Copyright Board of Canada Accessibility Plan 2023-2025

Context

In July 2016, the Government of Canada (GC) began consultations with more than 6,000 Canadians in order to determine what an accessible Canada means to them. As a result of these consultations, Bill C-81: An Act to ensure a barrier-free Canada, was tabled in June 2018. The Accessible Canada Act, which aims to make Canada a barrier-free country by January 1, 2040, came into force in July 2019. In order to attain that goal, all GC organizations are required to proactively identify, remove and prevent barriers in the following seven (7) 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
  • transportation (airlines, as well as rail, road and marine transportation providers that cross provincial or international borders)

According to the 2017 Canadian Survey on Disability, one in five Canadians (6.2 million) aged 15 years and over had one or more disabilities that limited them in their daily activities.

Based on the data obtained with respect to employment equity in the public service of Canada for fiscal year 2017 to 2018, 5.3% of employees of the core public service identify as persons with disabilities. These figures indicate that the public service is having difficulty attracting and retaining persons with disabilities, despite the significant number of available candidates in the labour market. This same report also shows that not only has the rate of promotion for employees with disabilities decreased over the last 10 years, but the percentage of new hires with disabilities has continued to fall below the workforce availability for this group. Moreover, results from the 2018 Public Service Employment Survey suggest there is a significant difference in rates of harassment for employees who self-identify as having a disability (18% higher than those who do not self-identify).

In light of all this, it is clearer than ever that the public service as a whole has some work to do to in terms of improving representation in the public service and ensuring that persons with disabilities can participate fully and meaningfully in the workplace. The GC’s Accessibility Strategy for the Public Service of Canada (the GC Strategy) lays out a vision for becoming the most accessible and inclusive public service in the world.

The Strategy’s guiding principles

  • "Nothing about us without us" – persons with disabilities are involved in the design and implementation of the Strategy
  • Collaboration – GC organizations work in collaboration with each other, with bargaining agents and with other public, private and not-for-profit organizations
  • Sustainability – the Strategy prioritizes actions that will have an enduring impact
  • Transparency – the Strategy is developed and implemented transparently; and GC organizations will report openly and transparently on their efforts to remove barriers

The GC Strategy’s goals

Five goals are key to realizing the vision:

  1. Employment – Improve recruitment, retention and promotion of persons with disabilities
  2. Built environment – Enhance accessibility
  3. Technology – Make information and communications technology usable by all
  4. Services – Equip public servants to design and deliver accessible programs and services
  5. Culture – Build an accessibility-confident public service

In addition to the publication of GC organizations’ first Accessibility Plan, the Accessible Canada Act has the following planning and reporting requirements:

  • Prepare and publish accessibility plans 
    • Develop accessibility plans to identify, remove and prevent barriers in the priority areas in their:
      • policies
      • programs
      • practices
      • services
    • update organization plans every three years or as specified in regulations
    • consult people with disabilities when creating and updating organization plans
  • Establish a feedback process 
    • Build internal capacity to receive and deal with feedback about accessibility within the organization
  • Prepare and publish progress reports 
    • Issue regular progress reports describing the actions the organization has taken to implement these accessibility plans, including the feedback received and how the organization took the feedback into consideration
    • Consult people with disabilities when preparing progress reports

These requirements help ensure that accessibility is an ongoing priority and that all GC organizations are continuously improving and implementing inclusive design and working towards an accessible by default end state. The responsibility/accountability for accessibility will no longer be placed on persons with a disability but rather with all functional groups within GC organizations. The GC will establish proactive mechanisms to address accessibility systemically, from the outset.

General

The Copyright Board of Canada (“the Board”) is an independent regulatory body and administrative tribunal responsible for setting royalties for the use of copyrighted works when these rights are administered by a collective society. Through its decisions on proposed tariffs, the Board helps define the economic parameters of the use cycle of copyrighted works.

The Board is a micro-organization with 25 full time employees; and its Vice Chair serves as its chief executive officer under the Financial Administration Act.

Accessibility Approach

The guiding principles set out in the GC Strategy – “nothing about us without us”, collaboration, transparency, and sustainability - are at the heart of the Board’s approach to its first formal Accessibility Plan (the Plan). These principles also align with the vision expressed in the Board’s Letter on the Implementation of the Call to Action on Anti-Racism, Equity and Inclusion published in 2021 – to build a culture of inclusion that values diversity and addresses systemic barriers that could prevent full participation in the Board and its activities.

“Nothing about us without us” – The Board currently employs persons who self-identify as having a disability, with representation of over 10% of the Board’s total workforce. However, given our very small size of 25 employees, this does not represent very many people. Therefore, the Board will move forward with a two-pronged approach to keep the Plan updated as well as relevant to future Board employees :

  • First, the commitments and actions outlines in its first Plan are based on engagement and research results from bigger organizations, reflecting lessons learned and any best practices from a larger representation of persons with disabilities in the Public Service. In consultation with larger federal administrative tribunals, and with the Department of Innovation, Science and Economic Development (ISED), the Board identified the following as barriers:
    • Disabilities and the barriers faced by persons with disabilities are not well-understood.
    • There is reluctance or lack of awareness by some employees to self-identify as having a disability.
    • There is reluctance or lack of awareness by some employees to request accommodation.
    • Managers do not specifically explore or use staffing options or tools to prioritize persons with disabilities.
    • Commonly noted barriers to full participation for persons with a disability can include inaccessible meetings, resources and documents (including email, internal websites, work-related information, software); language used also often inaccessible in both internal and external communications.
    • There is a shortage of internal expertise in creating or procuring accessible tools and documents, or leading accessible meetings.
    • The burden is often placed on the employee to research possible solutions and accommodation, especially for IT equipment.
    • Processes for procuring adaptive or ergonomic equipment, software, tools can be long and unclear.
    • There is no formal existing process to provide in a timely matter alternative formats and communication supports upon request by a user or employee.
    • Accessibility not deliberately considered when new policies and practices are put in place.
    • Change initiatives tend to focus on fixing problems as they are identified, rather than starting from an expectation of accessible design.
    • With the adoption and development of a hybrid approach to the workplace, there is opportunity now to re-evaluate the built environment in planning the return to a physical office.
  • Second, using the first Plan as a basis for engagement and consultation, the Board will create opportunities for dialogue specifically with its own employees who self-identify as persons with disabilities, as well as more generally with all Board employees. The engagement activities will increase awareness, and set its collective foundation for full and inclusive participation in enriching and implementing the first Plan. This will include guidance and training for all Board employees on accessibility, accommodation and common barriers faced by persons with disabilities.
  • A Champion for Accessibility has been appointed from existing employees who identify as persons with a disability, to promote the Board’s objectives and action, and open a channel for continuous awareness-raising and feedback. The Champion includes their work in this role as part of their performance commitments, and will be directly supported by the Secretary General, as the Board’s designated senior official responsible for employment equity, diversity and inclusion.
  • This engagement will also solicit feedback on this Plan and any early outcomes - to ensure that specific gaps and issues of top priority to current Board staff are well-reflected.

Collaboration and Leadership – Given its very small size, the Board cannot achieve its accessibility goals alone, nor can it hope to develop a sustainable inclusive culture without a robust network for information, idea and experience exchange.

To address this, the Board will, early in 2023, join three communities of practice, to expand its network connections and offer its own employees’ views and experiences to the broader federal conversation, at various levels:

  • The Board’s Accessibility Champion will actively participate in the ISED Persons with Disabilities work, and with the Interdepartmental Accessibility Community of Practice, sharing information and best practices between the Board and these networks. The Accessibility Champion will also explore persons with disabilities networks that could be available to Board employees, as the Board is too small to convene an effective internal network.
  • The Board’s Secretary General, as the designated senior official responsible for employment equity, diversity and inclusion, will actively participate on the ISED Accessibility Feedback Panel, and will continue to engage colleagues in other federal administrative tribunals and micro-organizations to share lessons learned, best practices, and potential areas for collaboration.
  • The Board’s Vice-chair and Chief Executive Office will leverage her role as Chair of the Council of Federal Administrative Tribunals Chairs to raise awareness on this issue and facilitate the sharing of best practices as a means to increase access to justice across the federal administrative justice system.

Transparency and Sustainability – Over the past three years, the Board has reiterated its commitment to greater efficiency, predictability and transparency across its judicial proceedings and practices. Significant organizational change to this effect has required time, committed leadership, and continuous engagement from all Board stakeholders.

The Board’s Accessibility Plan has been created with the same approach in mind – recognizing the overall importance of developing, in collaboration with Board employees, with its interdepartmental community, and with its stakeholders, an organizational culture that consistently supports an accessible environment that is attractive to a diversity of employees and stakeholders, including persons with a disability. An inclusive culture is at the heart of sustainable, transformative change.

Given its very small size and capacity, the Board must often adapt to unpredictable pressures and challenges that may lead to changing priorities and re-focusing efforts. These circumstances could affect timing on some of the concrete planned activities below. While it may need to be flexible, the Board will not compromise on transparency, and commits to regular monitoring and reporting on its progress, as described below.

Feedback process

The Accessible Canada Act requires organizations to establish a departmental process for receiving and dealing with feedback regarding the implementation of the accessibility plan. The Board has established channels for public and employee feedback through its internet website.

The Board is dedicated to continuous improvement and aims to deliver accessible services to our employees, collaborators and stakeholders. The Secretary General and the Accessibility Champion for the Board will be responsible to regularly monitor and evaluate the feedback, raise it with their interdepartmental communities of practice, and report quarterly to the Board management table to ensure its consideration in Board future plans, when possible.

If you have any questions, feedback or suggestions, please contact the Board by:

  • By email at secretariat@cb-cda.gc.ca
  • By telephone at 1-833-860-7131
  • By mail to the attention of the Secretary General, Copyright Board of Canada, Suite 800 - 56 Sparks  Street, Ottawa, Ontario, K1A 0C9
  • By fax to 613-952-8630
  • Online Through the Accessibility feedback form

Priority areas identified by the Accessible Canada Act

This section is an overview of how the Board plans to address the Government of Canada’s Accessibility Strategy and its goals, and what the Board hopes to achieve before its next iteration of the plan.

1. Employment

The Board plans to implement government-wide initiatives and increase representation of persons with disabilities across all occupational groups and levels. As such, removing and preventing barriers to recruitment and retention, and the promotion of persons with disabilities are priorities. The Board will start by focusing on three barriers to employment commonly identified through internal consultations across departments :

  • overall, disabilities are generally misunderstood - more awareness and engagement is required for the Board to become a more accessible workplace;
  • managers may not understand how to staff and support persons with disabilities; and
  • employees are often reluctant to self-identify disability.

In order to break down these barriers, the Board will:

  • Build accessibility awareness and confidence within the organization, by
    • Naming its first Accessibility Champion to engage interdepartmental networks, Board employees and responsible teams to implement the commitments of this plan, and further the goals of the Accessible Canada Act;
    • Adding related Government of Canada-focused training to its mandatory training plan for all employees for 2023-2024;
    • Promoting events and tools available to all employees and to employees with disabilities, across the federal government;
    • Engaging persons with disabilities and all Board employees to create a culture of continuous improvement that supports diversity and inclusion, starting before 2023-2024 fiscal year. This will include a quarterly discussion at the management table on progress across the Board’s diversity, inclusion and accessibility commitments.
  • Roll-out new tools and resources that support safe and supported approach to recognizing and valuing persons with disabilities in the workplace, by
    • Promoting self-identification in MyGCHR once available, to ensure that representation within the Board is accurately portrayed;
    • Implementing the Government of Canada Workplace Accessibility Passport as a tool for employees and managers to exchange accommodation-related information and embrace a “yes by default” approach to accommodation;
    • Continuing to promote flexible work arrangements that support the diverse needs of all employees, while aligning with Government of Canada obligations and organizational requirements. This will include continuing to re-evaluate work arrangements and needs at least once a year (telework agreements are signed on a yearly basis).

Responsible: Corporate Services, Accessibility Champion and Secretary General, Management

2. Built environment

The physical workplace can present multiple barriers to persons with disabilities, including a lack of automatic door openers, poor signage and space restrictions. In the first survey on the development of the federal strategy, respondents also noted that physical workspaces do not account for invisible disabilities such as environmental sensitivities, chronic pain, anxiety and autism.

The Board recognizes the importance of an accessible physical environment to support persons with different abilities. Over the past 2 years, the Board has provided access to ergonomic evaluations for their home workspaces, equipped all employees with ergonomic equipment at home and in the office, and re-designed the workplace offices to meet the different needs of employees returning to a hybrid work situation following the Covid-19 pandemic.

The Board recognizes there is more that needs to be done. To this end, the Board will:

  • Review its safety and resource plans with the mindset of “inclusive by design” and “accessible by default’’, by
    • Completing its review of the emergency and evacuation plan with accessibility considerations, and ensure that all employees are aware of the procedures to follow, including who to communicate with if they require additional support;
    • Adopting, in consultation with employees, an inclusive design checklist for accessibility considerations (including safety, ergonomics and signage);
    • Establishing a regular procedure using the inclusive design checklist to review its work and common spaces and dialogue with Public Services and Procurement Canada/ facilities management to ensure its workplace meets accessibility requirements and employee needs.

Responsible: Corporate Services, Management

3. Information and Communication Technologies (ICT)

Since March 2020, Board employees have been working primarily from home on a full-time basis. Over this period, the Board, supported by the Department of Innovation, Science and Economic Development (ISED) with varying success in offering and providing accessible information and communications technology (ICT). In particular, two barriers to accessibility were raised within the Board, and have been echoed in a number of departmental consultations:

  • Challenges faced by employees and by our very small Corporate Services team to research possible solutions and accommodation for Information Technology (IT) equipment;
  • Lack of awareness and skills among employees regarding creating accessible content and generating accessible documents.

With the transition to a hybrid workplace officially underway, the Board will :

  • Put in place the necessary capacity and capabilities to address accessibility barriers in ICT, by
    • Liaising directly with the Accessibility, Accommodations and Adaptive Computer Technology initiative at Shared Services Canada, and participating, to the extent possible, in their Lending Library Services Pilot Project to facilitate quick access to short-term accommodations adaptive technology, services, and tools for Board employees;
    • Identify tools and supports for accessible ICT that are or could be employed by Board staff and Board Members, in the context of renewing the Board’s Memorandum of Agreement for IT Services provided by ISED

Responsible: Corporate Services

4. Communications other than ICT

The Board is dedicated to ensuring that all its communications, whether internal or external, are accessible, and available in alternative formats in a timely manner. This includes ensuring that our communications and products available to the public are in plain language, and are published in line with accessibility standards.

The Board has already implemented a number of initiatives to this end, in support of its access to justice priorities, such as:

  • Board-sponsored training for all employees and Board Members on plain language decision-writing for administrative tribunals;
  • Full review and re-design of the Board’s public website to ensure easy access, plain language, and coherence with GC-related accessibility guidelines;
  • New procedures in place to ensure its online publications (Annual Report, Departmental Plan, Departmental Results Report, etc.) comply with GC-related accessibility guidelines.

In addition, the Board has recently begun to increase the number of documents it publishes online, to promote maximum transparency of its practices. However, there is currently no formal process to respond to external or internal requests for alternative formats and communication supports in a timely manner upon request. Since 2020, the Board has prioritized a hybrid oral hearings model. To address and prevent systemic barriers to accessibility linked to its new initiatives, the Board will:

  • Adopt internal procedures and clear responsibilities for public-facing communications to be in plain language, and for all documents to be made available per the latest Web Content Accessibility Guidelines (WCAG), the GC’s Standard on Web Accessibility, and the Standard on Web Interoperability;
  • Develop accessibility toolkit for Board employees, to support accessible content and documents and accessible meetings by default for internal and stakeholder engagement purposes;
  • Collaborate with other administrative federal tribunals, and develop new accessibility guidelines for hybrid hearings at the Board.

Responsible: Corporate Services and Registry

5. The procurement of goods, services and facilities

With a total operating budget of approximately $800,000/ year, the Board does relatively little procurement of goods and services. That said, the Board will contribute, to the greatest extent possible, to ensuring procured goods and services are accessible by design so that Canadians with disabilities can use them without adaptation. The Board also procured new office equipment with accessibility standards in mind, recognizing that employees will share work spaces, and must be able to tailor them to their own abilities and needs. The Board also provided ergonomic assessments and access to ergonomic equipment required by Board employees, whether working from home or at the office.

To address and prevent systemic barriers to accessibility linked to these new initiatives, the Board will:

  • Liaise with the Accessible Procurement Resource Centre at Public Services and Procurement Canada for guidance on how to meet new obligations regarding the consideration of accessibility in procurement;
  • Include a checklist for accessibility considerations into Board procurement justification templates, to ensure these have been taken into account for all procurement activities.

As noted above, a commonly raised barrier to accessibility experienced by public servants is that procuring adaptive equipment is slow and not well-supported. In working with the Lending Library Services Pilot Project for short-term (noted above), the Board will:

  • Track timeliness and completion with respect to accommodation requests, to measure rapid access to accessibility tools and equipment.

Responsible: Corporate Services

6. The design and delivery of programs and services

The GC Accessibility Strategy challenges all federal organizations to assess their programs, in consultation with persons with disabilities, to identify and remove barriers for persons with disabilities, to build accessibility into new policies and programs, and to develop data on client satisfaction from the perspective of persons with disabilities.

Consultation with larger federal organizations indicate the following common barriers in this area:

  • Accessibility is not systematically or transparently considered when new policies and practices are put in place;
  • Problematic to fix problems as they are identified, rather than start from an expectation of accessible design.

At this time, the Board does not proactively identify or seek information about the accessibility or accommodation needs of its clients, nor does it build accessibility criteria into its internal policies and practices. In order to break down and prevent barriers in this area, the Board will:

  • Build into upcoming reviews of internal and external policies, practices and rules to eliminate barriers and support access to persons with disabilities. This includes renewal processes for the Board’s Memoranda of Agreement with other departments for many internal services, including staffing, classification, labour relations, financial management, etc.;
  • Establish formal procedures for providing employees or the public with alternate formats of its publications, upon request;
  • Prepare standard communication for stakeholders who wish to participate in Board tariff or licensing activities, to identify early in the process, any accessibility requirements for the Board to address with participants;
  • Include accessibility considerations and questions in upcoming stakeholder consultations on Board processes.

Responsible: Corporate Services and Registry

7. Transportation

This priority area under the Accessible Canada Act does not apply directly to the Board. However, the Board’s commitment to increase the use of hybrid oral hearings should promote access and participation opportunities in the hearings for persons with disabilities who would otherwise have difficultly engaging transportation to reach the Board’s hearing room, located in Ottawa’s downtown core.

Consultations

As highlighted in Section A of this Plan, the Board is committed to involving persons with a disability in the design and implementation of its accessibility planning moving forward, to ensure that their unique and valuable perspectives and experiences are reflected and respected.

Given its limited resources, small size of 25 employees, and an even smaller number of persons self-identifying as having a disability, the Board took the decision to develop the first iteration of its Accessibility Plan as a basis for meaningful internal consultation. The Plan therefore is grounded in feedback provided through broader consultations in larger departments, with ISED in particular, as the Board’s portfolio partner. Having a broader range of feedback to guide internal discussions will support an accessible organization for current and potential Board employees and stakeholders. Its initial planned activity, therefore, will be to engage the few Board employees who self-identify as having a disability, as well as (separately) all employees, in prioritizing and shaping the actions within the Plan.

Implementation, monitoring and reporting

In order to ensure that accessibility remains a constant priority within the government, the Accessible Canada Act dictates that regulated entities prepare and publish annual progress reports on the implementation of their accessibility plans. These progress reports must be prepared in consultation with persons with disabilities and present the feedback received (if any) and how that feedback was taken into consideration.

The Board's first progress report will be published in fiscal year 2024-2025, It will include a “diversity, inclusion and accessibility” dashboard, as a transparent tool to report on concrete progress made in achieving the commitments outlined in its Accessibility plan over the first two years, including report on continuous feedback from Board employees.

As specified in the regulations, GC organizations must publish a revised plan every three (3) years. As such, the Board’s first revised accessibility plan will be published in December 2025.

Glossary

Access to Justice

means a people-centered approach to justice that puts consideration of the individual at the heart of Canada’s rule of law, by providing access to information, programs and policies.

Accessibility, Accommodations and Adaptive Computer Technology

The Accessibility, Accommodation and Adaptive Computer Technology Program of Shared Services Canada provides a wide range of services, on a cost-recovery basis, to help integrate employees with disabilities, injuries and ergonomic requirements and who require access to systems, programs, information, computers and computer resources.

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.”

Government of Canada Workplace Accessibility Passport

The Government of Canada Workplace Accessibility Passport helps address the obstacles federal public service employees and applicants with disabilities face in obtaining the tools, supports and measures to perform at their best and succeed in the workplace. It facilitates recruitment, retention, and career advancement for persons with disabilities. The Accessibility Passport facilitates employee mobility between GC organizations. It is meant to follow each employee and it is an evergreen document that can be updated throughout a career.

"Nothing about us without us"

"Nothing about us without us" is a guiding principle used across the Government of Canada to communicate the message that no policy should be decided by a representative without the full and direct participation of the members of the group affected by that policy.

Self-Identification Modernization Project

In September 2020, the Treasury Board Secretariat launched the Self-Identification (self-ID) Modernization Project to increase the accuracy, depth and breadth of the data across government. The project explored ways to reduce stigma associated with self-identification for all employment equity groups. Following extensive research and consultations, a new questionnaire was co-designed with employees from various diversity networks.