2023 OIC Progress Report Accessible Canada Act

Office of the Information Commissioner of Canada
30 Victoria Street
Gatineau, QC K1A 1H3

Tel. (toll free): 1-800-267-0441
Fax: 819-994-1768
Email: general@oic-ci.gc.ca
Website: https://www.oic-ci.gc.ca/en
December 2023

Contents

• Executive summary
• General
• Areas in section 5 of the ACA
  • Programs and services
  • Built environment
  • Information and communication technologies, Communication (ICT), other than ICT
  • Employment
  • Procurement of goods, services and facilities
  • Transportation
• Consultations
• Feedback
• Conclusion

Executive summary

The Information Commissioner of Canada is an Agent of Parliament whose mandate is to investigate complaints submitted under the Access to Information Act about various types of allegations, many of which are associated with an access request an individual submitted to an institution covered by the Act.

The Office of the Information Commissioner (OIC) supports a culture that embraces diversity and inclusion to enable the full participation of its employees, clients, and stakeholders in the delivery of its activities and its mandate. The Canadian legislative framework that supports diversity and inclusion was strengthened by the addition of An Act to ensure a barrier-free Canada, also known as the Accessible Canada Act (ACA or the “Act”), which came into force on July 11, 2019.

In order to meet the legislative requirements, the OIC published its “2022-2025 Accessibility plan for the Office of the Information Commissioner: Moving toward a more accessible OIC” (Accessibility Plan) in December 2022. This included a three-year action plan and a detailed accessibility feedback process (web form and electronic mailbox).

Over the past year, the organization has been working to implement this plan, and has created a working committee to monitor the action plan and ensure coordination and sharing of best practices in terms of accessibility. Committee members included representatives from all the organization's sectors (human resources, investigations, security and administration, Information Technology, and communications).

General

As required by the ACA, the OIC must report annually, by December 31, on progress made against its accessibility plan, and update it every three years.

This first OIC’s Progress Report outlines the organization’s achievements to date in implementing its Accessibility Plan through the following sections.

• Areas in section 5 of the ACA: This section provide progress made implementing OIC’s action plan.
• Consultations: This section includes description of how OIC consulted persons with disabilities for preparing its progress reports.
• Feedback: This section provides information about the feedback the organization received.
• Conclusion: This section highlights actions the organization will prioritize in the coming year.

Finally, this first section provides a reminder of OIC’s feedback process, including the title of the person designated to receive feedback, and the information on how to communicate with your organization to address accessibility issues.

The Director and Head of Human Resources is designated to receive accessibility feedback and to coordinate with internal subject matter experts responsible for each of the seven priority areas to meet new obligations described under the ACA as required.

Should you have any comments or feedback, please direct them to:

Accessibility Inquiries
Office of the Information Commissioner of Canada
30 Victoria Street
Gatineau, QC K1A 1H3

Toll-free: 1-800-267-0441 (Toll Free)
Fax: 819-994-1768

Email: accessible@oic-ci.gc.ca

Accessibility Feedback Form: https://www.oic-ci.gc.ca/en/form/accessibility

Website: https://www.oic-ci.gc.ca/en/accessibility

Alternative formats of both the progress report and the accessibility plan are available upon request (i.e. print, large print, braille, audio format, or an electronic format that is compatible with adaptive technology that is intended to assist persons with disabilities).

Areas in section 5 of the ACA

The regulations require organizations to report on the following areas, identified in Section 5 of the ACA:

• a) employment
• b) the built environment
• c) information and communication technologies (ICT)
• c.1) communication, other than ICT
• d) the procurement of goods, services and facilities
• e) the design and delivery of programs and services
• f) transportation

To address identification and removal of barriers, and the prevention of new barriers, in these areas, the OIC identified six organizational goals:

Goal 1 – Ensure that OIC employees are sufficiently equipped to deliver accessible programs and services, including an accessible complaint process to ensure Canadians can participate fully and equally and, tools and platforms they need to perform their work.

Goal 2 – Create a safe environment and a workplace free of physical barriers to improve the working environment for all OIC employees of various abilities.

Goal 3 – Remove barriers for OIC communications products by creating an “accessibility by design” culture, where staff at all levels are aware of requirements.

Goal 4 – Share knowledge and best practices widely to eliminate barriers across the public service.

Goal 5 – Create a culture of accessibility, where respect and inclusion are embedded in all aspects of the workplace and where all employees are empowered and supported to achieve their full potential.

Goal 6 – Implement accessible practices to eliminate and prevent barriers to the recruitment, retention, and promotion of persons with disabilities.

This section will highlight the progress made on each of these organizational goals.

Overall, the OIC action plan published in December 2022 included 28 actions to be carried out over the fiscal years 2022-2023 to 2024-2025. Although this first year also focused on setting up a monitoring structure for the action plan, and raising awareness among employees, the OIC managed to accomplish a considerable amount of work. All the planned actions have been initiated, including those that were scheduled for completion in 2024-2025. In addition, three unplanned actions were initiated, and only one had to be postponed to a later year.

The following table shows the number of actions completed, initiated or postponed for each fiscal year covered by the action plan.

• For fiscal year 2022-2023, a single action was planned. As it has been postponed to the following fiscal year, no action were completed or initiated.
• For fiscal year 2023-2024, ten actions were planned, which have all been initiated. As a result, no actions have been completed or postponed.
• For fiscal year 2024-2025, five actions were planned, which have all been initiated. As a result, no actions have been completed or postponed.
• The Plan included nine actions to be achieved on an ongoing basis, and these have all been initiated.

Table 1: Overview of actions initiated, completed or postponed^{Footnote 1}

Programs and services

Goal 1 – Ensure that OIC employees are sufficiently equipped to deliver accessible programs and services, including an accessible complaint process to ensure Canadians can participate fully and equally and, tools and platforms they need to perform their work.

Regarding this goal, the OIC had identified barriers to accessing its online complaint form, to communicating with the organization using the 1-800 line and to accessing its website. It was also identified that employees needed more tools to better support complainants.

To eliminate these barriers, and to ensure Canadians can have access to OIC’S tools and platform, the organization has:

• Reviewed its complaint form. Simplified and clarified it to make sure it was more accessible (language, font, button, etc.). This new form has been online since July 2023.
• Simplified and clarified menu options for its 1-800 number.
• Developed guidance, writing tips, FAQs and templates for investigators working with the public.
• Simplified and clarified some of its human resources policies, guidelines, and processes.
• Launched an OIC study/survey to seek Canadians’ views on how accessible OIC’s complaint process is.

The OIC will pursue its work to ensure that the solutions identified have the desired effect. The remaining actions listed in the action plan are progressing according to schedule.

Built environment

Goal 2 – Create a safe environment and a workplace free of physical barriers to improve the working environment for all OIC employees of various abilities.

Regarding this goal, the OIC had noted that its evacuation plan needed to be revised to ensure that it was appropriate for the new hybrid working model.

To ensure all employees have equal and fair access to and use of internal infrastructure, the OIC has:

• Implemented a program to help employees with disabilities or conditions that prevent them from evacuating the building safely (a monitor is identified for employees needing help evacuating the building).
• Documented and reviewed evacuation plans for employees with disabilities.
• Made sure the building was equipped with smoke alarms, fire extinguishers, audio/visual alarms and proceeded with annual testing.
• Provided new employees with a manually adjustable work desk. Provided tools, hardware and software to employees who needed accommodation.

The OIC will pursue its work to ensure that working environment is safe and that safety issues are dealt with. The remaining actions listed in the action plan are progressing according to schedule.

Information and communication technologies, Communication (ICT), other than ICT

Goal 3 – Remove barriers for OIC communications products by creating an “accessibility by design” culture, where staff at all levels are aware of requirements.

Regarding this goal, the OIC had identified barriers to accessing its website, and its online complaint form. In addition, some documents created over the past few years (reports, presentations, etc.) were not accessible by design.

To remove these barriers and improve our communications products, and to ensure staff at all levels are aware of requirements, the OIC has:

• Developed guidance, writing tips, FAQs and templates for parties to complaints that are written as simply as possible and encouraged investigators to include plain language in their communications such as emails, reports, etc.
• Shared useful links and documentation related to the creation of “accessible documents by default”, and promoted them internally in the weekly newsletter.
• Provided guidance to employees on inclusive writing and terminology.
• Updated some of the human resources policies, guidelines and procedures using practices that meet accessibility requirements (font).
• Explored methods of offering additional help to Canadians when filling out forms required to access OIC services.

In addition, and as outlined at the beginning of the reported, the organization initiated three actions that were not included in the plan. These were the optimization of accessibility in the creation of training content using “Adobe Captivate” software, and the adaptation and implementation of pedagogical methods that take accessibility into account for both online and face-to-face training.

The OIC will pursue its work to ensure that accessibility toolkit, training and documentation are available to all employees. Also, the organization will continue to raise awareness among employees to ensure that documents created are accessible by design. The remaining actions listed in the action plan are progressing according to schedule.

Goal 4 – Share knowledge and best practices widely to eliminate barriers across the public service.

Regarding this goal, the OIC had observed that some of the tools available to employees, including best practices with regard to accessibility, were not widely known.

To ensure knowledge and best practices are widely shared, the OIC has:

• Created a working committee to monitor the action plan and ensure coordination and sharing of best practices in terms of accessibility.
• Shared with employees new/updated tools and invitations to accessibility-related training and events on the intranet and in its weekly newsletter.
• Held a series of equity, diversity and inclusion conferences to raise employee awareness about the challenges faced by people with disabilities.
• Updated its mandatory training list which will soon be shared with employees.
• Implemented a feedback process for all accessibility-related issues and monitored incoming messages, as well as messages received in the anonymous OIC employee suggestion box.
• Participated in meetings to share best practices (interdepartmental community of practice, internal working committee, experts and partners, etc.)

The OIC will pursue its work to ensure that tips and guidance are provided to all employees on technical aspects of building and maintaining accessibility in documents. The remaining actions listed in the action plan are progressing according to schedule.

Goal 5 – Create a culture of accessibility, where respect and inclusion are embedded in all aspects of the workplace and where all employees are empowered and supported to achieve their full potential.

Regarding this goal, the OIC had identified barriers to accessing specific applications, software and systems.

To remove barriers with respect to this goal, and to ensure all employees are empowered and supported, the OIC has:

• Integrated validation of accessibility requirements into the software development cycle, and into the conformity assessment of new non-standard software applications.
• Worked to offer bilingual tools to employees when purchasing equipment related to accommodation requests.
• Adapted existing systems, such as the customer relationship management (CRM), to make them accessible and to meet Government standards.
• Made sure to offer bilingual tools to users when purchasing hardware and software.
• Equipped all workstations with an electronically adjustable desk and two monitors.
• Began working in partnership with Public Services and Procurement Canada on a project to modernize its premises.
• Provided training to investigators to help them deal with difficult complainants.
• Met with the Accessibility, Accommodation and Adaptive Computer Technology (AAACT) group that supports departments in offering services to the public to identify training opportunities.

The OIC will pursue its work to ensure that its infrastructure, equipment, software meet accessibility requirements, that employees have access to useful training. The remaining actions listed in the action plan are progressing according to schedule.

Employment

Goal 6 – Implement accessible practices to eliminate and prevent barriers to the recruitment, retention, and promotion of persons with disabilities.

Regarding this goal, the OIC had found that some of the tools available to managers to help them make staffing processes even more inclusive were not widely known.

To remove barriers with respect to this goal, the OIC has:

• Provided training opportunities to hiring managers, relating to the amendment to the Public Service Employment Act (PSEA) aiming to strengthen diversity and inclusion that came into force.
• Participated in internal and interdepartmental accessibility committees to acquire tools and develop accessibility expertise in staffing
• Shared Public Service Commission staffing tools with hiring managers.
• Promoted the “Workplace Accessibility Passport” with managers and employees.
• Participated in the Self-Identification Modernization Project led by Treasury Board Secretariat.
• Started working on its orientation program review.
• Provided employees with the ergonomic equipment they need to work safely and effectively in the workplace, following the recommendations of the ergonomic consultant.

The OIC will pursue its work to ensure that tools and training are provided to hiring managers and employees, that internal policies and practices are reviewed to identify systemic and attitudinal barriers to employment opportunities for persons with disabilities. The remaining actions listed in the action plan are progressing according to schedule.

Procurement of goods, services and facilities

As outlined in its accessibility plan, the OIC has entered into a Memorandum of Agreement with the Canadian Human Rights Commission (CHRC) for the OIC’s procurement-related activities. As the contracting authority for the OIC, the CHRC will ensure that procurement-related activities conducted on behalf of the OIC comply with all legal and policy requirements, including the ACA. Accessibility requirements will be part of the procurement process from the outset. More information on the OIC’s procurement-related activities and how these activities meet the requirements of the ACA can be found in the CHRC’s accessibility website.

Transportation

As outlined in its Accessibility Plan, there were no barriers identified under this area for action at the OIC.

Consultations

The OIC’S Accessibility Plan aims to provide a path forward for the OIC to eliminate barriers and adapt to changing demographics and will be updated as new initiatives are introduced. While addressing improvements in the lives of OIC employees with disabilities is paramount, improving service to the public must also be a priority.

To finalize this Progress Report in a consultative manner, the OIC worked in collaboration with accessibility representatives in each sector through its working committee to contribute to the writing of the report. Furthermore, the OIC consulted with internal stakeholders such as members of the Equity, Diversity and Inclusion Advisory Committee, executive committees and, legal services. These consultations which were held through face-to-face meetings, virtual meetings and questionnaires.

Also, the OIC retained the services of Excellence Canada an independent, not-for-profit corporation that is dedicated to advancing organizational performance across Canada to review its accessibility plan for compliance with the Accessible Canada Act and complete consultations on its Progress Report with an advisory committee representing the interests of persons with disabilities. The participants were asked to review the overall progress report and comment on whether all disabilities are considered, if there were adequate progress and if there were anything else that could be included to provide further accessibility. The target group included participants living with different disabilities, such as learning disability, mobility disability, and mental health.

Over the coming year, the OIC intends to hold more consultations, particularly internally through a survey of all employees and focus groups. This will enable the organization to obtain more feedback on accessibility issues by the next progress report and thus ensure that it continues to meet the Act’s requirements.

Feedback

As outlined at the beginning of this report, there are many ways for the organization to receive feedback from both employees and the public. Although the organization has not received feedback through its feedback mechanism, it did gather some information through the consultations listed below. These consultations enabled the OIC to obtain feedback on the following issues: complainant form, 1-800 line, product communications (use of accessible font and format, plain language, etc.), employee awareness, feedback mechanism.

In the coming year, the OIC intends to review its feedback mechanism to ensure that it is both clear and easy to access. This will enable the organization to benefit from more feedback on accessibility issues, and thus ensure that it complies with the Act's requirements.

Conclusion

The OIC’s aim with its accessibility plan is twofold: identify, remove, and prevent accessibility barriers in the OIC’s delivery of services to the public, and continue to address the accessibility needs of its employees.

Moving forward, and in keeping with the “nothing about us without us” guiding principle, the OIC will conduct more consultations with persons with disabilities to ensure that identified solutions have the desired effect, or whether more accessibility features can be incorporated.