Accessibility progress report 2024 for the Office of the Privacy Commissioner of Canada

Moving toward a more accessible OPC

December 2024

Executive Summary

The Privacy Commissioner of Canada, supported by the Office of the Privacy Commissioner (OPC), is an agent of Canada’s Parliament. Our mission is to protect and promote the privacy rights of people in Canada. The OPC supports a culture that embraces diversity and inclusion in order to provide the highest quality of service to Canadians. The OPC works to make sure that employees, clients and stakeholders can take part fully in our Office’s mandate and activities.

A new law, the Accessible Canada Act (“the Act”), came into force on July 11, 2019. Along with other Canadian laws, the Act helps to support diversity and inclusion by directing Canadian organizations to remove and prevent barriers to accessibility.

As directed by the Act, the OPC published an accessibility plan in December 2022. The OPC’s goal is for the plan to help reduce existing barriers and prevent new barriers for people with disabilities. The plan covers 3 years and focuses on 7 priority action areas. The plan also lays out 10 organizational goals that the OPC has set related to accessibility.

This is the second year that the OPC reports our progress under the plan, and we have continued to improve. Plain language writing is an area that the whole office improved on. This means that more people can connect with our communications, making privacy more accessible to all Canadians.

We learned that involving users with disabilities in the design and testing of accessible resources provides critical insights that may be overlooked by those without lived experience. This understanding leads to more effective solutions that better meets users’ needs.

Introduction

The Accessible Canada Act (“the Act”) came into force on July 11, 2019. Its purpose is to make Canada barrier-free by January 1, 2040. The Office of the Privacy Commissioner of Canada (OPC) published our first Accessibility Plan under the Act in December of 2022.

We are proud of the progress that we have intentionally made this year towards a more inclusive OPC.

The following report highlights areas where we have made progress. It also identifies barriers to accessibility and what plans we have put in place to remove these barriers in the year ahead.

Barrier^{Footnote 1} “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.”

Disability “means any impairment, including a physical, mental, intellectual, cognitive, learning, communication or sensory impairment—or a functional limitation—whether permanent, temporary or episodic in nature, or evident or not, that, in interaction with a barrier, hinders a person’s full and equal participation in society.”

Identifying and removing barriers is a priority for the OPC in serving all Canadians. This involves identifying, removing and preventing barriers in the following priority areas:

• Employment
• The built environment (buildings and public spaces)
• Information and communication technologies
• Communication, other than information and communication technologies
• The procurement of goods, services and facilities
• The design and delivery of programs and services, and
• Transportation (airlines, as well as rail, road and marine transportation providers that cross provincial or international borders)

General

This is our second progress report on our accessibility plan. We have been inspired to work with experts in accessibility to do a review of our practices related to accessibility.

How to provide feedback

Commenters can provide feedback anonymously or 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.

Alternative 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

Priority Areas

To reach our objectives, the OPC has set specific goals for each priority area in our Accessibility Plan. Each of these goals has helped us target activities to advance our objectives.

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 is proud of our culture that celebrates and promotes diversity and inclusion. We aim to create a safe space to explore and promote accessibility, and to discuss barriers to accessible services. This year, we have taken many steps toward achieving this goal.

• To promote awareness, a calendar of Equity, Diversity and Inclusion events was created and shared with everyone in the office. This calendar is also shared with new employees during onboarding to promote our culture of inclusion from the beginning. We create and share themed backgrounds for our computer screens and for Microsoft Teams meetings to promote topics and events related to accessibility. Employees are encouraged to learn about the topics discussed in these awareness events, and to use the backgrounds to improve awareness.
• This fall, all Managers and Executives were invited to attend training on neurodiversity, presented by experts in the field of accessibility. The firm Left Turn Right Turn (LTRT) led engaging discussions on neurodiversity in the workplace to expand our office’s understanding of what it means to be neurodivergent. We also discussed the impacts that neurodivergence can have on a person at work and the kinds of accommodations a person might benefit from in the workplace. The goal for these sessions was to help create a culture of curiosity, respect, and inclusion and to empower teams to achieve their full potential.
• Following the neurodiversity training sessions, two information sessions on the Duty to Accommodate (DTA) were delivered by the Office of the Chief Human Resources Officer (OCHRO) on September 23 and October 3, 2024. Invitations were sent to Managers and Executives across the OPC. Following the sessions, a DTA Resources tool was shared with Management. These resources will help us to support a culture of understanding and inclusion.
• As an additional tool in managers’ toolkits, an information session delivered by the Accessibility, Accommodation and Adaptive Computer Technology program (AAACT) on "Best practices in accessibility, workplace adjustments and job accommodation" was held on October 8 and 9, 2024.
• The OPC is also promoting the use of the Government of Canada Accessibility Passport in the workplace to help employees document and share their accessibility needs. A presentation by Human Resources (HR) on this tool was given at the Managers’ Forum on February 28, 2024. With increasing understanding of accessibility and culture of inclusion, managers and employees are encouraged to discuss how best to use the Accessibility Passport to empower and support employees.

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

This year, we led several reviews and studies to find potential barriers to accessibility related to employment with the OPC.

• We carried out an analysis of how employment equity (EE) groups are represented in our workforce. This analysis included people with disabilities as one of the EE groups. We compared the representation rates for employees at the OPC with those for the public service in general, and with representation in the overall workforce. This data is produced three times each year, and it helps our managers to make informed decisions on our staffing practices and outcomes.
• In May, we launched a self-identification campaign on employment equity (EE) at the OPC. A message was shared by email and on Microsoft Teams, calling on employees to voluntarily self-identify as part of one or more of the EE groups. This data helps us understand the representation of employment equity-seeking groups within our office.
• We also led a study of the Office’s employment systems, which we completed in August. Employees who self-identified with an EE group, including people with disabilities, were invited to participate in this study to share their experiences and concerns as employees of the OPC. This data informed our Employment Systems Review (ESR), which helps us to identify potential gaps across the EE groups in our workforce.
• Our Human Resources (HR) team analyzed a sample of our hiring and selection processes to see if there are stages in our assessment when candidates with disabilities are more likely to be unsuccessful. These results were compared with those of people who did not identify with an EE group. Our goal was to find and address any gaps or barriers for candidates with disabilities in our selection processes.

The results of these studies and the review of our data will inform our new integrated HR plan. Collecting and using data will help us plan for a culture of inclusion and a strategic plan that helps prevent barriers.

In 2024, the OPC introduced new strategies to improve accessibility and looked for ways to improve our existing employment practices.

• We want to better understand our retention of employees and the reasons why employees leave. We have signed a service agreement with Public Services and Supply Canada’s Office of Shared Ombudsman Services to conduct retention interviews with our employees and exit interviews with employees who are leaving. These interviews are an opportunity for employees, including those with disabilities, to share their experiences and concerns. Interviews can be conducted orally or in writing to accommodate employees’ needs.
• Our staffing team continues to promote resources for hiring people with disabilities. These resources are shared on our “Information for Managers” Intranet page, which was updated at the beginning of 2024. This update provided managers with information about accessibility issues, including new staffing tools and options and links to the Accessibility Passport. It also features an updated list of training courses offered by Canada School of Public Service to promote respectful and inclusive workplaces.
• Since July 2023, we have used the Mitigating Bias and Barriers in Assessment tool for all our hiring processes, whether or not they are advertised. The tool is meant to help hiring managers identify potential biases and barriers in their assessment methods, which could disadvantage people from equity-seeking groups. In addition, a document sharing interview tips and common assessment errors is given to members of all selection committees.
• To stay informed of government-wide best practices, current issues, and initiatives, the Human Resources (HR) directorate took part in discussion groups with other departments about accessibility. These discussion groups will continue into the future.

Design and delivery of programs and services

The OPC delivers important services to Canadians. They 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 the Privacy Act
• Review and investigate complaints under PIPEDA
• Receive and review breach reports under PIPEDA

For the second year of reporting on our progress in improving accessibility, we reviewed how the design of our services affects Canadians, including those with disabilities. 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.

The OPC offers employees a recommended learning path that highlights courses offered by the Canada School of Public Service. The learning path includes topics such as unconscious bias, making documents accessible, and removing barriers to accessibility. Employees are contacted and updated about the learning path through the year, and they are encouraged to take these courses. This focus on continuous learning equips our employees to deliver accessible programs and services.

For example, employees in our Legal Sector who work with the public participated in training that included plain language writing for legal documents. It is important that the principles and reasoning behind a decision are easily understood by the average reader, particularly when the decision involves the reader. The lawyers delivering the training shared examples drawn from another tribunal’s Style Guide for writing decisions as practical examples of how to write accessibly.

Each year, employees participate in procedural fairness training given by our Legal Services department. This training discusses unconscious biases and the importance of fairness in decision-making. This training ensures that employees understand the needs of Canadians, including people with disabilities, and that they know how to reduce barriers and enhance accessibility as they deliver our programs and services.

This fall, we also updated our policy on accommodating clients with disabilities. The update was guided by the advice of an external accessibility leader. We encourage employees to read the updated policy and to integrate the policy approaches in their day-to-day service delivery. This policy is available to the public and is promoted internally for all employees.

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

This year, we focused on making the language and formatting of our resources more accessible. This includes writing in plain language, which continues to be a priority for the OPC. Employees are encouraged to write in plain language to make it easier for all Canadians to understand the sometimes-complex nature of our work.

• To mark National Accessibility Week, we shared resources about plain language with all our employees. These included the Treasury Board’s Digital Accessibility Toolkit, which is a new OPC resource on plain language and writing user-friendly content that improves accessibility for everyone.
• In the fall of 2023, the Translation Bureau, in collaboration with the OPC, published the Personal Information and Privacy Glossary. The glossary is helping to create a consistent standard in the terms that are used in the field of privacy protection in Canada. This consistency will help make the language used more accessible to all.
• This year, we reviewed and revised several of our forms for plain language writing with support from an accessibility consulting firm. These changes will make it easier for the public to use the forms and reduce barriers to our services.
• We have also written plain language definitions of complaints and a plain language code of conduct statements to make sure more people understand our messages.

We also reviewed our internal and public-facing resources to ensure they are as clear and accessible as possible.

• For example, when our Real Risk of Significant Harm (RROSH) tool was reviewed, we found that changes to its flow would make it easier to use, easier to understand, and faster to complete. A new version of the tool will be tested by users internally at OPC and by actual business users. We will use what we have learned as we continue to improve forms and documents and make them more accessible.
• We made several user-centered improvements to the Contact pages of our website. These changes will help people navigate the contact page and access answers to top questions. Changes to the Information Centre landing page now offer individuals and businesses a list of the most requested information and services, allowing visitors to find what they are looking for more quickly.
• Information on the availability of alternative format publications and documents is now more prominent on our website. Our Communications directorate has a contract with a company that provides alternative formats of documents upon request (such as braille, audio, and large print).

The built environment

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

Accessibility is part of the scope of work for all our projects, which means it is always taken into consideration as we make changes with designers to the OPC’s working environment. All cubicles’ workstations are adapted for mobility aids and equipped with adjustable sit-stand desks. Focus rooms are available for employees who need quiet working spaces with fewer distractions, and the lights are adjustable in these rooms.

As we continue with the workspace design project, the next phase will focus on the enclosed offices and focus rooms. We will be rearranging the offices and adding new furniture, and the plans from our designer are designed for accessibility. We plan to begin this next phase of work next year.

Before this takes place, we have consulted with leading experts in accessibility services to come to our office for a walkthrough. This walkthrough will result in a report with recommendations to improve our working environment, to reduce barriers, and to make it more accessible.

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

The OPC has internal guidelines for employees or people in the office who require assistance in case of an emergency. These guidelines say that when our Occupational Health and Safety (OHS) coordinator receives a completed form from an employee requiring assistance, they will schedule a meeting with the employee. At the meeting, the OHS coordinator will explain emergency and evacuation procedures, as well as the roles and responsibilities of everyone involved. The administrative services team also keeps an up-to-date list of employees who require assistance in case of an emergency.

Information and communication technologies (ICT)

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 sourcing and buying accessible technology. We want to ensure that all staff have access to the tools and platforms that they need to perform their work. Employees who require adaptive or ergonomic equipment are not required to provide a medical note. We also equip employees with ergonomic accessories, such as chairs or wrist rests, both at the office and at home.

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

Our Information Technology (IT) team participates in working groups, communities of practice, and other resources related to technology and accessibility. These are sources of new and important knowledge on technology and accessibility. We update our IT practices and tools on an ongoing basis to make sure they meet accessibility requirements.

Consultations are currently taking place for accessibility-related improvements to specific software and technologies, such as captioning of Teams meetings. Training on accessibility related to technology is part of our IT team’s ongoing learning.

The Information Technology and Information Management directorate continues to work with the other sectors at the OPC to stay on top of changing accessibility standards and practices, and to purchase services and applications related to accessibility. This is part of the OPC’s broader commitment to enhancing current public services.

Communication, other than information and communication technologies (ICT)

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.

Clear communication, including using plain language, is essential to the OPC’s services. On March 14, 2023, members of the Linguistic Services unit attended a training program titled “Plain Language Training: A Clear Voice for Canada,” offered by Shared Services Canada. Having plain language skills within the Communications directorate means that more of our communications will be developed with accessibility by design. Members of the Linguistic Services unit also attended the Document Accessibility Workshop offered by Shared Services Canada’s Accessibility, Accommodations and Adaptive Computer Technology Program (AAACT).

The web team within the Communications directorate ensures that all the OPC’s website content meets both accessibility guidelines and the Standard on Web Accessibility. Their work involves using accessible templates and other tools like contrast checkers. A graphic designer works to apply accessibility standards to all graphics, resources, and publications that are developed for the OPC. This June, all Communications team members participated in training about the user experience and developing user-centered web content. The training included techniques and methodologies for assessing and developing web content that is clear, usable, and accessible.

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

Members of the Linguistic Services Unit continue to apply the Canada.ca Content Style Guide rules for plain language and inclusive writing. These set consistent standards for plain language in OPC documents in both official languages.

This year, the OPC Communications directorate also published its own plain language reference guide, which was shared by email with all staff by the Executive Director of Communications. The reference guide is also posted on the communications Intranet page for easy access.

Procurement of goods, services, and facilities

Most software and hardware that we purchase goes through existing standing offers or supply arrangements, where accessibility needs have already been identified and confirmed.

When we need to procure new goods or services, the Canadian Human Rights Commission (CHRC) is the contracting authority for the OPC. This means the CHRC ensures that when goods or services are being sourced and purchased on behalf of the OPC, these processes comply with the Accessible Canada Act. Accessibility is therefore part of the OPC’s process of sourcing, selecting, and purchasing goods and services from the beginning. 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 also been working with the CHRC, Legal Services, and the Shared Services Canada Accessibility, Accommodation and Adaptive Computer Technology teams to make sure that contracts we prepare in-house meet accessibility requirements.

Transportation

This section is not applicable to the OPC. The OPC has limited responsibility over transportation for its employees and for the public we serve. We do not offer public access to our building and do not offer services in person.

During the year, we have communicated with employees when transportation to the office may be impacted. For example, when detours and road closures have happened, we have included alternative routes to the office.

Options for transportation to both of our locations, in Gatineau and in Toronto, are included in our onboarding information. We also encourage a carpooling initiative for employees to commute to the office.

Consultation

The OPC is committed to listening to and including people with disabilities in our work. We collaborate with people with disabilities as we write and review our Accessibility Plans and Progress Reports. For this Progress Report, we consulted both with our employees who have disabilities, and a focus group of Canadians with disabilities.

To help us consult with our employees, we engaged an accessibility consulting firm. They invited our employees to review a draft of this Progress Report, and to confidentially share their feedback about our progress over the last year. 7 employees participated in these interviews, and they all self-identified as being neurodivergent and/or living with disabilities. Overall, we heard a lot of positive feedback about accessibility at the OPC, especially with respect to our accommodations process. Some of the feedback also suggested that our employees are not always aware of the specific progress we are making to remove barriers and improve accessibility as it is happening. We will address this by committing to improve and promote communication about accessibility in the workplace. We will be mindful of our employees’ feedback as we plan for future accessibility initiatives.

The accessibility consulting firm also helped us to consult with a focus group of Canadians with disabilities. The members of the focus group have diverse backgrounds and disabilities, and they represent people who might one day need to interact with the OPC. They reviewed a draft of this Progress Report and then met virtually to share their feedback on our progress. We applied this feedback in the final version of this report. The focus group members told us that they appreciated the steps we have taken toward becoming more accessible, particularly our efforts to raise awareness and enhance training. They also shared positive feedback about the ways we are using plain language in our work. Importantly, the focus group gave us suggestions related to accessible formatting that we applied to the final version of this report.

We are grateful to our employees and to the members of the focus group for sharing their opinions with us, and we will continue to incorporate their feedback into our work.

Feedback

This year, the OPC received 7 submissions from our Accessibility Feedback Form on our website. Most of these submissions included very few details. Five (5) of the emails were from individuals seeking help either in making a complaint, reporting a breach, or following up on a decision. We followed up with these individuals when they included their contact information in their submission.

Training

Since 2020-2021, the OPC has included the Canada School of Public Service (CSPS)’s Learning in Support of Respectful and Inclusive Workplaces in the OPC Learning Roadmap recommended training for all our employees. The accessibility section of the Learning Roadmap was updated in October 2023 to add more resources. We remind and support our employees to develop their understanding of diversity, including disability matters, so that we can collectively offer the best services to all Canadians.

This year, the OPC welcomed Thérèse St-Arnaud, a guest speaker from the Forum of Federal Speakers on Life Experience. She shared her experiences living with disabilities and the accommodations that were put in place to ensure her success in the workplace. This session deepened our awareness and understanding of how we can reduce barriers to accessibility when we offer services to Canadians.

A particular focus this year has been to broaden our appreciation of invisible disabilities. To meet this important goal, we held training sessions on neurodiversity for management and executives to better understand the lived experience of neurodivergent people, both as employees and as members of the public. Following these sessions, which were delivered by the accessibility consulting firm Left Turn Right Turn (LTRT), we held discussions on our workplace culture to look for ways to improve our practices.

Next, management and executives were invited to participate in two information sessions on the Duty to Accommodate (DTA), which were delivered by the Office of the Chief Human Resources Officer (OCHRO). Together, these training sessions equipped our managers with the knowledge and resources to improve the experiences of people who work at the OPC.

The OPC is dedicated to continued learning activities and development to improve our services and programs for Canadians. As we uncover areas to improve and make plans to reduce barriers to accessibility, our goal is to serve all Canadians, including those who live with disabilities.

Lessons learned

Building a culture of accessibility requires ongoing training and awareness. These commitments are essential to sustaining a culture of inclusivity and ensuring that all team members understand their role in promoting accessibility.

While comprehensive changes are ideal, we realized that smaller, incremental improvements also help keep up momentum and provide lasting benefits of their own.

We learned last year that tracking our changes quarterly is essential for accountability. This year, we improved on this tracking by sharing regular communications on our collective progress. The lesson is that with good communication, the OPC can align goals and share resources effectively. For example, our tracking showed that many teams were putting efforts towards plain language writing, in their own ways. However, a more strategic approach for cross-sectoral methods could reduce duplication of efforts.