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Accessibility Plan – First Progress Report

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National Security and Intelligence Review Agency, Accessibility Plan – First Progress Report, December 2023
Title in French: Office de surveillance des activités en matière de sécurité nationale et de renseignement, Plan sur l’accessibilité – Premier rapport d’étape, Décembre 2023
Also available online: https://nsira-ossnr.gc.ca/publications/secretariat-operations/accessibility-plan-first-progress-report/
ISSN: 2818-5927
Key title: Accessibility Plan – First Progress Report (National Security and Intelligence Review Agency (Canada))
© His Majesty the King in Right of Canada, 2023

Date of Publishing:

From the Executive Director

In accordance with the Accessible Canada Act, I am pleased to table the National Security and Intelligence Review Agency’s (NSIRA) first progress report to its Accessibility Plan 2022 – 2025. This progress report describes the work that has been done to implement activities over the course of 2023.

As noted in our inaugural plan, accessibility is a work in progress. The Review Agency and the NSIRA Secretariat have made advances on several fronts, however there is more work to be done. Despite the best of intentions, it is apparent that some of the timelines were optimistic given the organization’s small size and the need to wait for work to be completed by other departments or agencies.

Most of the activities identified for completion in the first year were focused on increasing awareness and improving accessibility for the workforce and in the workplace. Consequently, for this first progress report consultations were limited to engaging with members of the NSIRA Secretariat’s workforce who offered their insights as persons with disabilities. The information provided by employees reinforced the importance of seeking input from persons with disabilities to identify and resolve barriers.

Through the combined efforts of growing internal capacity and new service level agreements with other public service organizations, NSIRA hopes to be better positioned to address areas that fell behind in 2023. We are optimistic that the coming year will provide an opportunity to double down on efforts to ensure that accessibility is integrated in an effective and sustainable manner in all aspects of the Review Agency’s and the NSIRA Secretariat’s work.

John Davies

Executive Director, NSIRA Secretariat

General

The Executive Director of the NSIRA Secretariat, who is the deputy head and employer, leads the Secretariat that supports the Review Agency in the fulfillment of its mandate under the National Security and Intelligence Review Agency Act. The Secretariat is responsible for monitoring feedback to evaluate progress and to determine its future accessibility plans.

In compliance with the requirements of the Accessible Canada Act (“ACA”) and the Accessible Canada Regulations, this progress report is available on NSIRA’s website, which is used to communicate with the public.

To request a copy of this report, the accessibility plan, or a description of the feedback process in an alternate format or to provide feedback about NSIRA’s progress report, the accessibility plan and any barriers encountered in dealing with NSIRA, please contact the undersigned by mail, telephone, or email.

Chief of Staff, Executive Director’s Office
National Security and Intelligence Review Agency Secretariat
P.O. Box 2430, Station “B”
Ottawa, Ontario, K1P 5W5


Telephone: 1-833-890-0293
Email: info@nsira-ossnr.gc.ca

Introduction

The National Security and Intelligence Review Agency published its Accessibility Plan 2022 – 2025 in December 2022. This first progress report describes the work that has been done to implement activities between January 1 and December 31, 2023.

The Accessibility Plan 2022 – 2025 set out three priority areas to improve accessibility:

  1. Increasing staff awareness about accessibility and the barriers that limit access for Canadians with disabilities.
  2. Ensuring Canadians have access to NSIRA’s publications and services.
  3. Continuing to advance a culture of respect and inclusion by integrating accessibility in all aspects of the organization’s work.

Through the efforts of the Senior Advisor, Wellness Initiatives, the NSIRA Secretariat can monitor progress, identify areas for improvement, and ensure overall coherence across the activities outlined in the accessibility plan.

Progress with respect to the priority areas and the accessibility plan is set out on the following pages. It is organized according to the seven key areas outlined in the Accessible Canada Act namely: employment; built environment; information and communication technologies (ICT); communication other than ICT; procurement of goods, services, and facilities; design and delivery of programs and services; and transportation.

The Review Agency and the NSIRA Secretariat were able to make advances on several fronts, however delays in staffing, stringent security requirements, and the organization’s small size meant activities did not progress as quickly as initially anticipated. The NSIRA Secretariat does not have ultimate control over certain fundamental aspects related to the built environment, technology, or security and must, therefore, adjust its pace to align with the direction given by the responsible policy centres.

Progress vis-à-vis accessibility plan

Employment

While developing the accessibility plan, the NSIRA Secretariat identified gaps with respect to employment. There was no written accommodation process for persons with disabilities employed in the NSIRA Secretariat. Furthermore, there was limited information available about accessibility requirements, resources, and information.

Status: On track

The NSIRA Secretariat was able to make advances in relation to many of the priorities with respect to employment. The Manager, Human Resources Services was joined by the Senior Advisor, Wellness Initiatives, midway through the year. Together they worked on 14 specific cases in 2023 to ensure that employees received the accommodations they requested to enable them to participate fully in all aspects of their work experience. Additionally, the following progress was made:

  • Duty to accommodate training was developed and delivered to all human resources staff and managers in February 2023.
  • Work is underway to make available a series of “how to” guides and a calendar of events for HR advisors, managers, and employees early in 2024.
  • The NSIRA Secretariat launched a new SelfID questionnaire in 2023, which was completed by all term and indeterminate employees. The data shows that the representation of persons with disabilities currently stands at 19.5%.
  • Performance measures and indicators relative to employment are under development, which will enable the NSIRA Secretariat to review selection practices to identify and prevent or mitigate barriers.
  • All recruitment and staffing material and communications with candidates at all stages of hiring processes include information about accommodations and accessibility. For example, invitations to interviews or to written exams clearly indicate that accommodations are available upon request.
  • A new feedback questionnaire was developed and launched in November 2023, to systematically seek feedback from candidates about the effectiveness of accommodation measures in selection processes.
  • A second feedback questionnaire was developed and launched in October 2023 to seek feedback from NSIRA Secretariat employees about barriers, gaps, appropriateness, and timeliness of workplace accommodations. (See the section entitled “Feedback” for more information.)
  • Employees and managers received training on the Government of Canada Workplace Accessibility Passport (GCWAP) in February and May 2023. Managers and employees are routinely encouraged to use GCWAP.
  • The Senior Advisor, Wellness Initiatives, introduced a standard operating practice to consult with other organizations to increase awareness of accessibility and to develop accommodation strategies for NSIRA Secretariat employees. Additionally, the Senior Advisor coordinates with the Communication Security Establishment (CSE), Privy Council Office (PCO), RCMP, and ergonomic firms as needed to develop individualized approaches.
  • Electronics must undergo specialized screening before they can be brought into the workplace. This type of security screening falls outside the control of the NSIRA Secretariat, which has requested expedited screening of electronics intended as an accommodation measure. The NSIRA Secretariat has set up a small inventory of screened equipment to further accelerate the process.
  • A new workshop entitled Accommodations at NSIRA was developed and delivered in May 2023. It will continue to be offered at least annually during National Accessibility Week. Accessibility awareness is routinely discussed at various occupational health and safety committee meetings.
  • Accessibility awareness and accommodation measures are now featured in training offered to HR staff and managers, as well as new employee orientation and on-boarding. Every letter of offer includes a point of contact with whom employees may confidentially discuss their accommodation needs.

Built Environment

The accessibility plan reported barriers in the built environment including heavy doors without automatic door openers; airlocks between doors; tripping hazards; narrow corridors; lack of accessible signage; restrictions with respect to assistive devices and job aids; an emergency alert system that flashes lights but does not emit an audible alarm; lack of control over lighting or temperature within the office space; and an outdated building emergency evacuation plan. Some of the barriers were tied to requirements of the Treasury Board Policy on Government Security and other policies that apply to the NSIRA Secretariat, but for which it is not the author.

Status: Ongoing

The NSIRA Secretariat made some inroads incorporating accessibility requirements into the built environment, but progress was slow. Delays can be attributed to two main reasons. First, NSIRA’s built environment is subject to standards established by Public Services and Procurement Canada (PSPC) and the CSE. Second, there was a lot of staff movement, which was compounded by delays in staffing. The following provides additional detail about progress in respect of the built environment:

  • The NSIRA Secretariat identified the need for updated standards to PSPC and CSE and will continue to emphasize the importance of accessibility assessments in the built environment in its ongoing discussions with PSPC and CSE.
  • Efforts to develop an action plan to remove and/or mitigate barriers, such as text to voice platforms, audible and visual alerts, signage, etc., have advanced slowly because of delays staffing.
  • In partnership with CSE and PCO, work is underway to develop and document a process to procure and enable the use of medical/assistive devices and adaptive technology in the workplace. This work is being done in consultation with the Senior Advisor, Wellness Initiatives.
  • Alternate arrangements were established on a case-by-case basis to address accessibility issues prior to individuals attending a site or office. This involved working in partnership with managers and corporate services. Delays in staffing may affect the extent to which alternative arrangements are delivered on a consistent and timely basis.
  • The NSIRA Secretariat created a process to identify employees who need assistance in a building emergency and evacuation, which was deployed for a drill in the fall 2023. The NSIRA Secretariat is continuing to work with the building senior managers of the Courts Administration Service and the Department of Natural Resources Canada, who are responsible for establishing the Building Emergency Procedures at NSIRA’s two worksites.
  • The security component of new employee on-boarding has been reviewed to identify barriers or gaps for persons with disabilities. Revisions are underway and the updated content will be launched early in 2024.

Information and Communication Technologies

The accessibility plan identified barriers with respect to information and communication technologies (ICT), notably that neither the intranet website, nor the internet website were fully accessible. Documents on both websites were not designed with accessibility in mind. Individuals bringing a complaint did not have the option to bring a complaint through any means other than by completing a templated form and persons with a hearing impairment had limited options for engaging with the Registrar.

Status: Ongoing

The NSIRA Secretariat’s Information Management (IM) and Information Technology (IT) team had several important priorities to tackle in 2023, one of which was a well-functioning internet website that adheres to accessibility standards and is compliant to Web Content Accessibility Guidelines (WCAG). This was accomplished in November 2023. The IM and IT team is understaffed and therefore has not been able to undertake all the activities identified in the accessibility plan. The team has still made some small progress in the following areas:

  • Work planning to review and modify accessibility of previously published documents, including fillable forms to ensure they are WCAG 2.0 compliant has been initiated and will continue.
  • Preliminary and informal discussions have been initiated drawing on the experiences of NSIRA’s existing workforce to better understand the types of barriers encountered as persons with disabilities and the challenges associated with accommodating their needs.
  • The NSIRA IT providers are the PCO and the CSE and both deliver their IT services with their own service model. There is a Memorandum of Understanding (MOU) between the CSE and the NSIRA as well as a MOU between the PCO and the NSIRA for the respective IT services. The NSIRA relies on these two different IT providers, which own their respective IT network and which the NSIRA Secretariat uses to communicate and collaborate; these IT providers control, monitor, manage and maintain the IT equipment on their respective networks. The NSIRA has no control over the hardware or the software that can be used on any of the networks to which it has access. Both service models are perceived not to be designed to be flexible and adaptable to meet the specific accessibility requirements of the NSIRA. In this context, the NSIRA Secretariat has already informally engaged these two partners to address accessibility in the interim. The NSIRA Secretariat will formally engage both partners to discuss tangible and sustainable solutions or means regarding accessibility in IT service delivery going forward.
  • Training for all staff about creating accessible documents and using other accessibility features available through ICT has been delayed due to a lack of resources. The Corporate Services team will inform NSIRA Secretariat employees early in the new year about training, information sessions, and online tools offered by other Government of Canada departments.
  • The NSIRA Secretariat’s Webmaster completed some training in which some concepts of WCAG 2.1 were taught. Training for other employees who draft reports, publications, and other publicly available material will begin in the second year of the Accessibility Plan 2022–2025. In the interim, the Webmaster will continue to ensure that material posted online is WCAG 2.0 compliant.
  • The work to incorporate digital tools to enhance accessibility with respect to the complaints process is delayed. As opposed to simply adapting existing forms, the NSIRA Secretariat has determined that a new complaints portal must be developed. Accessibility will be incorporated into the design and development of the new portal.

Communication other than ICT

The accessibility plan aimed to address several barriers with respect to communication for staff and members of the public including the absence of a process to provide alternate formats and communication support upon request. Other barriers included technical or sector-specific language in public facing documents and reports, as well as lack of guidance or established procedures for use of closed captioning, sign language interpretation, or TTY for persons with a hearing disability.

Status: Ongoing

In 2023 the NSIRA Secretariat engaged the services of a communications expert, a partner of the Five Eyes Intelligence Oversight and Review Council (FIORC), to develop a new communication strategy, which reviewed internal and external communications, as well as stakeholder engagement practices. The strategy identified key priorities for improving NSIRA’s output, engagement, and reputation, including recommendations for a new public-facing website. The NSIRA Secretariat is in the process of recruiting a Communications Manager, whose responsibilities will include implementing the communication strategy and leading on the communications activities identified in the Accessibility Plan 2022 – 2025. Progress was achieved on the following in 2023:

  • The NSIRA Secretariat’s Review Report Style Guide ensures that all review reports are written in accordance with accessibility guidelines published by Employment and Social Development Canada.
  • The Review Report Style Guide is an evergreen document. Additional changes are underway, which will be more explicit about what to include/consider from an accessibility perspective.
  • The NSIRA reports published in 2023 were available in HTML and PDF and included alt text for all graphics and images. Alt text was also included for posts on X (formerly known as Twitter).

Procurement of Goods, Services and Facilities

Although no barriers were identified with respect to the procurement of goods, services and facilities, the accessibility plan nevertheless noted that improvements could be made to ensure “accessibility by design” in procurement practices.

Status: Delayed

Due to a lack of staff, the NSIRA Secretariat was unable to carry out its planned activities for incorporating accessibility by design in its procurement practices. The NSIRA Secretariat recently negotiated a service level agreement with another public service organization and will explore integrating accessibility into the services offered in the new year.

Design and Delivery of Programs and Services

An important part of NSIRA’s mandate is to investigate complaints related to activities carried out by the Canadian Security Intelligence Service and the CSE, as well as complaints related to the denial or revocation of security clearances, and other matters under its purview. Ensuring that Canadians with disabilities can participate in these processes is integral to the investigations, however the Rules of Procedure do not provide accessibility options to accommodate the needs of persons with disabilities, while also complying with the necessary security requirements.

Status: Ongoing

As the work began to address the barriers identified with respect to NSIRA’s investigative function, it became clear that accessibility is contingent primarily on the built environment. The accessibility plan reported barriers such as heavy doors without automatic door openers. This includes the hearing room where investigative proceedings are held. Tripping hazards and restrictions with respect to assistive devices were also noted, among other concerns.

Similarly, progress around programs and services is inextricably linked to the barriers with respect to information and communication technologies. For the complaint investigation process, this included the internet website, which was not fully accessible, and limited options for persons with a hearing impairment to engage with the Registrar.

The new internet website includes a more user-friendly interface that meets WCAG standards. Complainants can more easily navigate to the information and forms they need to bring a complaint. The complaint forms themselves have been redesigned to be more accessible. Additionally, the following activities are underway:

  • A new section of the Rules of Procedure is being drafted to reflect the Review Agency’s commitment to ensuring accessibility. Progress is significantly dependent on the NSIRA Secretariat’s progress in incorporating accessibility requirements into the built environment.
  • In addition, the amendments to the Rules of Procedure will reflect an investigation participant’s ability to access alternate arrangements on a case-by-case basis to address their accessibility needs prior to their attendance on the premises for investigative proceedings.
  • The Rules of Procedure will also provide that the Registrar is to be notified of barriers and/or accessibility requirements for the Review Agency to accommodate those needs.
  • Finally, the Rules will provide that an individual wishing to bring a complaint must be provided procedural assistance by the Registrar in the event assistance is needed to address any barriers. This will enable access to persons with a variety of disabilities, including an individual with a cognitive disability who may require assistance articulating their complaint or allegations.

Transportation

The NSIRA Secretariat did not identify any barriers or develop an action plan with respect to this element.

Status: On track

Although specific actions were not identified, it is worth noting that NSIRA’s offices are in Ottawa, where employees and members of the public may use various modes of transportation to reach the work sites. Accessible transportation services are provided by OC Transpo in Ottawa and by the Société de Transport de l’Outaouais in Gatineau. Individuals who use their personal vehicles may park in designated spots available at nearby lots. Information is provided to new hires about designated parking spaces.

Consultations

The Accessible Canada Act requires consultations with persons with disabilities in preparing progress reports. The activities outlined in the accessibility plan for completion or launch in the first year aimed to improve accessibility for the workforce and in the workplace. This, combined with NSIRA’s specific mandate, greatly influenced the focus of consultations for this first progress report.

Thanks to the introduction of a self-identification (SelfID) questionnaire, employees who identified as a person with a disability were specifically invited to provide insight into barriers in the workplace and how to resolve, remove or mitigate them. Additionally, all staff were offered an opportunity to participate in the consultation process whether they had self-identified as a person with a disability or not. In this manner the NSIRA Secretariat benefited from a range of perspectives and first-hand experiences about barriers and the actions needed to become a more inclusive and accessible organization.

Feedback

Feedback from the NSIRA Secretariat’s employees included suggestions to improve security scanning of assistive devices and other required technology. Suggestions were also made with respect to knowledge transfer among staff responsible for facilities (i.e., the built environment) to ensure a smooth transition and avoid potential delays for employees who await assistive or adaptive devices or equipment.

Other employees identified barriers with respect to wheelchair accessibility at one location, which had not been previously noted. Concerns also included the height of some equipment, which was out of reach for a person using a wheelchair.

Since the pandemic, meetings often include employees working on-site and from home. The feedback from employees revealed that the sound system does not pick up voices consistently from all areas of the boardrooms. Consequently, parts of presentations or discussions in the boardroom are not being captured and employees participating from home cannot hear what is being said. It was therefore recommended that this be addressed in the context of the built environment.

No feedback was received from members of the public about the accessibility plan during the year under review. The NSIRA Secretariat will continue to welcome feedback in the coming year.

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Accessibility Plan 2023-2025

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National Security and Intelligence Review Agency, Accessibility Plan 2022 – 2025
Title in French: Office de surveillance des activités en matière de sécurité nationale et de renseignement, Plan sur l’accessibilité 2022 – 2025
Also available online: www.nsira-ossnr.gc.ca/accessibility-plan-2022-2025/
ISSN: 2817-1160, PS106-13E-PDF
Key title: Accessibility plan (National Security and Intelligence Review Agency (Canada)‏)
© His Majesty the King in Right of Canada, 2022

Date of Publishing:

From the executive director

I am pleased to share the National Security and Intelligence Review Agency Accessibility Plan 2022 – 2025. This plan outlines the activities that are necessary to address barriers in priority areas identified in accordance with the Accessible Canada Act.

The National Security and Intelligence Review Agency (NSIRA) is committed to ensuring it is accessible to Canadians. Our objective is to identify and remove, as well as prevent, barriers to accessibility to the greatest extent possible. Accessibility is a work in progress and where barriers cannot be removed, we will take action to mitigate them. This inaugural accessibility plan outlines the steps that will be taken to increase accessibility, both within the organization and for Canadians more generally, over the next three years.

This plan was developed in consultation with NSIRA Secretariat managers, subject matter experts, and employees who volunteered to share their experience as persons with a disability. Consultations also included an external panel of resources whose lived experience as persons with a disability provided an invaluable insight into barriers, potential gaps, and important considerations with respect to mitigation strategies.

It is slightly more than three years since NSIRA came into existence. Much has been accomplished in that time, however, there is still much to do to ensure accessibility in all aspects of the Agency’s work. This plan is an essential first step towards achieving this objective.

John Davies
Executive Director

General

The Executive Director of the NSIRA Secretariat, who is the deputy head and employer, leads the Secretariat that supports the Review Agency in the fulfillment of its mandate under the National Security and Intelligence Review Agency Act. The Secretariat will monitor feedback to evaluate progress and to determine its future accessibility plans.

In compliance with the requirements of the Accessible Canada Act (“ACA”) and the Accessible Canada Regulations, this plan is available on NSIRA’s website, which is used to communicate with the public.  

To request a copy of the accessibility plan or a description of the feedback process in an alternate format, or to provide feedback about NSIRA’s accessibility plan and any barriers encountered in dealing with NSIRA, please contact the undersigned by mail, telephone, or e-mail. 

Chief of Staff, Executive Director’s Office
National Security and Intelligence Review Agency Secretariat
P.O. Box 2430, Station “B”
Ottawa, Ontario, K1P 5W5


Telephone: 1-833-890-0293
Email: info@nsira-ossnr.gc.ca

Executive Summary

The National Security and Intelligence Review Agency (NSIRA) is committed to ensuring it is accessible to Canadians. Our objective is to identify and remove, as well as prevent, barriers to accessibility to the greatest extent possible. Accessibility is a work in progress and where barriers cannot be removed, we will take action to mitigate them. This inaugural accessibility plan outlines the steps that will be taken to increase accessibility, both within the organization and for Canadians more generally, over the next three years.

As a micro-organization of fewer than 100 full-time equivalents and not having in-house expertise, the NSIRA Secretariat engaged the services of an external consultant to conduct an accessibility assessment. The consultant was charged with examining NSIRA’s policies, programs, practices and services in relation to the identification and removal of barriers, and the prevention of new barriers in the areas described in section 5 of the ACA, i.e., employment; the built environment; information and communication technologies (ICT); communication other than ICT; the procurement of goods, services and facilities; the design and delivery of programs and services; and transportation.

The consultant gathered relevant information by reviewing documents, examining NSIRA’s public-facing website, and engaging with a variety of stakeholders by means of interviews and focus group discussions. Consultations also included an external panel of resources whose lived experience as persons with a disability provided an invaluable insight into barriers, potential gaps, and important considerations with respect to mitigation strategies.

Several issues surfaced through the consultant’s research and consultations. The issues included the need to: 

  • improve education and awareness about accessibility among NSIRA’s workforce;
  • integrate accessibility in respect of information, communication, employment, the built environment, and programs and services; and
  • work collectively to become “inclusive by design and accessible by default”.

The following pages provide some insight into NSIRA’s context and describe the actions that NSIRA will take with respect to the seven areas identified in the ACA.

Context

The National Security and Intelligence Review Agency (NSIRA) is an independent and external review body that reports to Parliament. NSIRA reviews Government of Canada national security or intelligence activities to assess whether they are lawful, reasonable, and necessary and reports accordingly. NSIRA investigates complaints from members of the public regarding activities of the Canadian Security Intelligence Service and the Communications Security Establishment, as well as the national security activities of the Royal Canadian Mounted Police and decisions by deputy heads to deny or revoke a security clearance. In addition, NSIRA investigates complaints that are closely related to national security referred by the Civilian Review and Complaints Commission for the Royal Canadian Mounted Police (CRCC), matters referred by the Canadian Human Rights Commission (CHRC) and certain reports made to NSIRA under the Citizenship Act. This independent scrutiny contributes to strengthening the framework of accountability for national security or intelligence activities undertaken by Government of Canada institutions and supports public confidence in this regard.

The National Security and Intelligence Review Agency Secretariat is a separate agency identified in Schedule V of the Financial Administration Act (FAA) and is not a part of the core public administration. Treasury Board of Canada policies with respect to financial management, procurement, communications, information management and technology, amongst others, apply to the NSIRA Secretariat. With respect to human resources, the Executive Director is the employer, whose authorities are derived from the National Security and Intelligence Review Agency Act (sections 42 through 47) and subsection 12(2) of the FAA. 

Under the ACA and the Accessible Canada Regulations, federally regulated entities must report to the public on their policies and practices in relation to the identification and removal of barriers by publishing their accessibility plans, feedback processes and progress reports. Each department, agency and federally regulated employer is also required to develop an accessibility plan and report on progress made against this plan annually starting in December 2023.

Priority areas and action plan

The following describes NSIRA’s plan to improve accessibility by acting on three fronts:

  1. Increasing staff awareness about accessibility and the barriers that limit access for Canadians with disabilities.
  2. Ensuring Canadians have access to NSIRA’s publications and services.
  3. Continuing to advance a culture of respect and inclusion by integrating accessibility in all aspects of the organization’s work.

A table summarizing the priority areas and action plan can be found at Appendix A.

1. Employment

The National Security and Intelligence Review Agency comprises up to seven members appointed by Order-in-Council. The Executive Director, who is the deputy head and employer, leads the Secretariat that supports the Review Agency in the fulfillment of its mandate. The NSIRA Secretariat is identified in Schedule V, Separate Agencies, of the Financial Administration Act.  It is not subject to the Public Service Employment Act, with the exception of Part 7 dealing with political activities. It has fewer than 100 employees who work primarily out of two locations in the National Capital Region. At the present time, staff work on-site and/or telework.

NSIRA is committed to removing and preventing barriers to recruitment, retention, and the promotion of persons with disabilities.  Accessibility accommodations are established in accordance with the duty to accommodate under the Canadian Human Rights Act (CHRA). Additionally, they are fulfilled in accordance with Treasury Board policies on financial management, government security, procurement, etc. 

Through the accessibility assessment, gaps were identified with respect to employment, notably that there is no written accommodation process for employees with disabilities, and that staff at all levels have limited access to and familiarity with accessibility requirements, resources and information.

Actions

  1. Ensure that recruitment and selection processes are accessible.
    1. Provide Human Resources (HR) staff and hiring managers with training in accessibility best practices.
    2. Review past recruitment and selection practices to identify and prevent future barriers.
    3. Ensure that all recruitment and staffing material, and communications with candidates clearly identify accessibility/accommodation options.
    4. Seek feedback from candidates about the effectiveness of accommodation measures in selection processes.
  2. Formalize and communicate an accommodation process for employees with disabilities.
    1. Consult employees to identify barriers and gaps in workplace accommodations.
    2. Inform employees about the Government of Canada Workplace Accessibility Passport and implement on a voluntary basis.
    3. Consult other organizations to increase awareness of accessibility and to seek individualized accommodation strategies for employees.
    4. Identify mechanisms to reduce wait times for workplace accommodations.
  3. Increase awareness for staff at all levels on accessibility issues.
    1. Provide all staff with training on accessibility awareness and sensitivity.
    2. Provide enhanced training to executives, managers, and subject matter experts relative to their role, e.g., training on Web Content Accessibility Guidelines (WCAG) for IT staff.
    3. Incorporate accessibility awareness generally and information about accommodation measures specifically in new employee orientation and on-boarding.
  4. Review the NSIRA Secretariat’s Human Rights, Accessibility, Employment Equity, Diversity, and Inclusion PlanHuman Resources Management Policy, and Terms and Conditions of Employment Policy and revise as necessary to ensure overall coherence.

2. Built Environment 

The National Security and Intelligence Review Agency occupies several locations in the National Capital Region. At the present time, staff work on-site and/or telework. Hearings/investigative interviews and inter-organizational meetings are held on-site.

NSIRA recognizes the importance of an accessible built environment. As such, NSIRA will continue to work with employees, building owners, and key partners to achieve the highest level of accessibility within the current location(s).

Through the accessibility assessment barriers were identified in the built environment including heavy doors without automatic door openers; air-locks between doors; tripping hazards; narrow corridors that limit access; lack of accessible signage; restrictions with respect to assistive devices and job aids; an emergency alert system that flashes lights for various safety and security reasons, but does not emit an audible alarm; no control over lighting or temperature within the office space; and an outdated building emergency evacuation plan. Some of the barriers are tied to the requirements of the Treasury Board Policy on Government Security and other policies, which apply to the NSIRA Secretariat, but for which it is not the author.

Actions

  1. Identify, remove, prevent and/or mitigate barriers in the built environment.
    1. Conduct a full assessment of accessibility barriers in the built environment(s) in conjunction with Public Services and Procurement Canada (PSPC), the Communications Security Establishment (CSE), and persons with disabilities.
    2. Develop an action plan to remove and/or mitigate barriers, e.g., text to voice platforms, audible and visual alerts, signage, etc.
    3. Establish in consultation with partners an accessibility/duty to accommodate process for medical/assistive devices within the on-site workspace.
    4. Ensure alternative arrangements are available to anyone needing accessibility accommodations prior to attending a site or office. 
    5. Review, revise and document building emergency evacuation procedures and training with an accessibility lens, in collaboration with the building senior officer’s security team.
  2. Contribute to making security program information and facilities accessible by default.
    1. Review forms, tools and services to identify barriers for persons with disabilities.
    2. Collaborate with policy centers (including CSE, TBS, DND) to develop and implement accessible alternatives.
    3. Establish an inclusive and nimble on-boarding and off-boarding process, including in-person training for operating within the on-site workspace.
    4. Revise training and awareness to ensure accessibility.

3. Information and Communication Technologies (ICT) 

The NSIRA websites, both intranet and internet, are the main vehicles for sharing information internally and with the public. The internet is also the main option for members of the public to access the complaints process, including information about the process and the required forms to file complaints.

Staff use a variety of software and tools to carry out their daily responsibilities, both while working on-site and while teleworking.

Several barriers were identified with respect to information and communication technologies (ICT). First and foremost is that neither the intranet, nor the internet are fully accessible. None of the documents shared via the intranet or the internet were designed with accessibility in mind, although features exist within the available software. There is no option for a person to bring a complaint through any means other than by completing a templated form and there is no TTY or similar alternative for a person with a hearing impairment to engage with the Registrar.

Actions

  1. Ensure NSIRA’s public-facing website and internal ICT platforms (e.g., Sharepoint libraries) adhere to all accessibility standards and are compliant to WCAG 2.0 AA at a minimum.
    1. Review and revise current publications.
    2. Develop a lifecycle review plan to modify accessibility of document previously published by NSIRA.
  2. Ensure major corporate ICT inventory (i.e., systems, hardware and software) is accessible.
    1. Review existing inventory to identify accessibility barriers and gaps.
    2. Develop plans to resolve, mitigate and prevent accessibility barriers in consultation with key partners, including increasing awareness of accessibility requirements.
    3. Ensure that future ICT systems, hardware and software meet the leading accessibility standards and function with adaptive technologies.
  3. Build awareness among all NSIRA staff about accessibility requirements, tools and options.
    1. Provide training for staff at all levels about creating accessible documents and using other accessibility features available through ICT (e.g., text to voice options, tools for virtual meetings, etc.)
    2. Provide enhanced accessibility training to those responsible for publications, reports and web content.
  4. Ensure that persons with disabilities can participate fully in the complaints process.
    1. Recommend to the Review Agency appropriate amendments to NSIRA’s Rules of Procedure.
    2. Incorporate digital tools to enhance accessibility.

4. Communications other than ICT 

The purpose of NSIRA’s review function is to ascertain facts after careful examination to develop findings and recommendations that inform accountability.  NSIRA’s findings and recommendations are communicated to the implicated departments and agencies, as well as the responsible minister. NSIRA’s Annual Report, summarizing and contextualizing its review work from the previous year is provided to the Prime Minister and tabled in Parliament. Unclassified versions of each review report and the Annual Report are published on NSIRA’s website. In this way, review by NSIRA informs the broader deliberation – fundamental in a free and democratic society – about the means, lengths and laws by which national security or intelligence activities are carried out.

Several barriers were noted with respect to communication for staff and members of the public including no existing process to provide alternate formats and communication supports upon request; technical or sector-specific language in public-facing documents and reports; lack of guidance or established procedures for use of closed captioning, sign language interpretation, or TTY for persons with a hearing disability.

Actions

  1. Ensure that all communications are accessible for staff, stakeholders and members of the public.
    1. Review existing practices, tools, and systems to remove, resolve, mitigate and prevent barriers.
    2. Recommend to the Review Agency appropriate amendments to NSIRA’s Rules of Procedure.
    3. Put in place arrangements for services to support communications such as sign language interpretation, Braille printing, etc.
  2. Build awareness among all NSIRA staff about accessible communication requirements, tools and options.
    1. Provide training for staff at all levels about accessible communication and using accessibility features such as closed captioning for meetings and events, alternate formats such as large print, Braille, audio or electronic formats.
    2. Provide enhanced accessibility training to those responsible for publications, reports, meetings and events.

5. Procurement of Goods, Services and Facilities 

The NSIRA Secretariat procures goods, services and facilities in accordance with the policies and processes established by Public Services and Procurement Canada, Treasury Board of Canada, and other key partners.

No barriers were identified with respect to the procurement of goods, services and facilities. Nonetheless the NSIRA Secretariat has noted that improvements are needed to ensure “accessibility by design” in procurement practices.

Actions

  1. Ensure that procurement practices, processes and outcomes support an accessible workplace and accessible programs, and services.
    1. Provide training for cost centre managers and staff about integrating accessibility considerations into procurement processes and practices.
    2. Provide enhanced accessibility training to those responsible for procurement.
    3. Review practices and processes and revise as appropriate to ensure compliance with Accessible Procurement principles, e.g., accessibility requirements incorporated in contracts, documentation, etc.
    4. Assess the feasibility of incorporating standard requirements for procurement practices and processes, e.g., templates for scope-of-work documentations, evaluation criteria, contracts etc.

6. Design and Delivery of Programs and Services

An important part of NSIRA’s mandate is to investigate public complaints related to any activity carried out by the Canadian Security Intelligence Service (CSIS) and the Communication Security Establishment (CSE), as well as complaints relating to the denial or revocation of security clearances.  In addition, NSIRA investigates complaints that are closely related to national security referred by the Civilian Review and Complaints Commission for the Royal Canadian Mounted Police (CRCC), matters referred by the Canadian Human Rights Commission (CHRC) and certain reports made to NSIRA under the Citizenship Act.  By law, every investigation is conducted in private.

Ensuring that Canadians with disabilities can participate in these processes fully is integral to NSIRA’s investigations. NSIRA’s Rules of Procedure do not provide accessibility options to accommodate the needs of persons with disabilities at all stages of the complaint process, while also complying with the necessary security requirements.

Actions

  1. Ensure that NSIRA’s programs and services are inclusive and accessible, while protecting privacy, meeting necessary security requirements and safeguarding sensitive information.
    1. Recommend to the Review Agency appropriate amendments to NSIRA’s Rules of Procedure.
    2. Ensure that accessibility is integrated in the approval process for new programs, activities or services.

7. Transportation 

This priority area does not apply to the National Security and Intelligence Review Agency.  As such no barriers or actions were identified.

Consultations

One of the guiding principles of the Government of Canada’s accessibility strategy is the statement “Nothing without us” which affirms that persons with disabilities must be involved in the design and implementation of this plan. Persons with disabilities offer a unique and valuable perspective and our goal is to ensure that we do not have any barriers that prevent their full participation in the workplace and that of those whom we serve.

All staff were invited to participate in the consultation process with a focus on engaging persons with a disability, regardless of whether they had previously identified as such. Subject matter experts, managers and employees with a disability were consulted in facilitated focus groups or individual interviews, which were conducted in either or both official languages.

Internal stakeholders with knowledge of employment practices, procurement, facilities, digital resources, communications, and the design and delivery of goods and services, were consulted. Questions regarding accessibility barriers, current accommodation practices, and priorities for remediation were discussed and responses have been used to inform this plan.

The input provided by subject matter experts, managers and employees was essential to identifying the barriers and gaps described in this plan and to developing actions to enable NSIRA to become a more inclusive and accessible organization.

In addition, the draft accessibility plan was reviewed by the consultant’s standing Accessible Canada Act Review Committee.  Review Committee members are individuals with a variety of lived experience with disabilities, and knowledge of a range of accessibility issues. The five-member committee consists of members who self-identify with a disability including mobility, vision, learning disability, mental health disability, and hearing loss.  

Committee members were provided an overview of the functions at NSIRA and an advance copy of the draft accessibility plan. Members provided comments on the plan format and readability, accessibility actions as outlined in the plan, suggested timelines for actions, and specific barriers that could be encountered.  Committee feedback has been incorporated into this approved plan.

Implementation, monitoring and reporting

To ensure that accessibility remains a priority, the Accessible Canada Act and the Accessible Canada Regulations require that regulated entities prepare and publish annual progress reports on the implementation of their accessibility plans. Like the accessibility plan, progress reports must be prepared in consultation with persons with disabilities and describe the manner of the consultations. The progress reports must also include any feedback that NSIRA receives and describe how that feedback was taken into consideration. NSIRA’s first progress report will be published 12 months after the publication of this first accessibility plan, in December 2023. It will include updates with respect to the actions that NSIRA has taken.

In accordance with the regulations, NSIRA will publish an updated plan every three (3) years, starting in December 2025.

Glossary

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.

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.

Information and Communication Technology (ICT): is an extensional term for information technology (IT) that stresses the role of unified communications and the integration of telecommunications (telephone lines and wireless signals) and computers, as well as necessary enterprise software, middleware, storage and audiovisual, that enable users to access, store, transmit, understand and manipulate information.

Web Content Accessibility Guideline (WCAG): the Web Content Accessibility Guidelines (WCAG) are part of a series of web accessibility guidelines published by the Web Accessibility Initiative (WAI) of the World Wide Web Consortium (W3C), the main international standards organization for the Internet. They are a set of recommendations for making Web content more accessible, primarily for people with disabilities.

References and resources

Accessible Canada Act (justice.gc.ca)

Accessible Canada Regulations (justice.gc.ca)

Accessibility Strategy for the Public Service of Canada – Canada.ca (also referred to as “Nothing Without Us”)

Canadian Human Rights Act (justice.gc.ca)

Canadian Human Rights Commission

National Security and Intelligence Review Agency Act (justice.gc.ca)

Policy on Government Security- Canada.ca

Web Content Accessibility Guidelines (WCAG)

APPENDIX A – SUMMARY OF PRIORITY AREAS AND ACTION PLAN

PRIORITY AREAS AND ACTIONS LEAD BRANCH TARGET FOR COMPLETION

1. EMPLOYMENT

   

a) Ensure that recruitment and selection processes are accessible.

  1. Provide Human Resources (HR) staff and hiring managers with training in accessibility best practices.
  2. Review past recruitment and selection practices to identify and prevent future barriers.
  3. Ensure that all recruitment and staffing material and communications with candidates clearly identify accessibility/accommodation options.
  4. Seek feedback from candidates about the effectiveness of accommodation measures in selection processes

Corporate Services Branch

2023-24 and ongoing

b) Formalize and communicate an accommodation process for employees with disabilities.

  1. Consult employees to identify barriers and gaps in workplace accommodations.
  2. Inform employees about the Government of Canada Workplace Accessibility Passport and implement on a voluntary basis.
  3. Consult other organizations to increase awareness of accessibility and to seek individualized accommodation strategies for employees.
  4. Identify mechanisms to reduce wait times for workplace accommodations.

Corporate Services Branch

2023-24 and ongoing

c) Increase awareness for staff at all levels on accessibility issues.

  1. Provide all staff with training on accessibility awareness and sensitivity.
  2. Provide enhanced training to executives, managers, and subject matter experts relative to their role, e.g., training on Web Content Accessibility Guidelines for IT staff.
  3. Incorporate accessibility awareness generally and information about accommodation measures specifically in new employee orientation and on-boarding.

Corporate Services Branch

2023-24 and ongoing

d) Review the NSIRA Secretariat’s Human Rights, Accessibility, Employment Equity, Diversity, and Inclusion Plan, Human Resources Management Policy, and Terms and Conditions of Employment Policy and revise as necessary to ensure overall coherence.

Corporate Services Branch

2023-24 and ongoing

2. BUILT ENVIRONMENT

   

a) Identify, remove, prevent and/or mitigate barriers in the built environment.

  1. Conduct a full assessment of accessibility barriers in the built environment(s) in conjunction with Public Services and Procurement Canada (PSPC), the Communications Security Establishment (CSE), and persons with disabilities.
  2. Develop an action plan to remove and/or mitigate barriers, e.g., text to voice platforms, audible and visual alerts, signage, etc.
  3. Establish in consultation with partners an accessibility/duty to accommodate process for medical/assistive devices within the on-site workspace.
  4. Ensure alternative arrangements are available to anyone needing accessibility accommodations prior to attending a site or office.
  5. Review, revise and document building emergency evacuation procedures and training with an accessibility lens, in collaboration with the building senior officer’s security team.

Corporate Services Branch

2023-24

2023-24

2024-25

2023-24

2023-24

b) Contribute to making security program information and facilities accessible by default.

  1. Review forms, tools and services to identify barriers for persons with disabilities.
  2. Collaborate with policy centers (including CSE, TBS, DND) to develop and implement accessible alternatives.
  3. Establish an inclusive and nimble on-boarding and off-boarding process, including in-person training for operating within the on-site workspace.
  4. Revise training and awareness to ensure accessibility.

Corporate Services Branch

2025-26

2025-26

2023-24

2023-24

3. INFORMATION AND COMMUNICATION TECHNOLOGIES (ICT)

   

a) Ensure NSIRA’s public-facing website and internal ICT platforms (e.g., Sharepoint libraries) adhere to all accessibility standards and are compliant to WCAG 2.0 AA at a minimum.

  1. Review and revise current publications.
  2. Develop a lifecycle review plan to modify accessibility of previously published NSIRA documents.

Corporate Services Branch

2023-24 and ongoing

b) Ensure major corporate ICT inventory (i.e., systems, hardware and software) is accessible.

  1. Review existing inventory to identify accessibility barriers and gaps.
  2. Develop plans to resolve, mitigate and prevent accessibility barriers in consultation with key partners, including increasing awareness of accessibility requirements.
  3. Ensure that future ICT systems, hardware and software meet the leading accessibility standards and function with adaptive technologies.

Corporate Services Branch

2023-24 and ongoing

c) Build awareness among all NSIRA staff about accessibility requirements, tools and options.

  1. Provide training for staff at all levels about creating accessible documents and using other accessibility features available through ICT (e.g., text to voice options, tools for virtual meetings, etc.)
  2. Provide enhanced accessibility training to those responsible for publications, reports and web content.

Corporate Services Branch

2023-24 and ongoing

d) Ensure that persons with disabilities can participate fully in the complaints process.

  1. Recommend to the Review Agency appropriate amendments to NSIRA’s Rules of Procedure.
  2. Incorporate digital tools to enhance accessibility.

Investigations

Corporate Services Branch

2023-24 and ongoing

4. COMMUNICATIONS OTHER THAN ICT

   

a) Ensure that all communications are accessible for staff, stakeholders and members of the public.

  1. Review existing practices, tools, and systems to remove, resolve, mitigate and prevent barriers.
  2. Recommend to the Review Agency appropriate amendments to NSIRA’s Rules of Procedure.
  3. Put in place arrangements for services to support communications such as sign language interpretation, Braille printing, etc.

Executive Director’s Office

Investigations

Corporate Services Branch

2022-23 and ongoing

2023-24 and ongoing

b) Build awareness among all NSIRA staff about accessible communication requirements, tools and options.

  1. Provide training for staff at all levels about accessible communication and using accessibility features such as closed captioning for meetings and events, alternate formats such as large print, Braille, audio or electronic formats.
  2. Provide enhanced accessibility training to those responsible for publications, reports, meetings and events.

Corporate Services Branch

2023-24 and ongoing

5. PROCUREMENT OF GOODS, SERVICES AND FACILITIES

   

a) Ensure that procurement practices, processes and outcomes support an accessible workplace and accessible programs, and services.

  1. Provide training for cost centre managers and staff about integrating accessibility considerations into procurement processes and practices.
  2. Provide enhanced accessibility training to those responsible for procurement.
  3. Review practices and processes and revise as appropriate to ensure compliance with Accessible Procurement principles, e.g., accessibility requirements incorporated in contracts, documentation, etc.
  4. Assess the feasibility of incorporating standard requirements for procurement practices and processes, e.g., templates for scope-of-work documentations, evaluation criteria, contracts etc.

Corporate Services Branch

2022-23 and ongoing

6. DESIGN AND DELIVERY OF PROGRAMS AND SERVICES

   

a) Ensure that NSIRA’s programs and services are inclusive and accessible, while protecting privacy, meeting security requirements and safeguarding sensitive information.

  1. Recommend to the Review Agency appropriate amendments to NSIRA’s Rules of Procedure.
  2. Ensure that accessibility is integrated in the approval process for new programs, activities or services.

Investigations

Executive Director’s Office

2023-24

2022-23 and ongoing

7. TRANSPORTATION

   

N/A

   
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Review of the Canadian Forces National Counter-Intelligence Unit

Review Backgrounder

This review focused on one aspect of the Department of National Defence / Canadian Armed Force’s (DND/CAF) intelligence activities: The Canadian Forces National Counter-Intelligence Unit (CFNCIU, or the Unit). The review was selected given that it is consistent with NSIRA’s emphasis on conducting a series of safeguarding reviews over the next few years.

The review examined CFNCIU’s domestic efforts at investigating Counter Intelligence (Cl) threats posed to DND/CAF, the rationale used by CFNCIU for justifying investigations, and the associated activities that transpire once this determination is made.

NSIRA reviewed the Unit’s case files, interviewed CFNCIUFIQ staff, detachment investigators and other internal stakeholders, as well as key senior officers with the aim of understanding CFNCIU’s contribution to Cl and insider-threat scenarios within DND/CAF. Based on the assessment of this information, NSIRA made several findings and recommendations to improve how intelligence is derived from investigations and conveyed to government decision-makers.

It is important to note that since inception of the Unit in 1997, the CFNCIU has been the subject of ten internal studies, each of which have identified the Unit as having suffered from resource and policy limitations (among others), resulting in an inability to fully meet its mandate. This review does not significantly depart from these previous assessments.

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