CRCC Accessibility Action Plan 2023–2026

1. Message from the Chairperson

As a federal public servant, each employee has the right to an inclusive, respectful and safe workplace with the right tools to succeed in their work. With that said, we are very proud to present our first Accessibility Plan.

This Plan presents actions that will be taken over the next three years, in collaboration with persons with disabilities and the Inclusion, Diversity and Equity Advisory Committee to remove and prevent barriers faced in the workplace.

As the Chairperson of the Civilian Review and Complaints Commission for the RCMP (CRCC), I take great pride in the work that is done at the CRCC. The CRCC has expressed its commitment to integrating employment equity and diversity into its human resource management practices and management accountability mechanisms. This Plan focuses on the concrete steps that the CRCC can take to achieve a just and equitable workplace for persons with disabilities, commencing with the ways we can improve their recruitment, retention and promotion.

The CRCC has identified a departmental Champion for Diversity and Inclusion, Roxane Bériault, Senior Director of the Corporate Services Division. In collaboration, we will be holding ourselves accountable in ensuring we all take an accessibility-by-default approach in all areas.

Over the next three years, we will be focusing on generating momentum through the concrete actions identified in the Plan, and ensuring that the voices of those most impacted are brought to the forefront. By committing to create a barrier-free workplace, we are in turn supporting a diverse, inclusive, healthy and productive workforce at the CRCC.

Michelaine Lahaie
Chairperson, CRCC

2. Message from the Diversity and Inclusion Champion

As CRCC's Diversity and Inclusion Champion, my role consists of enhancing diversity and inclusion, addressing harassment and discrimination, and promoting employment equity and official languages in the workplace.

By advocating for a diverse and inclusive workplace, we are bringing together individuals with different experiences, ideas and perspectives. To be an innovative, creative and resilient team, we need a culture change. Although the CRCC is well represented in the other employment, diversity and inclusion groups, we are underrepresented for the persons with disabilities (PwD) group and are greatly committed to increasing this representation.

It is our concerted duty to ensure that PwD have the tools, resources and policies in place to effectively and equitably succeed in our workplace. I am very proud to champion the CRCC Accessibility Plan for 2023–2026 and help promote the activities outlined. Our vision is to make Canada's public service the most accessible and inclusive in the world, and I am truly thrilled to be part of the solution.

Roxane Bériault
Diversity and Inclusion Champion and Senior Director, Corporate Services, CRCC

3. General

a. Accessibility Statement

Being a diverse, inclusive and accessible employer is a priority at the CRCC. We are committed to creating a barrier-free workplace that will allow the full and equitable participation of persons with disabilities (PwD) in our workforce.

The desired end state through meeting the legislative requirements for the CRCC is to:

• build strong, diverse teams;
• promote fairness, justice and equity;
• advocate for the full participation of PwD in the workforce; and
• establish a barrier-free Canada.

b. Background

Beginning in July 2016, the Government of Canada consulted with more than 6,000 Canadians to understand what an accessible Canada meant to them, as part of the Accessibility Strategy for the Public Service of Canada,^{Footnote 1} led by the Treasury Board Secretariat (TBS). Following these consultations, a clear goal was set to make Canada's public service the most inclusive public service in the world.

On July 11, 2019, the Accessible Canada Act^{Footnote 2} came into effect, with the desired end state to make Canada barrier-free by January 1, 2040. To achieve this goal, each federally regulated entity, including the CRCC, is required to prepare and publish an accessibility plan by December 31, 2022.

It is understood that people who face barriers may not feel comfortable self-identifying as having a disability. Therefore, this action plan uses the terms "persons with disabilities" and/or "PwD" to refer to all persons who face barriers as a result of an identified or unidentified; visible or invisible; permanent, situational or temporary impairment of any type. This is in line with the purpose of the Accessible Canada Act, which is "to benefit all persons, especially persons with disabilities."

Consultations with public servants with disabilities^{Footnote 3} have found that they:

• experience harassment and discrimination at rates that are higher than for other public servants;
• have significantly lower chances for promotion;
• frequently feel disrespected or marginalized where their voices would be critically helpful;
• lack mentorship and role models;
• face extensive barriers to securing a public service job in the first place;
• too often have to explain and justify even the most basic adjustments repeatedly as they move through the public service;
• expend significant energy to have even minimally suitable working conditions; and
• have an exit rate that is almost twice the hiring rate across the federal government.

The CRCC is committed to preventing, identifying, and removing barriers for the people who face them and to create more consistent experiences of accessibility in the following priority areas:

• Improve recruitment, retention and promotion of PwD;
• Enhance the accessibility of the built environment (i.e. the physical work environment);
• Make information and communications technology usable by all;
• Equip public servants to design and deliver accessible programs and services; and
• Build an accessibility-confident public service.

Through a "Nothing Without Us"^{Footnote 4} approach in the development of the CRCC Accessibility Plan for 2023–2026, we are striving for advances in the areas of transparency, collaboration and proactivity. In the fall of 2020, the Inclusion, Diversity and Equity Advisory Committee (IDEAC) was established in the CRCC. It consisted of CRCC employees and ex officio CRCC members, including PwD employees, to provide informed advice and guidance, through the lens of inclusion, diversity, equity and GBA+ analysis, to the Chairperson and the Senior Management Team on issues and/or emerging trends that are important to the work of the CRCC. Through these discussions, successes, barriers, and opportunities have been identified in the priority areas listed above.

4. Strategic Considerations

a. Snapshot of Disability in Canada^{Footnote 5}

• In 2017, one in five (22%) Canadians aged 15 years and over—or about 6.2 million individuals—had one or more disabilities.
• Women (24%) were more likely to have a disability than men (20%).
• Disabilities related to pain, flexibility, mobility, and mental health were the most common disability types.
• Among youth (aged 15 to 24 years), however, mental health-related disabilities were the most prevalent type of disability (8%).
• Among those aged 25 to 64 years, PwD were less likely to be employed (59%) than those without disabilities (80%).
• Among those with disabilities aged 25 to 64 years who were not employed and not currently in school, two in five (39%) had the potential to work. This represents nearly 645,000 individuals with disabilities.

For further information on PwD in the public service, the TBS has developed an infographic^{Footnote 6} showcasing a snapshot of PwD working in the core public administration based on the Government of Canada's Diversity and Inclusion Statistics.^{Footnote 7}

b. Hiring Targets of PwD

In early 2022, the Public Service Commission and TBS provided the CRCC with updated PwD representation rates and hiring targets, as well as an update on progress towards the federal commitment to hire 5,000 new PwD by 2025,^{Footnote 8} taking into account attrition. By committing to these goals, the CRCC population will see an increase in the diversity in the lived experiences of those developing departmental programs, products and services and increasing the inclusivity to meet the needs and expectations of diverse audiences.

Key figures for the CRCC as of 2021–2022 reveal the following:

• Total population (as of March 31, 2022): 75
• Workforce availability (WFA) for persons with disabilities (based on Census 2016 and the 2017 Survey on Disability): 8.8%
• CRCC representation of persons with disabilities: 6.7%
• Gap between WFA and representation: 2%

c. CRCC Accessibility Readiness

The current organizational accessibility readiness in the key priority areas (employment, built environment, information and communications technologies, programs and services and accessibility confidence) was also assessed for the CRCC through the Accessibility Self‑Assessment Tool, developed by the Office of Public Service Accessibility.

d. Diversity and Inclusion at the CRCC

The CRCC will focus on some key focus areas within this Accessibility Plan:

• establish and maintain full representation of all designated groups in all occupational categories;
• making continuous improvements in the execution of its Accessibility Plan; and
• remaining vigilant in addressing PwD issues, present or future.

The strategy outlines three specific objectives:

1. Inclusive Hiring at the CRCC: A proactive approach
2. Unconscious Bias Training: Laying the groundwork for making better staffing decisions
3. GC Workplace Accessibility Passport: Facilitating the movement of PwD into and within the CRCC

The CRCC has implemented tangible actions to increase awareness, change behaviour, and address systemic barriers. In fact, it has implemented the Canada School of Public Service (CSPS) Understanding unconscious bias W005 (INC105) as mandatory training for all employees at all levels, as well as Inclusive hiring practices for a diverse workforce H205 (COR120) for hiring managers and Human Resources advisors. These courses aim to increase awareness and ultimately assist hiring managers in reducing barriers in their staffing processes and to encourage self-awareness with regard to their staffing decisions.

The CRCC will adopt the GC Workplace Accessibility Passport and it has communicated this important initiative through the Inclusion, Diversity and Equity Advisory Committee (IDEAC). All new hires to the CRCC are informed of their right to be accommodated through documents accompanying their letter of offer.

Another example of a tangible action is streamlining the collection process of self-identification data to ensure that all new hires and current employees receive and submit their self‑identification form through PeopleSoft.

e. Roles and Responsibilities

The development and implementation of the Accessibility Plan for 2023–2026 falls on each employee at the CRCC. The chart below outlines the specific roles, responsibilities and expectations over the course of the next three years.

• Diversity and Inclusion Champion: The champion advises and supports the project sponsor in decision-making. The champion is a key advocate for the plan and the changes that come with it. In addition, the champion must build employee morale, engage employees affected by the change, and demonstrate desired behaviours.
• Human Resources Directorate: The Human Resources Directorate is responsible for the development, promotion and implementation of the CRCC Accessibility Plan for 2023–2026. In collaboration with the IDEAC, they will ensure that the actions outlined in the plan are assigned to the appropriate groups and lead frequent progress check-ins. The Human Resources Directorate will also lead the development of the Key Performance Indicators, in collaboration with the IDEAC, to ensure that progress is monitored and opportunities for improvement are identified.
• IDEAC: The Inclusion, Diversity and Equity Advisory Committee has key roles in the overall implementation of the Plan, including to:
  • identify priorities and actions to be included in the Plan;
  • provide advice on disability issues, inclusion and accessibility that will be used in the Plan; and
  • review and provide feedback on the drafts of the Plan.
• Governance: The CRCC corporate governance will be consulted periodically to provide strategic direction or make recommendations, as required, about actions set out in the Plan. The governance bodies consulted include the:
  • CRCC Senior Management Committee;
  • IDEAC.
• Managers: A manager's role will expand beyond daily operational duties. They play a vital role in employees' adoption and acceptance of a culture that supports accessible day-to-day operations. Managers will be communicators, advocates, coaches, liaison and active proponents of accessibility.
• Employees: All employees play a part in the success of the CRCC Accessibility Plan. To foster an accessible culture within our workforce, employees should:
  • adopt the behaviours encouraged in the Accessibility Plan;
  • advocate change by soliciting interest and support; and
  • openly communicate with management about any concerns/barriers, or potential opportunities.

5. Pillars and Actions

A joint effort with the senior management team, the Inclusion, Diversity and Equity Advisory Committee (IDEAC) and the Human Resources Directorate will be taken to ensure that these actionable items are implemented over the course of the next three years (2023–2026).

5.1 Improve recruitment, retention and promotion of persons with disabilities

To improve the recruitment, retention and promotion of persons with disabilities, the CRCC commits to:

1. Closing the 2% gap between the workforce availability of persons with disabilities and their representation within the CRCC by March 31, 2024, by:
   • leveraging existing GC programs (e.g. Federal Internship Program for Canadians with Disabilities, Federal Student Work Program, FSWEP program for student with disabilities, Virtual Door to Talent with Disabilities);
   • identifying PwD in existing pools to hiring managers; and
   • reviewing representation, identifying gaps in specific occupational groups, and creating targets.
2. Informing employees about, and promote the use of, Shared Services Canada's Lending Library Service Pilot Project, which offers personalized supports for students and other short‑term employees with disabilities or injuries, including adaptive technology, services and tools.
3. Co-developing a Mentorship Plus Program with interested employees of employment equity and equity-seeking groups.
4. Hosting speakers from the Federal Speakers' Forum on Diversity and Inclusion twice yearly. The Forum "is a platform for public servants to share their lived experience with diversity and inclusion, accessibility and other related topics."
5. Increasing management awareness (e.g. through mandatory training, workshops, information sessions) to ensure they are equipped in supporting their PwD employees in their work, performance and career aspirations; and
6. Ensuring PwD have equal access to career advancement opportunities (e.g. assignment, promotions, developmental).

5.2 Enhance the accessibility of the built environment

The built environment pillar focuses on the physical work environment, and the equipment and tools available within. All individuals deserve access to an equitable and safe work environment.

Public Service and Procurement Canada (PSPC) is responsible for managing and providing government organizations and parliamentarians with federal property and accommodation services. In support of this, PSPC is undertaking an evaluation of the physical accessibility of federal buildings in consultation with persons with disabilities.

PwD report challenges in their workplaces, such as a lack of automatic door openers, poor signage and way-finding. In the first survey on the development of the Strategy,^{Footnote 9} several respondents noted that the physical workspace does not account for invisible disabilities, such as:

• environmental sensitivities
• chronic pain
• anxiety
• autism

To enhance the accessibility of the built environment, the CRCC commits to:

1. Pursuing two approaches when considering how to meet the Strategy and comply with the Accessibility Plan:
   • Apply binding requirements (i.e. directives, leases, etc.);
   • Solicit and consider practical and lived experiences.
2. Determining and considering the exact relationships and stakeholders implicated by the current leases, to include, among others, the CRCC, the landlord, PSPC, employees with disabilities, clients with disabilities, and other government departments.
3. Reviewing the terms of current agreements for built environments for terms applicable to accessibility, and ensuring that such terms are assessed against the standards cited by the Strategy and the Directive.
4. Engaging with appropriate stakeholder groups about the overall built environment, to include persons with disabilities, to determine areas of concern, and to ensure the suitability of established standards, or to establish higher standards.
5. Internally publicizing the efforts to engage with appropriate stakeholders and solicit their input.

5.3 Make information and communications technology usable by all

The Accessibility Strategy's overarching goal for communications and technology is that "Government of Canada clients and employees can access and use all information and communications technology, regardless of ability or disability." The research done by the IDEAC identifies both barriers to use of technology, as well as an action plan to overcome these obstacles to make the CRCC a more accessible workspace.

Barriers to communications and technology have been identified by Canadians in the workplace through the Accessible Canada – Creating new federal accessibility legislation: What we learned from Canadians report. Namely, information being impossible to access, read or understand, due to the way it is presented, or the technology and equipment being used to access it. Furthermore, civilians involved in the research pointed to government spending as a barrier to obtaining proper technology to enhance an accessible workspace.

The IDEAC looks to courses like the Accessibility, Accommodation and Adaptive Computer Technology (AAACT) Program as an opportunity for the CRCC's supervisory staff to undergo sessions on adaptive technology, job accommodations, accessibility testing and more. The AAACT Program's goal is to, "help integrate employees with disabilities, injuries and ergonomic requirements and who require access to systems, programs, information, computers and computer resources."

The range of services AAACT offers stretch from hands-on training for technicians, to web content evaluations, converting documents to multiple formats, and providing needs-based assessments. With this course being required of all supervisory staff, a collective understanding of adaptive computer technology would be the standard here at the CRCC. This would ensure that those seeking accommodations are met by colleagues who retain some background knowledge of adaptive computer technology, so that the 'gatekeepers' of the accommodation process are comfortable and familiar with the range of technological accommodation possibilities.

Another way to ensure the CRCC is a comfortable and accommodating workspace is to embed accessibility into our standardized processes. The Digital Accessibility Toolkit is a great resource to rely on; for technology and communications, accessible standardized processes might look like:

• using standardized heading-styles rather than bolding words;
• ensuring hyperlinks are titled rather than copy and pasted URLs;
• avoiding the use of text boxes;
• ensuring photos (e.g. emails, CRCC website) have 'alternative text.'

To make information and communications technology usable by all, the CRCC commits to:

5.3.1 Requiring that its managers and IT staff attend comprehensive AAACT sessions to familiarize themselves with adaptations and troubleshoot their application to the CRCC's technology; this will ensure they have the required education when someone approaches them with accessibility concerns.

5.3.2 Ensuring that the CRCC's webpage/InfoExpress is fully accessible through both desktop and mobile devices.

5.3.3 Circulating and implementing new standards for shared documents in alignment with the Digital Accessibility Toolkit.

5.4 Equip public servants to design and deliver accessible programs and services

There is limited data on the accessibility of the Government of Canada's programs and services to clients. However:

• findings from Employment and Social Development Canada's 2017 Client Experience Survey^{Footnote 10} revealed that clients with restrictions (whether hearing, seeing, mobility, cognitive/mental health or other) have a 67% overall satisfaction rate when accessing services, compared with 87% for all clients;
• these clients report that they have more difficulties than other clients with ease, timeliness and effectiveness in accessing services.

During consultations for this Strategy, many public servants expressed a need for more tools and training to better serve clients with disabilities.

To equip the CRCC's employees to design and deliver accessible programs and services, the CRCC commits to:

5.4.1 Considering the feasibility of developing a client-satisfaction data strategy for the services delivered directly to the public by the CRCC (particularly by the Intake and Review units), keeping in mind the particular challenges associated with this type of survey given the emotionally charged content and services.

5.4.2 Considering new ways to monitor how accessibility influences the discretionary functions of the CRCC's mandate when making decisions with respect to public complaints. While the CRCC does not issue grants or contributions to recipients, this category could extend to discretionary refusals or exceptions (e.g. complaints or review requests that fall outside of the time limit). Additionally, the demographics of employees receiving Instant Recognition Awards could be monitored.

5.4.3 Consulting with external organizations of persons with disabilities and disability advocacy organizations to assess the CRCC's current programs, with specific attention to direct service providers.

5.4.4 Continuing to consult with the above-indicated organizations and groups when designing and implementing new programs and services.

5.5 Build an accessibility-confident public service

Accessibility is generally not integrated into the everyday business of the public service. It is often treated as an afterthought and, although there are some accessibility initiatives, these are often siloed. There are few mechanisms for departments and employees to share best practices.

In an accessibility-confident public service, public servants will understand what accessibility means and why it matters, and have the resources to make the public service a more accessible and inclusive employer and service provider.

To build an accessibility-confident public service, the CRCC commits to:

1. Developing and disseminating communication products to raise the awareness of CRCC employees about:
   • - The definitions of "disability" and "accessibility";
   • - The new Accessible Canada Act and the rights it provides; and
   • - The new Office of the Accessibility Commissioner and its role in receiving, investigating and ruling on complaints filed under the Accessible Canada Act.
2. Inviting the Accessibility Commissioner to present to the CRCC.
3. Ensuring all its processes relating to the employment, retention, and/or promotion of an employee with a disability use inclusive language and do not create barriers for persons with disabilities.

6. Monitoring Progress

The implementation of the CRCC Accessibility Plan for 2023–2026 is an important step in the CRCC's commitment to an equitable workplace for PwD, and creating an organizational culture that recognizes, understands and works together for, and in collaboration with, PwD.

As we move forward, consultation will continue with subject matter experts, internal and external stakeholders and the IDEAC to ensure that the CRCC is equipped with the right knowledge to implement the vision (the Accessibility Statement), eliminate barriers, and put the proposed actions into place. Successful implementation of the Plan will not only be measured through meeting the hiring targets by 2026 but through organizational performance.

Organizational performance is defined as the department's implementation of the tools and activities as defined in the strategic framework. By 2026, the goal is to ensure that the CRCC is transformed to reach the future desired state.

Data sources that will be used in the collection of data and the development of performance indicators include the following:

• Accessibility Self-Assessment Tool
• Public Service Employee Survey (PSES)

The Human Resources Directorate will report on progress made on the Accessibility Plan to CRCC senior management on an annual basis as well as to central agencies, when required.

7. Annexes

7.1 Annex A: Definitions

Barrier means anything—including anything physical, architectural, technological or attitudinal, anything that is based on information or communications or anything that is the result of a policy or a practice—that hinders the full and equal participation in society of persons with an impairment, including a physical, mental, intellectual, cognitive, learning, communication or sensory impairment or a functional limitation (obstacle).

Discrimination means treating someone differently or unfairly because of a personal characteristic or distinction, which, whether intentional or not, has an effect that imposes disadvantages not imposed on others or that withholds or limits access that is given to others. There are 13 prohibited grounds of discrimination under the Canadian Human Rights Act (i.e. based on race, national or ethnic origin, colour, religion, age, sex, sexual orientation, gender identity or expression, marital status, family status, genetic characteristics [including a requirement to undergo a genetic test, or disclose the results of a genetic test], disability or conviction for an offence for which a pardon has been granted or in respect of which a record suspension has been ordered).

The Duty to Accommodate is part of the Canadian Human Rights Act and requires employers to implement necessary measures to allow employees to perform their duties to the best of their abilities. These measures need to be undertaken in a timely fashion while respecting the privacy of the individual who requires them.

Harassment is normally a series of incidents, but it can be one severe incident that has a lasting impact on the individual. Harassment is any improper conduct by an individual that is directed at and offensive to another individual in the workplace, including at any event or any location related to work, and that the individual knew or ought reasonably to have known would cause offence or harm. It comprises objectionable act(s), comment(s) or display(s) that demean, belittle, or cause personal humiliation or embarrassment, and any act of intimidation or threat. It also includes harassment within the meaning of the Canadian Human Rights Act (i.e. based on race, national or ethnic origin, colour, religion, age, sex, sexual orientation, gender identity or expression, marital status, family status, genetic characteristics [including a requirement to undergo a genetic test, or disclose the results of a genetic test], disability or conviction for an offence for which a pardon has been granted or in respect of which a record suspension has been ordered).

A micro-aggression is a statement, action, or incident regarded as an instance of indirect, subtle, or unintentional discrimination against members of a marginalized group such as a racial or ethnic minority.

Plain language is a writing technique of organizing information in ways that make sense to the reader. It uses straightforward, concrete, familiar words. Plain language helps the writer adapt what they have to say to the reading abilities of the people who are most likely to read the document. 

Workforce availability refers to the estimated availability of people in designated groups as a percentage of the workforce population. For the core public administration, workforce availability is based on the population of Canadian citizens who are active in the workforce and who work in those occupations that correspond to the occupations in the core public administration.