportunities in an accessible format, particularly important on private sites (versus jobs.gc.ca). Look at our application process online (i.e. have community stakeholders look at it) and ensure it is not a barrier to people with disabilities.
2. Stakeholder organizations should be consulted as a resource when hiring.
3. Review existing development programs to ensure that persons with disabilities are represented and supported at each stage, from entry to exit.
4. People who can’t physically work in an office should be able to work from home.
5. Develop tools and training for supervisors to enable them to create inclusive teams.

OBJECTIVE 2 – Infrastructure

1. Physical Environment

Where Government is as a whole

Persons with disabilities report challenges in the workplace, such as a lack of automatic door openers and poor signage and way-finding. In the first survey on the development of the federal strategy, several respondents noted that physical workspace do not account for non-visible disabilities such as environmental sensitivities, chronic pain, anxiety and autism.

Where ACOA expects to be in 2021

• Employees with disabilities will have been engaged in making their workplace more accessible (code is often insufficient to meet needs).
• Starting in 2020, all new designs are accessible and have incorporated the feedback of persons with disabilities (employees, clients and others who regularly conduct business in the building); and starting in 2021, all new builds or retrofits are accessible and incorporate the feedback of persons with disabilities.

How ACOA will get there

1. Develop a Disabilities Considerations Checklist of 5-10 items to make the physical workspace more accessible for all: signage (incl. pictograms); create calm workspace; recirculate air through proper filters, esp. in 2.0 office space; automatic push buttons for all access doors.
2. Ensure events and meetings are accessible to all employees, and where applicable, the public
3. Evacuation plans should include how to evacuate an employee/visitor with a disability. Regular practices, with person with disability in different locations. 
4. Create “calm” space to work – low traffic, low-level lights, little sound, soothing paint colours. There is a need calm and consistency.
5. Universal design for new buildings – create accessible spaces.

2. Technology

Where Government is as a whole

The current Treasury Board of Canada Secretariat Standard on Web Accessibility is not sufficient to ensure that all information and communications technology products, services and digital content are accessible: it only covers externally facing websites. It does not cover other aspects, including hardware, software and other digital content. It is not designed or intended as a complete accessible information and communications technology standard.

Where ACOA expects to be in 2021

• Develop an information technology accessibility strategy that focuses on:
  • education, outreach and communications
  • accessibility governance and accountability
  • accessible procurement
  • compliance and assessment
  • accessibility standards and guidelines
  • enhancing service delivery to employees with disabilities.
• All major new systems, both internal and external, launched as of 2021 are accessible.

How ACOA will get there

1. Need dedicated person in Agency who is familiar with the Accessibility, Accommodation and Adaptive Computer Technology (AAACT). Educate managers and employees about Shared Services Canada’s AAACT services and availability.
2. Make sure all platforms are accessible to users. 
3. “Accessibility Passport”: accommodations go with employee as they move from job to job/department to department. 
4. ACCESSIBILITY:
   1. Provide resources (e.g. training) for employees so they can generate accessible documents with common tools (e.g. Word, PowerPoint);
   2. enable accessibility features on all devices/software;
   3. convert all templates to accessible format by end of 2021; and
   4. ensure contracts with suppliers require that documents meet accessibility requirements.

OBJECTIVE 3 – Client Services

Where Government is as a whole

The consultations that led to the proposed Accessible Canada Act found that:

• Many persons with disabilities report that they do not receive equal quality of service.
• There are numerous barriers to communication, such as documents in formats that are not accessible.
• Persons with disabilities would like more opportunities to report service issues and suggest improvements.

Where ACOA expects to be in 2021

• Establish consultation and feedback processes for clients with disabilities as well as transparent mechanisms to address concerns raised by clients with disabilities.
• Proposals for new programs will document that they have integrated accessibility into their design.
• Website and intranet meet Web Content Accessibility Guidelines (WCAG) 2.1 (2018) (e.g. no red/green colours, which are difficult for those with colour blindness; contrast between colours in bar graphs; avoiding split/merged cells in tables)

How ACOA will get there

1. Ensure documents are accessible to all clients.  Ensure all concerned are aware of this.
2. Videos – should have sign language, cc, sub-titles and/or descriptive video
3. Ensure Rendezvous is accessible.
4. Develop data on client satisfaction from the perspective of persons with disabilities.
5. Pilot engagement and feedback processes from clients with disabilities.

OBJECTIVE 4 – Culture

Where Government is as a whole

Accessibility is not generally integrated into the everyday business of the public service; it is often treated as an afterthought. Although there are some accessibility initiatives across departments and across functions, these are often siloed. There is no governance to link initiatives together strategically, and there are few mechanisms for departments and employees to share best practices. In consultation for developing the federal strategy, respondents noted a need for a centre of expertise on accessibility.

Where ACOA expects to be in 2021

• Name a Champion/Chair for employees with disabilities who will provide visible and sustained leadership and help maintain a vibrant network of employees with disabilities.
• Informal Conflict Management Services (ICMS) promotes respect and inclusiveness in the workplace via available services.
• Computer equipment and furniture that are the result of an accommodation follow an employee from job to job, from department to department, so they do not have to start over every time
• Basic ergonomic principles are applied to a healthy population as an injury prevention measure

How ACOA will get there

1. Develop and maintain a vibrant network of employees with disabilities – through HR.  
2. Promote communications around “disabilities” day/week (December 3). Currently there is nothing to mark this day.
3. Implement a communications strategy, including an online presence, to raise awareness and promote a culture change around accessibility in the department. 
4. Language – we talk about hiring people from marginalized groups because it is the “right thing to do.” Need to change that language. Do it because it’s smart – highlight abilities/strengths they bring to the job.

Considerations

Collaboration

Many of the issues identified here regarding accessibility – such as developing and maintaining a vibrant network of employees with disabilities – are also issues for Employment Equity (EE) and Diversity Committee. It is suggested that the Accessibility Working Group and the EE and Diversity Committee join forces to work together to identify and address those issues that they have in common, rather than duplicating efforts.

National AccessAbility Week

Under the Act, each year throughout Canada, the week starting on the last Sunday in May is to be known as National AccessAbility Week. During this week, the Agency will organize relevant activities for employees and, every third year, update its Accessibility Action Plan.

Timeline

Once the plan has been approved, the following milestones will be observed:

1. Develop a Results Framework – Immediately after approval
2. Create a Roles and Responsibilities Table – Immediately after approval
3. Create a Communications Committee – Within 2 weeks of approval
4. Build an Implementation Team – Within 2 weeks of approval
5. Publish on the ACOA Website –  One week after approval
6. Update the plan – Every 3 years (notifying Accessibility Commissioner)