The Canadian Human Rights Commission's Accessibility Plan 2023 to 2025

General

Our commitment to accessibility

The Canadian Human Rights Commission is working hard to be an accessible and inclusive organization. As Canada's national human rights institution, Canada's human rights watchdog, and as the home to Canada's Federal Accessibility Commissioner, we take this responsibility seriously.

We know we have much work ahead to become a barrier-free organization. We will approach this responsibility by listening, learning and taking action.

We are working with the key principle of “Nothing Without Us.”

As we work to put this plan in place, we will continue to count on feedback from our employees, rights holders and people with lived-experience, and other stakeholders.

We will work hard to put this plan in place in a way that respects the principles of the Accessible Canada Act:

• dignity;
• equal opportunities;
• barrier-free access;
• meaningful options;
• involving people with disabilities in the development and design of our policies, programs, services and structures;
• recognizing that people can be excluded and discriminated against for more than one reason at the same time (intersectionality); and
• achieving the highest level of accessibility.

Together, Commission employees from all levels of the organization are working to implement this Accessibility Plan. We will implement the Plan in partnership with other Commission-wide efforts we are taking towards anti-racism, equity and inclusion.

Our Accessibility Plan will ensure that the work we undertake to achieve accessibility excellence is sustainable, transparent, and spans the areas of accessibility outlined in the Accessible Canada Act.

This Accessibility Plan is our formal pledge to everyone we employ and everyone we serve that the Commission is committed to creating environments, services and experiences where everyone can belong, and everyone feels valued and respected.

How we will make the Plan a reality

The Commission is taking steps to achieve the commitments, goals and actions in our Plan. We are doing this through:

• strong leadership that is accountable and provides visible and sustained support and direction;
• inclusive policies, processes and practices that ensure accessible program design and service delivery;
• meaningful engagement that enables people to have a voice and helps us be informed and responsive; and,
• on-going training, some of which will be mandatory, to give our employees the knowledge and tools to be leaders in accessibility.

Strong leadership

Accessibility is an organizational priority for the Commission, including our efforts to build a strong governance structure for accessibility. Our initiatives include:

• creating a committee and/or working groups to promote inclusion, diversity, equity and accessibility;
• appointing an executive Champion for People with Disabilities and Accessibility; and
• adding people with lived experience and/or expertise in accessibility, including employees and partners with specialized expertise, to our internal services units such as information management and technology and communications, and to our committees and working groups.

Our leadership helps the Commission meet its responsibilities for accessibility by:

• supporting the accessibility commitments, goals and actions in the Plan through their decision-making;
• promoting accessibility by engaging employees, rights holders and people with lived-experience, other stakeholders, and the public; and
• being accountable for the progress of the commitments in the Plan through their performance agreements.

Inclusive policies, practices and processes

The Commission will develop an accessibility policy that will:

• reflect the principles underlying the Act; and
• guide us on how we design and deliver our programs and services, and how we communicate to our employees and the people we serve.

Our accessibility policy will also help us integrate accessibility into our new and existing policies, practices and processes in a sustainable manner, and make it an organizational priority.

Meaningful engagement

In the spirit of Nothing Without Us, the Commission is committed to participating in public discussions on accessibility as part of its engagement on equity, diversity, and inclusion.

Here are some of the initiatives we have undertaken:

Guidelines for External or Stakeholder Engagement: to ensure that engagement activities are designed to be accessible and that they create opportunities for participants to freely express their views. Engagement activities will also consider the impacts on diverse groups of people based on intersecting factors such as disability, gender, race, ethnicity, and religion.

Interim Policy on Stakeholder Compensation: to acknowledge the valuable contribution that rights holders, people with lived-experience and other stakeholders make to the Commission's understanding of human rights issues and to the design and delivery of our programs and services. This policy is interim and we will replace the policy with any future Treasury Board of Canada policy, directive or guideline.

Internal Consultations: to consult employees with disabilities on policies, processes and practices that affect them. We will also consult on the Commission's Accessibility Plan and progress reports.

National network to advance disability inclusion: to advance disability inclusion through consultation and sharing of information with rights holders and people with lived-experience, stakeholders, and allies.

Targeted engagement with Indigenous, Black and other racialized people with disabilities: to help us promote awareness of our work and to design and deliver our programs and services as we modernize our complaint form. The Pro Bono Students Canada's Indigenous Human Rights Program is one example.

An intersectional framework to monitor the implementation of the United Nations Convention on the Rights of Persons with Disabilities (CRPD): to ensure the perspectives and priorities of Indigenous, Black and other racialized people with disabilities are reflected throughout our CRPD monitoring work.

Regular training

The Commission will develop a training roadmap and use training courses and events to strengthen our culture of accessibility and disability inclusion.

Our training will ensure that all employees at the Commission:

• have access to learning opportunities about accessibility and disability inclusion that promote awareness and self-development;
• understand how ableism and unconscious bias influence their thoughts, actions and decisions;
• have the competencies needed to support a culture of accessibility and disability inclusion; and
• are encouraged to participate in continuous learning and have it recognized as part of their performance.

Feedback

How to provide your input

The Commission recognizes the vital role that people with disabilities, our employees, people who use our services, and other interested members of the public play in helping us to identify, remove and prevent barriers.

You can use our feedback process to share your comments and ideas. We invite your feedback on:

• our Accessibility Plan;
• how we are putting the plan in place;
• any barriers that you may encounter when working for us or in communicating with us or accessing our programs and services; and
• our feedback process.

The Accessible Canada Act requires us to publish annual progress reports for the next 2 years and to develop a new plan in 3 years. We will use this feedback to produce our progress reports and to create our next Accessibility Plan.

We have designated our Director General, Corporate Management Branch, to receive feedback on behalf of the Commission.

You can send feedback anonymously or you can include your name and contact information. You can provide feedback in the following ways:

• Send an email to info.com@chrc-ccdp.gc.ca
• Call by telephone at 1-888-214-1090 or by TTY at 1-888-643-3304
• Use Video Relay Service at Canada VRS
• Mail us at: 344 Slater Street, Ottawa, ON, K1A 0N7

We will confirm that we have received your feedback.

Alternate Formats

You can ask for a copy of our Accessibility Plan or a description of our feedback process in one of these alternate formats:

• Print
• Large print
• Braille
• Audio format
• Electronic formats

We will send you the document within 15 days. For Braille and audio formats, we will send them to you within 45 days.

Consultations

What we have heard so far

The Commission has been consulting people with disabilities for many years.

As an example, in January 2016, the Commission consulted with people with visual disabilities and disability organizations on advancing the human rights of blind Canadians. This resulted in a series of annual follow up conference calls. In late October 2018 an additional consultation was held and focussed on our complaints services. The consultations identified barriers, and provided guidance on how to remove them. You can learn more about this in section 6. Design and Delivery of Programs and Services.

Another example was the Commission's Discrimination Prevention Forum, Beyond Labels. The forum challenged people's thinking about the labels we use to describe each other and ourselves. It was the start of many discussions about how human rights relate to technology, institutions, workplaces, and public spaces. Many of the people who attended the 2017 Beyond Labels conference told us it was the most accessible event they had ever attended.

In May 2021, the Commission held a virtual discussion with representatives from disability organizations. The objective of this event was to introduce participants to the Chief Commissioner of the Canadian Human Rights Commission (CHRC), the Chair of the Canadian Transportation Agency (CTA), the Chair of Canadian Radio-television and Telecommunications Commission (CRTC), the Chair of the Federal Public Sector Labour Relations and Employment Board (FPSLREB) and the Chair of Canadian Human Rights Tribunal (CHRT). The Chairs of these agencies spoke about their commitment to collaboration under the Accessible Canada Act and their work on the “No Wrong Door” approach to complaints and asked questions about the barriers people face when filing complaints.

Consulting for the Plan

The Commission places a lot of importance on consulting with people in a way that is meaningful, accessible and inclusive.

As a first step, we completed four external reviews. Each review assessed our current levels of accessibility, identified barriers and suggested ways to remove and prevent them. Employees with disabilities, and disability organizations helped us complete these reviews. We used this work to develop this plan.

As a second step, we held consultations with our employees. Of the people we talked to, some have disabilities, some are racialized, and some are represented in other equity deserving groups.

For our external consultations, we sent invitations to people with disabilities and several disability organizations. We also invited members of our Network for Advancing Racial Equality to ensure an intersectional lens.

The following individuals and organizations, who represent a cross-sectional lens of disability and advocacy for equality, diversity and inclusion, participated:

• Alliance for Equality of Blind Canadians
• B.C. Aboriginal Network on Disability Society / Indigenous Disability Canada
• Canadian Association of the Deaf
• Confédération des organismes de personnes handicapées du Québec
• Council of Canadians with Disabilities
• Hauser & Associates Ltd.
• Health Canada, Network for persons with disabilities
• Inclusion Canada
• Institut National pour l'Équité, l'Égalité et l'Inclusion des personnes en situation de handicap
• Make a Difference Through Inclusion Ltd.
• National ME/FM Action Network
• Ontario English Catholic Teachers Association (representative for equality, diversity and inclusion)
• Procne Navigation
• Regroupement des activistes pour l'inclusion au Québec
• A representative from Service Canada
• The Mosaic Institute

We thank all those who shared their ideas and suggestions during the consultations. Thanks to their input we were able to strengthen our draft plan by:

• identifying additional barriers;
• defining additional actions to remove and prevent barriers;
• adding clarity; and
• identifying ways for the Commission to achieve higher levels of accessibility.

For our internal consultations, we consulted members of our three accessibility working groups, employees with disabilities, and members of our internal Decolonization and Anti-Racism Consultation Committee.

What we consulted on

We asked participants to comment on the barriers that we had identified, and the short, medium and long-term actions we planned to take to remove barriers and prevent new ones. We also asked participants to identify barriers they have encountered in employment and in accessing the Commission's programs, services and information that were not already identified in the draft plan.

When we consulted

The Commission's consultations have been guided by the principle of “Nothing Without Us”. We have sought the advice of our employees with disabilities, other individuals with disabilities, and disability organizations, beginning in the early days of developing our Plan up to the end of October 2022 when we held our final consultations.

How we consulted

The Commission ensured the consultations were inclusive and accessible. We provided the option for people to participate virtually or through written comments. This facilitated participation by those in different geographic regions and those without effective Internet access.

We ensured that our consultations were accessible by:

• inviting participants to identify their accommodation needs and addressing these in advance;
• using an accessible meeting platform;
• providing technical support where needed;
• providing CART services (instantaneous translation of what is being said into print so that it can be read);
• providing both American Sign Language (ASL) and Langue des signes québécoise (LSQ) sign language interpretation; and,
• making sure the documentation shared in advance of the meetings was accessible.

What we heard

During our external consultations, many shared their vision of accessibility, which was similar to the Commission's vision.
Stakeholders and rights holders shared some of the challenges they face when representing people with disabilities. They asked the Commission to do more to amplify their voices.

They provided thoughtful feedback regarding the Commission's draft accessibility plan. Some expressed support for the Commission's commitments in the plan, while others asked the Commission to go further.

During our external consultations, we heard the importance of:

• leading by example as a National Human Rights Institution when it comes to accessibility;
• developing a strong training work plan to ensure a culture of accessibility and on-going training to address unconscious bias and internalized ableism;
• consulting with persons and disability organizations who have or who represent a wide range of disabilities;
• emphasizing intersectionality in the Commission's accessibility plan;
• applying not only a human rights lens but also an accessibility lens to the development of the Commission's accessibility plan and its tools;
• ensuring employment offers and other documents are accessible by default and that internal systems are accessible;
• strengthening our accommodation policy and process to ensure supports are in place to ease the burden of self-identification and addressing the concept of colliding accommodations;
• collecting disaggregated data;
• using the term “rights holders” and not just “stakeholders” where appropriate;
• simplifying and improving our complaints process - user testing is positive but co-designing is better;
• consulting employees with disabilities when the Commission develops internal policies, procedures and tools, as well as rights holders where appropriate;
• addressing communication gaps between the Commission and First Nations communities;
• highlighting the need for accessible methods of communications including the use of plain language;
• engaging with organizations, not just consulting them, and;
• highlighting the best practises the Commission has already taken related to disability and accessibility, including:
  • developing a scent free policy which is communicated to all employees through their letter of offer and to contractors through their contracts;
  • partnering for many years with Live, Work, Play, a not for profit organization that assists individuals with intellectual disabilities, autistic persons, and individuals with a dual diagnosis, by providing employment opportunities at the Commission; and
  • having a service animal relief station.

The areas of our Accessibility Plan

The Commission is committed to identifying, removing and preventing barriers for our:

• employees,
• clients,
• rights holders and stakeholders, and
• members of the public.

This includes barriers that make it hard to communicate with us or use our services.

We have done internal and external reviews and audits, and consulted widely on our Plan. The results have helped us develop the goals and actions for removing barriers noted in this plan.

The results also showed us how to prevent barriers. We will prevent barriers in the future by:

• training employees;
• making necessary changes to our policies, practices and processes; and
• making changes to our built environment.

Where possible, we will take immediate action to remove barriers by December 31, 2023.

For barriers that will be harder to remove, we have set medium-term and long-term goals.

We have organized the following planned actions according to the seven areas of accessibility outlined in the Accessible Canada Act.

1. Employment

Our goal is to create a workplace that includes, empowers and supports everyone. This includes every aspect of employment: recruitment/onboarding, career development, promotion, and departure.

Hiring people with disabilities

The proportion of people with disabilities working at the Commission (representation) is higher than the number of people with disabilities available to work in the sector (availability). This means the Commission does not have any employment equity gaps related to people with disabilities.

However, we value diverse representation and life experiences in our work force. To help encourage diverse representation, we commit to:

• exceeding our representation in employment equity for people with disabilities;
• asking disability organizations to promote job opportunities that people external to government can apply to; and,
• prioritizing job opportunities for people with disabilities should there be a gap in representation in the future.

Improving our employment processes and practices

Internal working groups and external assessments done by an accessibility expert, and an expert in rehabilitation and work, identified these barriers:

• additional training on accommodation processes and practices would be helpful to managers and employees; and
• recent changes to the Public Service Employment Act that are meant to further reduce barriers and strengthen diversity and inclusion, including for people with disabilities, have not yet been included in the Commission's hiring processes and practices. For example, hiring managers will proactively inform candidates that they can submit exams in an alternate format.

We have also identified some goals and actions to improve our employment processes and practices, and we hope that by improving the following, we will prevent new barriers in the future by:

• promoting the hiring of more people with disabilities;
• ensuring that every employee can grow and move ahead in their career; and
• updating our guide on exit interviews so that managers engage with employees with disabilities who are leaving to get their views on any challenges, barriers and opportunities for improvement.

Immediate goals and actions (2023)

• 1.1 Ensuring we provide accommodation in a respectful, effective and timely manner. Developing a step-by-step plan to remove any accommodation barriers. This will ensure we consistently meet accommodation needs across the organization. As part of this work, we will:
  • review the results of our participation in a pilot project to implement a Government of Canada “workplace accessibility passport.” The passport documents the specific accommodation needs of an employee. It is designed to make it easier and faster to accommodate employees when they move to a new job within the federal public service;
  • work with our employees to update our accommodation policy, making sure the process is clear and well understood. When reviewing an accommodation request, we will see if it raises a systemic barrier and if so, we will plan to remove it on a permanent basis; and
  • continue to inform job applicants that they can ask to be accommodated during the hiring process.
• 1.2 Ensuring all employees feel welcome at the Commission by improving our onboarding practices. Revising the Commission's Onboarding Guidance and adding on-boarding information to the information package sent to new hires and to our intranet.

Medium-term goals and actions (2023 to 2024)

• 1.3 Ensuring employees responsible for hiring value a candidate with a disability's ability, and the lived experience and perspectives they would bring to the job. We will continue to adjust our recruitment processes and practices to implement the changes to the Public Service Employment Act. They are designed to reduce barriers and strengthen diversity and inclusion. Our work will include evaluating our qualification criteria for job opportunities and the design and application of our assessment methods to ensure that they do not reflect bias and other barriers. Where these exist, we will identify actions to mitigate or eliminate them.

Long-term goals and actions (2024 to 2025 and beyond)

• 1.4 Ensuring that every employee has an opportunity for growth and career advancement. Developing mentorship opportunities for employees with disabilities because we recognize the importance that mentorship can play in supporting employees achieve their career goals.

Ongoing training

Our employees will receive the training and tools they need to help achieve our accessibility goals for employment. We will provide training to:

• improve accessibility and disability awareness; and
• learn more about providing accommodation in an effective and respectful way. This will include training on interactions between managers and employees.

2. Built environment

The Commission is committed to ensuring that our workplaces are accessible for all. Over the past several years, we have consulted our employees and hired an organization that specializes in accessibility assessments. Although all the Commission's offices were certified as accessible, these processes identified barriers in our Ottawa and regional offices.

We will continue to remove barriers in the built environment that we have control over.

The consultations with our employees, external stakeholders and the external accessibility assessments identified a number of specific barriers, including the following:

• entrance, parking and exterior approaches could have more signs for directions and colour contrasting;
• insufficient number of accessible, gender-neutral restrooms, no emergency call button and no adult change stations in the washrooms;
• lack of assistive listening technology in reception areas, lounges and meeting rooms;
• problematic lighting in some spaces for staff with lighting sensitivities;
• inaccessible signage (too small; difficult to read; insufficient and inconsistent use of raised characters, Braille and tactile markings; insufficient colour contrast; inconsistent mounting heights and locations and missing signage to identify rooms and closets;
• limited wayfinding strategies, including no electronic wayfinding;
• inadequate emergency systems (including alarm pull not at accessible height and inadequate instructions for emergency evaluations);
• many corridors between workstations are too narrow; and
• insufficient visual fire alarms.

Immediate goals and actions (2023)

• 2.1 Ensuring our workplaces are accessible and inclusive for all those who use them. Developing an action plan to address the remaining barriers in our built environment using guidance from the external accessibility expert and targeting a number of short-term items.

Ongoing training

Our employees will receive the training they need to help the Commission achieve our accessibility goals for the built environment. We will also continue to provide training to build accessibility and disability awareness.

3. Information and communication technologies

The Commission will ensure that everyone can access the same information and receive the same services using information technology. We will ensure that our website, mobile site, web applications, electronic documents, software, and hardware do not create barriers to people with disabilities.

We are making progress on this pillar of our accessibility commitment by:

• creating a strategic roadmap for digital accessibility;
• providing ongoing training, including in web accessibility practices to the Commission web team;
• including people with disabilities in our design process;
• including accessibility instructions in our word and PowerPoint templates
• testing prototypes with people with disabilities;
• adding automated accessibility checks in our development process; and
• engaging people with disabilities to test the compatibility of our website with assistive technology.

We have also consulted on the accessibility of our website and mobile site. We completed an employee-led review, and we consulted with an external digital accessibility expert. Our website and social media content were assessed for compliance with the World Wide Web Consortium's Web Content Accessibility Guidelines (WCAG) 2.1, Level AA. The review and assessment included consulting people with disabilities. They used screen readers, screen magnifiers and alternative navigation technology in their user testing.

The consultation we conducted on the accessibility of our website and mobile site has identified the following barriers:

• readability issues caused by low contrast and thin fonts;
• checkboxes and radio buttons that are confusing to screen reader users;
• videos missing captions, audio descriptions or transcripts;
• problems on the mobile site with the quick links menu, auto-scrolling and carousels;
• difficulties completing our interactive forms, including the date fields;
• form validation errors that don't disappear after correction;
• tooltips that don't work with some types of assistive technology; and
• search function for the mobile site not working with Voiceover.

Internal consultations with employees also identified the following barriers:

• various internal and external systems and platforms are not accessible, some of which are mandated by the Government of Canada.

Immediate goals and actions (2023)

• 3.1 Ensuring all our employees can create accessible documents. We will provide our employees with software that has built-in accessibility features and provide the necessary training.
• 3.2 Ensuring clients, stakeholders and the general public do not face barriers when using our interactive web forms. We will convert our portable document format (PDF) web forms to hypertext markup language (HTML).

Medium-term goals and actions (2023 to 2024)

• 3.3 Ensuring our website, mobile site, and social media content fully complies with WCAG 2.1, Level AA. We will fix the remaining website and social media barriers identified through our internal and external consultations, reviews and audits.
• 3.4 Ensuring that employees who use adaptive technology do not face barriers. We will install new software and hardware to support the adaptive technology needs of our employees.
• 3.5 Integrating accessibility into the design of new digital solutions. We will add an accessibility designer to our development teams.

Long-term goals and actions (2024 to 2025 and beyond)

• 3.6 Ensuring our employees have access to internal and external systems (electronic document management systems, case management systems, human resource systems, financial systems, access to information and privacy system and library system). We will explore accessible alternatives to our current systems.
• 3.7 Aiming for website compliance with WCAG 2.1, Level AAA. We will update our website to AAA standards whenever possible.

Ongoing training

Our employees will receive the training and tools they need to help the Commission achieve our accessibility goals for information and communication technologies. We will provide training to build accessibility and disability awareness.

4. Communications

The Commission is committed to making accessible communication a permanent part of our culture and the way we reach our employees and our diverse audiences.

We do this by giving people the choice to communicate with us in the way that best meets their accessibility needs. In turn, we will reply by using their preferred method. The communication methods offered on our website are email, social media platforms, telephone, TTY, video relay service, and mail.

External audits done by an accessibility expert and by an expert in rehabilitation and work, as well as an employee-led assessment, identified these barriers relating to our communication materials, processes and practices:

• some of our documents are not accessible;
• some of our videos do not have American Sign Language (ASL) and Langue des signes québécoise (LSQ);
• inconsistent practices and processes for fulfilling requests for alternate formats; and
• our emergency handbook does not provide enough disability-related safety information.

Internal consultations with employees also identified the following barriers:

• some staff lack the knowledge to create fully accessible documents.

Immediate goals and actions (2023)

• 4.1 Ensuring that our documents are accessible to our employees, stakeholders, clients, and the general public. We are taking steps to make our documents accessible from the start by:
  • developing tools to assist our employees, such as our Accessibility Toolkit;
  • training all employees on creating accessible documents, and
  • training employees to write all documents in simple, clear and concise language.
• 4.2 Providing our documents in alternate formats. The Commission provides documents in alternate formats when requested. However, our processes and practices vary across our organization. This creates inefficiencies and delays. We will adopt a consistent service standard. This means sending documents in 15 days or less. For Braille and audio formats, sending them in 45 days or less.
• 4.3 Providing inclusive emergency information. We will update our emergency handbook and building evacuation code to more specifically include people with disabilities and how to ensure their safety during an emergency. We will make sure it is accessible to all staff.
• 4.4 Ensuring our accessibility plan is accessible to Deaf, deafened and hard of hearing people in Canada. We will provide ASL and LSQ videos for our Plan and the description of our feedback process.

Medium-term goals and actions (2023 to 2024)

• 4.5 Recognizing that Sign languages are the primary languages for communication by many Deaf, deafened and hard of hearing people in Canada. We have produced ASL and LSQ videos for some of our key documents. This includes ASL and LSQ videos about the Accessible Canada Act and our role in implementing it. However, most of our publications are not available in ASL and LSQ. We will consult with disability organizations on which documents to prioritize. We will also develop an action plan to address this barrier.

Ongoing training

Our employees will receive the training and tools they need to help the Commission achieve our accessibility goals for communication. We will:

• promote our Accessibility Toolkit;
• provide training on:
  • making written materials accessible;
  • using language and images that portray people with disabilities in a respectful, dignified way;
  • writing in simple, clear and concise language;
  • developing alternate formats and researching which suppliers can provide this service;
• share best practices, including writing for the Web;
• provide training on complex communication needs for communications materials; and
• provide employees with software that helps them write in simple, clear and concise language.

5. Procurement of goods, services and facilities

The Commission is committed to ensuring that accessibility is part of its procurement policy, processes and practices. To achieve this, we will integrate accessibility into our decision-making for procurement of goods and services.

An employee-led review identified these barriers relating to our procurement policy, processes, and practices:

• our contracting directive does not provide enough guidance to ensure that new barriers are not created when we purchase goods and services;
• we do not have a formal process to determine whether external venues are accessible; and
• our process for hiring third parties to provide services on the Commission's behalf does not emphasize accessibility.

Immediate goals and actions (2023)

• 5.1 Strengthening our contracting directive to ensure that the goods and services we obtain do not create accessibility barriers. Our current contracting directive reflects that accessibility is important but we want to make it better. We will revise the directive to make accessibility a key priority and we will ensure there is an appropriate challenge function if a contract does not identify an accessibility feature.
• 5.2 Ensuring external venues for our stakeholder meetings will not create barriers to participants with disabilities. We want our meeting participants to be able to focus on the discussions and not on accessibility concerns. We already take steps to ensure that external venues are accessible, but we want to strengthen our process. We will create a checklist to ensure we choose external venues that are accessible.
• 5.3 Ensuring that contracted organizations are provided with our accessibility policies, practices and processes. We will make sure they agree to respecting these policies.

Ongoing training

Our employees will receive the training and tools they need to help the Commission achieve our accessibility goals for procurement. We will provide training to build accessibility and disability awareness.

6. Design and delivery of programs and services

The Commission is committed to providing barrier-free programs and services to our clients, stakeholders and the public.

An internal working group and external assessments done by experts in accessibility, rehabilitation and work, and our clients identified these barriers relating to the design and delivery of our complaints related services:

• the complaints process is complicated. This includes the forms required to file a complaint and the forms used during the process;
• some complainants do not have enough ways to communicate with the Commission during the complaints process;
• some complainants cannot access the information and documents they receive from respondents;
• communicating through case numbers is not accessible for screen readers; and
• we lack relevant and current demographic data, including data on disability, which can help us design our programs and services.

The Commission has set up an Equal Access Unit in our complaints services branch. This unit focusses on increasing access to justice for complainants and ensuring our complaints process is accessible. For example, they provide training to employees, make sure that complainants' accessibility needs are clearly identified, work with individuals with lived experience to increase their capacity and understanding of frequently used software, review accessibility of our documents with screen readers, coordinate user testing of our forms, etc. We want to go further.

The Commission is also in the early stages of designing a number of new programs and services, such as the proactive compliance programs for Accessibility and Pay Equity. As these are still very new, the Commission has not yet identified any barriers related to this work but will rather focus on ensuring that the design and delivery of these new programs does not create barriers. Specifically we will ensure all our inspection and audit processes, tools and communications are accessible by:

• designing accessible communication portals for regulated entities;
• making our tools for regulated entities and employees accessible; and
• developing accessible tools and procedures for our inspectors and auditors so that we are well-prepared to hire diverse employees.

Immediate goals and actions (2023)

• 6.1 Providing better access to justice by improving the accessibility of our complaints processes and making better and more accessible products from the start.We will remove barriers by:
  • making our complaint forms more understandable and accessible;
  • consulting people with disabilities for feedback on our forms and co-designing a form with people with disabilities;
  • changing our complaint templates to allow electronic communication as an alternative to mail;
  • changing our email templates to make sure we use the full name of the respondent to help identify complaints; and
  • improving our case management system by obtaining consent and ensuring that complainant's accessible communication needs are met.
• 6.2 Collecting disaggregated data about people who use our complaints process, including information on disability. This will help us design effective programs and services to identify, remove and prevent barriers. We will change our complaint form to obtain demographic data through a voluntary survey to help us identify and track barriers, and determine whether there are factors that affect the outcomes of complaints in a positive or negative way.

Ongoing training

Our employees will receive the training and tools they need to help the Commission achieve our accessibility goals for the design and delivery of our programs and services. We will provide training to:

• build accessibility and disability awareness;
• provide knowledge on how to interact and communicate with people with different types of disabilities (including communication disabilities); and
• ensure that our complaints services include an accessibility and inclusion lens.

7. Transportation

The Canadian Human Rights Commission does not provide transportation services to the public.

Looking ahead

As we put the Plan in place, we will prepare regular progress reports as part of our obligations under the Accessible Canada Act and the Accessible Canada Regulations.

To do that, we will:

• consider the feedback that we receive through our feedback process;
• track our progress by recording how we have — or plan to — remove or prevent the barriers that are identified in this Plan, and any additional ones that might be identified; and
• report on this progress.

As we have done to develop this plan, we will consult people with disabilities to help us prepare our progress reports. The reports will reflect the information we receive through our feedback process and how we considered it.