2024 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 2024

Contents

• Executive summary
• General
• Areas in section 5 of the ACA
• Programs and services
• Built environment
• Information and communication technologies (ICT); and communication 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 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 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: These sections provide progress made implementing OIC’s action plan.
• Consultations: This section includes a description of how the 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 Senior Director, Human Resources, ATIP and Corporate Governance 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 formats, 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:

The following sections 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. In 2022-2023 the focus was on setting up a monitoring structure for the action plan, and raising awareness among employees, while last year (2023-2024) focused on consultations. As you will see from the report, the OIC managed to accomplish a considerable amount of work. All the planned actions have been initiated, some are in progress, and several have even been completed. In addition to all this work, a few unplanned actions were initiated.

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.

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.

Over the past two years, the OIC has been working to eliminate barriers, and to ensure Canadians have access to OIC’S tools and platforms. For 2023-2024, the organization has:

• Published the “Policy: accommodation when receiving services from the Office of the Information Commissioner” on its website.
• Added updated menu options for its 1-800 number in many locations. The organization will also include additional information on new web pages as needed.
• Promoted guidance, writing tips, FAQs and templates, the Digital Accessibility Toolkit, the Accessibility Hub on GCpedia, and the Accessibility glossary on Termium Plus, to all employees, including investigators.
• Identified and promoted accessibility training available through the Canada School of Public Service (PSPS) to all employees, including the investigation group.
• Introduced new styles with improved accessibility to be used in its templates for investigators working with the public.
• Simplified and clarified some of its human resources policies, guidelines, processes, and templates.
• Completed a study/survey to seek Canadians’ views on how accessible OIC’s complaint process is, and published the report on its website.
• Consulted with all employees, including persons with disabilities, through a questionnaire. Further consultation will take place to ensure a more in-depth understanding of the results.

The OIC will pursue its work to ensure that the solutions identified have the desired effect.

The following table shows the status of the actions related to this objective.

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.

The OIC had identified barriers related to the evacuation plan, which had not been adjusted to the reality of the new hybrid working model, and which did not consider the specific needs for employees with disabilities such as having a colleague available to assist that is physically present at the office at the same time.

Over the past two years, the OIC has been working to ensure all employees have equal and fair access to and use of internal infrastructure. For 2023-2024, 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).
• Implemented 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 the working environment is safe and that safety issues are dealt with.

The following table shows the status of the actions related to this objective.

Information and communication technologies (ICT); and communication 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.

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.

Over the past two years, the OIC has been working to remove these barriers improve our communications products, and to ensure staff at all levels are aware of requirements. For 2023-2204 the organization has:

• Developed internal and external guidance and training material (legal guides) ensuring that legal concepts are explained in plain language.
• Shared useful links and documentation on creating “accessible documents by default, and promoted them internally on the intranet and in the weekly newsletter.
• Provided training and guidance to employees on inclusive writing and terminology.
• Updated some of the access to information and privacy and 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.
• Started a project to develop and implement a process for managing accommodation requests made by parties to a complaint.

In addition, and as outlined at the beginning of the report, the organization has initiated actions that were not originally included in the plan. For example, it has optimized accessibility in the creation of training content using “Adobe Captivate” software. It has also adapted and implemented pedagogical methods that take accessibility into account for both online and face-to-face training. Finally, the OIC made sure all email templates/products for Registry and investigators are accessible (including headings and graphics).

The OIC will pursue its work to ensure that accessibility toolkits, 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 following table shows the status of the actions related to this objective.

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

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

Over the past two years, the OIC has been working to ensure knowledge and best practices are widely shared. For 2023-2024 the organization has:

• Shared with employees new/updated tools and invitations to accessibility-related training and events on the intranet and in its weekly newsletter.
• Offered orientation session to new employees to share principles of the Government Policy on Communications.
• Held a series of equity, diversity and inclusion conferences to raise employee awareness about the challenges faced by persons with disabilities.
• 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 following table shows the status of the actions related to this objective.

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.

The OIC had identified barriers to accessing specific applications, software and systems.

Over the past two years, the OIC has been working to remove barriers with respect to this goal, and to ensure all employees are empowered and supported. For 2023-2024, the organization has:

• Worked to offer bilingual tools to employees when purchasing equipment.
• Equipped all workstations with Microsoft Office 365, which offers a wide range of accessibility features designed to make it easier for everyone to use its applications. Key accessibility features include: Immersive reader, Accessibility checker, live captions and transcripts, dictate, alt text for images, and keyboard shortcuts.
• Continued to work in partnership with Public Services and Procurement Canada on a project to modernize its premises.
• Provided training to investigators and lawyers to help them deal with difficult complainants.

The OIC will pursue its work to ensure that its infrastructure, equipment, software meet accessibility requirements, and that employees have access to useful training. For example, although work was done in 2022-2023 to integrate validation for accessibility into the software development cycle and to add accessibility to the compliance assessment for new non-standard software requests, the OIC will continue to work to formally integrate this into its documentation.

 The following table shows the status of the actions related to this objective.

Employment

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

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.

Over the past two years, the OIC has been working to remove barriers with respect to this goal. For 2023-2024, the organization has:

• 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.
• Created the “GUIDE – Identifying Biases and Barriers in Assessments” to ensure that hiring managers identify and eliminate barriers throughout the staffing process.
• Participated in the Self-Identification Modernization Project led by Treasury Board Secretariat.
• Continued to work 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.
• Reviewed available workforce data and is in the process of planning next steps to ensure that persons with disabilities have access to its employment opportunities.

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.

The following table shows the status of the actions related to this objective.

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 ensure that procurement-related activities conducted on behalf of the OIC comply with all legal and policy requirements, including the ACA. Accessibility requirements are part of the procurement process from the outset. For example, the OIC has reviewed documents such as its Manager's Guide to Contracting for Goods and Services, as well as its “Statement of Work (SOW)” template in 2023-2024 to ensure that accessibility criteria are met wherever possible when awarding contracts. Managers issuing contracts this year considered accessibility criteria when analyzing, evaluating and drafting their contracts.

Also, a procurement representative participated in a training session on “How to consider and integrate accessibility in procurement” offered by Public Services and Procurement Canada’s (PSPC) Accessible Procurement Resource Centre and Shared Services Canada’s (SSC) Accessibility, Accommodation, and Adaptive Computer Technology program (AAACT). This training had provided tools and guidance to better support managers when issuing contracts. It covered the following topics:

• what accessible procurement means;
• the role of Business Owners (client department or agency, Technical Authority) and Contracting Authorities in considering accessibility in federal procurement;
• the steps to consider and integrate accessibility in procurement; and
• where to find resources and get help.

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 specific barriers identified under this area for action at the OIC. The organization does not have a fleet of vehicles to use for its employees. In addition, business travel has been rather limited since the pandemic. Although some employees occasionally travel to attend events in person, many attend events virtually.

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.

As mentioned in its last Progress Report, the OIC aimed to hold more consultations in 2023-2024, particularly internally to learn more about employees’ experiences of accessibility in the workplace. To this end, a questionnaire was developed and sent out to all employees, including those who live with a disability. There were 30 questions, and some were open to all employees, while others were specific to employees who live with a disability (self-identified or non-self-identified). The questionnaire was open from July 18, 2024, until September 7, 2024, giving participants 52 days to answer and ensuring everyone had a chance to respond. Employees were offered the option of answering the questions in a different format (e.g., by phone or email), but no such request was made.

Participants were asked to identify any barriers they were experiencing in their day-to-day work with respect to the seven areas identified in Section 5 of the ACA. The target group included persons with different disabilities, such as challenges with flexibility or dexterity, learning disability, hearing disability, sensory or environmental disability, mobility disability, chronic health condition or pain, cognitive disability and mental health disability. The organization is currently analyzing the results of the questionnaire and will continue to consult through focus groups and one-on-one meetings in the coming weeks to gather more information. This will allow it to complete its analysis, draw conclusions and develop an action plan.

While addressing improvements in the lives of OIC employees with disabilities is paramount, improving service to the public must also be a priority. This is why the OIC also consulted with complainants this year with respect to its complaint process. An independent third party conducted a confidential consultation process with complainants, seeking their input through an on-line questionnaire and focus groups. A final report of the findings and recommendations was prepared for Senior Management consideration in March 2024, and the final report and OIC’s response was published on the OIC’s website in November 2024.

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 were conducted using a variety of methods, including written communications as well as, face-to-face and virtual meetings.

Over the coming year, the OIC intends to pursue further consultations to get more feedback on accessibility. As a result, this will enable the organization to identify which barriers should be addressed in the next Accessibility Plan, and to 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 OIC to receive feedback from both employees and the public. Although the organization has not received feedback through its official feedback mechanism, it did gather some information through the consultations. These consultations enabled the OIC to obtain feedback on the barriers encountered by employees.

Finally, the organization has also created a new intranet page on accessibility, making it easier for employees to access the feedback mechanism and other useful information. This will also enable it to benefit from increased 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 alternatively, whether more accessibility features can be incorporated. The feedback received through the consultation will allow the organization to prioritize what needs to be addressed in its next accessibility plan.