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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:
- Increasing staff awareness about accessibility and the barriers that limit access for Canadians with disabilities.
- Ensuring Canadians have access to NSIRA’s publications and services.
- 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
- Ensure that recruitment and selection processes are accessible.
- Provide Human Resources (HR) staff and hiring managers with training in accessibility best practices.
- Review past recruitment and selection practices to identify and prevent future barriers.
- Ensure that all recruitment and staffing material, and communications with candidates clearly identify accessibility/accommodation options.
- Seek feedback from candidates about the effectiveness of accommodation measures in selection processes.
- Formalize and communicate an accommodation process for employees with disabilities.
- Consult employees to identify barriers and gaps in workplace accommodations.
- Inform employees about the Government of Canada Workplace Accessibility Passport and implement on a voluntary basis.
- Consult other organizations to increase awareness of accessibility and to seek individualized accommodation strategies for employees.
- Identify mechanisms to reduce wait times for workplace accommodations.
- Increase awareness for staff at all levels on accessibility issues.
- Provide all staff with training on accessibility awareness and sensitivity.
- 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.
- Incorporate accessibility awareness generally and information about accommodation measures specifically in new employee orientation and on-boarding.
- 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.
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
- Identify, remove, prevent and/or mitigate barriers in the built environment.
- 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.
- Develop an action plan to remove and/or mitigate barriers, e.g., text to voice platforms, audible and visual alerts, signage, etc.
- Establish in consultation with partners an accessibility/duty to accommodate process for medical/assistive devices within the on-site workspace.
- Ensure alternative arrangements are available to anyone needing accessibility accommodations prior to attending a site or office.
- Review, revise and document building emergency evacuation procedures and training with an accessibility lens, in collaboration with the building senior officer’s security team.
- Contribute to making security program information and facilities accessible by default.
- Review forms, tools and services to identify barriers for persons with disabilities.
- Collaborate with policy centers (including CSE, TBS, DND) to develop and implement accessible alternatives.
- Establish an inclusive and nimble on-boarding and off-boarding process, including in-person training for operating within the on-site workspace.
- 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
- 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.
- Review and revise current publications.
- Develop a lifecycle review plan to modify accessibility of document previously published by NSIRA.
- Ensure major corporate ICT inventory (i.e., systems, hardware and software) is accessible.
- Review existing inventory to identify accessibility barriers and gaps.
- Develop plans to resolve, mitigate and prevent accessibility barriers in consultation with key partners, including increasing awareness of accessibility requirements.
- Ensure that future ICT systems, hardware and software meet the leading accessibility standards and function with adaptive technologies.
- Build awareness among all NSIRA staff about accessibility requirements, tools and options.
- 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.)
- Provide enhanced accessibility training to those responsible for publications, reports and web content.
- Ensure that persons with disabilities can participate fully in the complaints process.
- Recommend to the Review Agency appropriate amendments to NSIRA’s Rules of Procedure.
- 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
- Ensure that all communications are accessible for staff, stakeholders and members of the public.
- Review existing practices, tools, and systems to remove, resolve, mitigate and prevent barriers.
- Recommend to the Review Agency appropriate amendments to NSIRA’s Rules of Procedure.
- Put in place arrangements for services to support communications such as sign language interpretation, Braille printing, etc.
- Build awareness among all NSIRA staff about accessible communication requirements, tools and options.
- 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.
- 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
- Ensure that procurement practices, processes and outcomes support an accessible workplace and accessible programs, and services.
- Provide training for cost centre managers and staff about integrating accessibility considerations into procurement processes and practices.
- Provide enhanced accessibility training to those responsible for procurement.
- Review practices and processes and revise as appropriate to ensure compliance with Accessible Procurement principles, e.g., accessibility requirements incorporated in contracts, documentation, etc.
- 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
- Ensure that NSIRA’s programs and services are inclusive and accessible, while protecting privacy, meeting necessary security requirements and safeguarding sensitive information.
- Recommend to the Review Agency appropriate amendments to NSIRA’s Rules of Procedure.
- 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.
|
Corporate Services Branch |
2023-24 and ongoing |
b) Formalize and communicate an accommodation process for employees with disabilities.
|
Corporate Services Branch |
2023-24 and ongoing |
c) Increase awareness for staff at all levels on accessibility issues.
|
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.
|
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.
|
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.
|
Corporate Services Branch |
2023-24 and ongoing |
b) Ensure major corporate ICT inventory (i.e., systems, hardware and software) is accessible.
|
Corporate Services Branch |
2023-24 and ongoing |
c) Build awareness among all NSIRA staff about accessibility requirements, tools and options.
|
Corporate Services Branch |
2023-24 and ongoing |
d) Ensure that persons with disabilities can participate fully in the complaints process.
|
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.
|
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.
|
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.
|
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.
|
Investigations Executive Director’s Office |
2023-24 2022-23 and ongoing |
7. TRANSPORTATION |
||
N/A |