2023 Progress Report on the Accessibility Plan for the Office of the Privacy Commissioner of Canada: Moving Toward a More Accessible OPC

How to provide feedback

Commenters can provide feedback anonymously or if they can include their name and contact information. People can use our form to tell us what they think:

• Accessibility feedback form

Other ways to give us feedback:

• Email address: Accessibility@priv.gc.ca
• Toll-free number: 1-800-282-1376
• Telephone number: 819-994-5444
• TTY line: 819-994-6591
• Mailing address:
  Accessibility Feedback – Chief of Staff
  Office of the Privacy Commissioner of Canada
  30 Victoria Street
  Gatineau, Quebec  K1A 1H3

The OPC will respond to confirm that our Office has received the feedback. The OPC will respond the same way as we received feedback. For example, if someone mails us a letter, our office will mail our response. The OPC will not be able to send a confirmation response to comments made anonymously.

Alternate formats

Commenters can ask for any information on the OPC’s accessibility plan or feedback process in alternate formats. Formats include print, large print, Braille and audio format (French and English) and electronic formats.

How long it takes receive alternate formats:

• Braille or audio format: within 45 business days
• Print, large print or electronic format: within 15 business days

Employment

Goal 1 – 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 OPC continues to foster an open culture and safe place for employees to celebrate and promote diversity and inclusion, to voice concerns and raise matters. This includes issues related to disabilities.

To achieve this objective, the OPC has named an Equity, Diversity, and Inclusion Champion and formed an active committee. This committee promotes events and activities related to accessibility. This includes:

• National Accessibility Week
• Invisible Disabilities Week
• International Day of Persons with Disabilities

These activities increase awareness and offer chances to learn about disabilities. During the above-mentioned weeks, the OPC gives employees Teams backgrounds. The backgrounds are images that appear behind users when they are in meetings on Teams. Employees are encouraged to use them to promote awareness of disabilities.

Over the past year, the Communications Directorate also promoted resources and events for accessibility in the OPC Weekly news bulletin. For example, to promote Plain Language Day, Communications sent tips and tools via email to all employees.

As well, the OPC continues to develop resources on topics such as plain language. These resources help with writing Reports of Findings and responses to accommodation requests. The OPC also suggested plain language text for investigators to use when responding to common questions from complainants about how OPC investigations work.

Over the past year, the Human Resources (HR) Directorate told OPC staff about learning opportunities related to accessibility. For example, it suggested courses to employees and management about hiring and keeping employees who have disabilities. We also promoted the GC Workplace Accessibility Passport. The Passport helps public service employees get tools, supports and measures so that they can do their best and succeed in the workplace. The Passport helps the OPC hire and keep employees with disabilities. It also helps with ensuring career advancement for employees with disabilities.

Over the last year, the OPC also accommodated employees with disabilities. The OPC offered flexible work arrangements to remove barriers. The OPC also bought equipment to meet their needs.

Goal 2 – Implement accessible practices to eliminate and prevent barriers to the recruitment, retention, and promotion of persons with disabilities.

The OPC takes part in accessibility groups that include many government departments. This helps us find out about tools and information that could help HR staff learn more about accessibility related to hiring. Over the past year, the HR Directorate also took part in meetings related to creating forms that let employees tell the OPC if they have a disability.

As well, the OPC takes part in equity, diversity and inclusion events and conferences. This allows our office to stay up to date on best practices in the HR field, which the OPC can also use in our hiring activities.

To improve how the OPC hires people we analyze information on employees who have asked for accommodation. This includes members of equity-deserving groups, including those who identify as having a disability. The OPC reviews all the stages of the staffing process to better understand how it could lead to some people being excluded from hiring.

On their first day at the OPC, new employees receive a welcome message. The message includes an invitation to submit a request to the Service Desk for accessibility tools they might need. This includes software and adapted technologies. Every year, the OPC reviews how it onboards new staff. The review looks at HR practices, including the mandatory orientation session for all new employees.

As of October 2023, the OPC has changed our service agreement with the Office of the Ombuds for Small Departments and Agencies from Public Services and Procurement Canada (PSPC) to include exit interviews. This allows the OPC to find out why staff living with disabilities leave the OPC. This information could help our office to improve how it accommodates people with disabilities so that fewer of them depart.

The OPC also removed barriers to access to our talent management program for non-executives. Our office has removed requirements to already have a CBC or above language profile for employees who belong to equity-deserving groups.

The Legal team has promoted the Accessibility Passport with employees and supported colleagues who looked for coaching for disability-related matters. The Legal team has also taken part in the Accommodation Consultative Committee along with the HR Directorate. This committee helps respond to requests for accommodation.

While the OPC has worked toward putting a self-identification form into place, it is delayed.

Finally, the OPC Employment Systems Review of internal policies and practices to identify barriers to employment for people with disabilities has been delayed. This review will help us uncover problems with our HR systems. It will also help uncover attitudinal barriers, such as stereotyping or stigma. These could prevent employment opportunities for people with disabilities. The review has been delayed until 2024. Funds have been approved for this project.

Design and delivery of programs and services

The OPC’s services include:

• Respond to inquiries
• Business Advisory Services
• Media Relations
• Respond to requests for information from Parliamentarians
• Contributions Program of the Office of the Privacy Commissioner of Canada
• Privacy Impact Assessment (PIA) Reviews
• Consultation Services
• Investigate complaints under the Privacy Act
• Receive and review breach reports under Privacy Act
• Review and investigate complaints under PIPEDA
• Receive and review breach reports under PIPEDA

The goals and related activities set out below are steps that the OPC is taking to increase the accessibility of our services.

Goal 3 – Ensure that OPC employees are sufficiently equipped to deliver accessible programs and services.

Over the past year, the OPC has encouraged employees to complete unconscious bias training. In particular, the Policy, Research and Parliamentary Affairs division hired a trainer to educate employees about unconscious bias. All Government Advisory employees also took the course, as well as most Communications employees.

The Legal Directorate continued to promote training related to disabilities and accommodation within its own directorate. The Legal team is looking into organizing a training session on the duty to accommodate for all managers in 2024. Compliance also offered a refresher training session on the OPC’s accommodation policy to our managers.

Goal 4 – Provide Canadians with barrier-free access to the OPC’s programs and services.

Over the last year, the OPC has drawn attention to the use of plain language. We sent several messages to all staff to inform employees about what plain language is and how it should be used. The Communications Directorate also shared plain language tips in the OPC weekly newsletter to all staff. The OPC is using simplified Advisory Letters, and has created generic messages using plain language.

The OPC acquired access to SiteImprove, a web tool, in October 2023. This tool:

• assesses accessibility
• flags usability issues such as broken links and typos
• evaluates the level of writing on webpages

SiteImprove will help make the OPC’s website more accessible. Similarly, all online forms are being updated to use a tool that conforms to WCAG 2.1 AA.

The OPC’s Compliance sector is revising our office’s online complaint form, taking accessibility into consideration. The OPC expects to finish the review in early 2024. Compliance also has ways to respond to accommodation requests from the public or complainants.

Communications has updated the website terms and conditions of use to reflect the OPC’s commitment to accessibility. There are plans to make further changes to the OPC website to highlight information about requests for alternate formats. Our office will promote this information via social media channels.

Communications has put contracts in place to ensure that the OPC can provide publications on our website in various formats upon request. Our accessibility plan is available upon request in print, large print, Braille, audio format (French and English) or an electronic format that is compatible with adaptive technology.

Communications is monitoring feedback about the OPC website. This will help the OPC assess whether we should add more accessibility features, such as a web feedback tool.

The OPC is committed to achieving a high standard of accessibility as defined in the Standard on Web Accessibility and the Standard on Optimizing Websites and Applications for Mobile Devices. If users have difficulty with our webpages, applications or device-based mobile applications, they can contact us for help. We have added training on skills related to interaction with the public to Information Officers’ training plans.

Built environment

The built environment can have an effect on health and wellbeing. If it is optimized, it can ensure that all employees and clients have equal and fair access to the OPC’s buildings and physical workplaces.

Goal 5 – Create a workplace free of physical barriers to improve the working environment for all OPC employees of various abilities.

The OPC is committed to creating a workplace free of physical barriers. This will improve the working environment for all OPC employees of various abilities. Currently, our office workstations are all equipped with sit-and-stand desks that users can adjust at the touch of a button. Most of our workstations are wheelchair accessible. The OPC is working with a designer to make the enclosed offices accessible. This will include using furniture that users can adjust electronically. It would also involve removing furniture that is a barrier to accessing the work space. In 2023-2024, to support this goal, the OPC will designate workstations for people with mobility impairments.

The OPC also plans to review our office’s built environment against the National Standard of Canada accessible design for the built environment. This will allow the OPC to identify gaps. The OPC will review the standard in 2024–2025. In addition, Public Services and Procurement Canada has started a review of the built environment for 30 Victoria alongside the revised national standards. This should lead to improved access to the common areas within the building.

Goal 6 – Ensure that all employees have a safe environment to work in.

The Corporate Management sector will put in place a buddy system for employees with disabilities who are working on site. The sector is reviewing evacuation plans with employees with disabilities. It is also checking that smoke, fire and other emergency alarms have visual as well as auditory alerts. The sector plans to finish this work during 2024-2025.

Information and communication technologies

Central agencies and common service providers such as Shared Services Canada (SSC) and Public Services and Procurement Canada (PSPC) set government standards for acquiring software and hardware for many products and services. Their leadership is essential in moving toward more accessible infrastructure.

Goal 7 – Provide accessible technology to ensure that all staff have access to the tools and platforms that they need to perform their work.

The OPC is committed to acquiring accessible technology. This will ensure that all staff have access to the tools and platforms that they need to perform their work.

Goal 8 – Acquire and implement technologies that ensure that all Canadians can access Government of Canada programs and services.

The OPC has formally added accessibility to the compliance assessment for new non-standard software requests. The OPC had informally added accessibility testing requirements to the non-standard software request process in 2021. With the step of making these requirements formal, OPC now has to confirm, when completing the assessment, that the software meets accessibility requirements.

Communication, other than information and communication technologies

The Government of Canada community of practice is creating performance indicators for accessible communications.

Government accessibility guidance suggests web material should be written to a grade 6 to 8 level. The OPC will do a plain language review of our website content for individuals. This will  help people understand and act on their privacy rights.

Goal 9 – Ensure that OPC communications products are developed within an “accessibility by design” culture, where staff at all levels are aware of accessibility requirements.

The OPC develops communications products within an “accessibility by design” culture. This means that employees at all levels are aware of accessibility requirements. The Communications Directorate also makes sure that every document posted on the OPC website is in an accessible format. All pages meet the Standard on Web Accessibility and the Standard on Optimizing Websites and Applications for Mobile Devices.

To encourage frontline staff to include plain language training in their learning plans, and follow the plain language process, the OPC is organizing training sessions. The Compliance Sector looked into options for plain language training for investigators in 2023–2024.

Communications will provide guidelines for usability and accessibility of content in the plain language reference guide and OPC intranet plain language and accessibility toolkit.

Finally, knowledge of web content accessibility guidelines is a requirement for new employees in web support. This ensures that current employees and future hires know about the guidelines.

Goal 10 – Share knowledge and best practices widely in order to reduce barriers across the public service.

The Communications Directorate has drafted a plain language guide, including a checklist. We expect it to be approved in 2024. Employees are made aware of the value of using plain language when communicating with the public.

In addition, the Communications Directorate has added instructions to the OPC’s form for our consultation on biometrics guidance. This helps users understand how the form works. As well, Information Centre employees are trained to help people fill out forms or access services offered by the OPC.

Procurement of goods, services, and facilities

The Canadian Human Rights Commission (CHRC) is the contracting authority for the OPC. The CHRC ensures that procurement activities conducted on behalf of the OPC comply with the Accessible Canada Act. This means that accessibility will be part of the procurement process from the outset. More information on the OPC’s procurement activities and how they meet the requirements of the Act can be found in the CHRC’s accessibility plan.

The OPC has been working with CHRC, Legal Services, and the Shared Services Canada Accessibility, Accommodation and Adaptive Computer Technology team to make sure that contracts the OPC prepares in-house meet accessibility requirements.

The OPC is waiting for Legal Services to finish their current round of contract clause reviews before it establishes a path toward including more accessibility requirements in our contracts moving forward.

Most software and hardware purchases that the OPC makes go through existing standing offers or supply arrangements where accessibility needs have already been identified and validated.

Feedback

The OPC launched our public feedback process on accessibility in December 2022. Since then, the OPC has received occasional requests from the public through our Information Centre for help with filling out forms, notably our online complaint forms. Information Officers are trained to respond to accommodation requests such as helping with forms. Processes are in place to resolve these issues to the client’s satisfaction. The OPC has not received any feedback from the public or from employees about the feedback of our employment, programs or services.