RCMP Accessibility Plan 2023-2025: Progress Report 2024

Accountability and governance

The accountability for implementing the Accessible Canada Act in the RCMP lies with the defined Accessibility Leadership. Accessibility related proposals go through the organization's existing governance structure ^{Footnote 1} in an effort to ensure that across the RCMP, we are embedding accessibility priorities in order to collectively advance this work.

Accessibility leadership

RCMP Governance

Contact information for feedback

Below is a description of our feedback process, which will facilitate the provision of anonymous feedback both internally and externally:

• The present Accessibility Plan and progress reports are to be published on the RCMP internal and external website. They will also be published on open.canada.ca
• The designated person for receiving feedback is Galina Ivanova, Employment Equity Research Analyst and Project Coordinator, at the following email address: rcmpaccessibility-accessibilitegrc@rcmp-grc.gc.ca
• A survey is published on the RCMP website, which will capture employee and client feedback on the implementation of the present Accessibility Plan
• As they are surfaced, issues will be addressed through governance structures
• Periodically as the Accessibility Plan is updated, it will reflect the feedback received
• A person may use the contact information listed to request a copy of the feedback process description in an alternate format
• The RCMP will ensure acknowledgement of receipt of all its feedback if it is not received anonymously
• Feedback received will be acknowledged in the same manner in which it was received unless it was received anonymously

Contact information to reach out to the RCMP

By email

The designated contact person for receiving feedback or for an accessible version of this document is Galina Ivanova, Employment Equity Research Analyst and Project Coordinator, at the following email address at rcmpaccessibility-accessibilitegrc@rcmp-grc.gc.ca

By mail

Anti-Racism, Equity, Diversity and Inclusion Secretariat
73 Leikin Drive
Mailstop 52
Ottawa ON  K1A 0R2

By toll-free number

1-833-690-3508

Desired outcome

The overall desired result for Communication (Other than Information and Communication Technologies) is to ensure existing and new communication content are accessible for all users.

Barriers identified in the Accessibility Plan

• Ambiguous policy and program governances
• Poor leadership awareness or training in Inclusion and Diversity
• Lack of awareness of the needs of the disability community
• Lack of communications in accessible, plain language formats and related training

How have we progressed in removing or preventing barriers identified in the Accessibility Plan?

Work continues in the RCMP to remove barriers identified in the areas of communication (other than ICT). Policies are being redefined to be less ambiguous and more streamlined. Program governance structures are being realigned to accommodate the needs of persons with disabilities in the RCMP. The organization's Accessibility Pillar Leads Taskforce continues to align the accessibility work that is being done on several pillars.

Diversity and Inclusion, Anti-Racism, and Leadership training continues for senior leadership. For example, the following courses remains mandatory for all employees including senior leadership:

1. Uniting Against Racism Learning Series
2. Cultural Awareness and Humility Course

There is a need to implement more awareness and training on accessibility for senior leadership and employees. The RCMP is now creating performance management objectives for executives to measure progress made in accessibility and inclusion in their teams. This includes awareness of the Accessible Canada Act and their obligations to the RCMP Accessibility Plan.

Since the Spring of 2022, the RCMP National Learning Services continues to take the necessary steps to educate the division on the importance of accessibility and the requirements of the Act. In this progress cycle, National Learning Services has shifted focus from awareness to planning and laying the foundation for conversion. They have also begun drafting the Accessible eLearning Strategy, the first of the three strategies to address accessibility in learning within the purview of Learning and Development.

The RCMP fully supports the Government of Canada's awareness campaigns, including the National Disability Employment Awareness Month and Persons with Disabilities programming. Key awareness campaigns, resources and tools are being socialized across the organization to promote the full implementation of the Accessibility Strategy on an annual basis. E-newsletters and web pages are fully dedicated to such communications. RCMP employees are invited to participate in such awareness campaigns run by Government of Canada and the Office of Public Service Accessibility. This includes training on the passport and other Office Public Service Accessibility sessions. The RCMP is also promoting, attending and sharing Government of Canada accessibility network meetings to promote accessibility knowledge sharing across the federal government.

The RCMP is promoting, attending and sharing Government of Canada accessibility network meetings to promote accessibility knowledge sharing across the government of Canada.

The search for an Executive National Champion and Divisional Co-Champions for Accessibility has begun with consultations from Disability Networks and key stakeholders. Efforts are being streamlined to keep communications in accessible and written in plain language. As accessible communications offer challenges with the availability of resources within the RCMP, there is a look out for communication consultants who understand issues that people with disabilities face and who can operate in the Accessible medium

Communications Matters: A Communication Strategies Pilot Project for Law Enforcement in Manitoba, Canada

Project Co-Creators:

• B. Adam
• A. Allen, Bachelor of Arts, Master of Science - Speech-Language Pathology, Certificate of Clinical Competence in Speech-Language Pathology
• A. McDougall, Master of Occupational Therapy, Registered Occupational Therapist (Manitoba)
• S. McRuer, Master of Occupational Therapy, Registered Occupational Therapist (Manitoba)
• G. Whelan, non-commissioned officer in charge

The Communication Matters pilot project team included speech-language pathology, occupational therapy, local law enforcement (Royal Canadian Mounted Police), and individuals with lived experience; including an individual who had been employed as a law enforcement officer (Winnipeg Police Services) prior to their disability.

Background

In 2019, the Government of Canada acknowledged that people with disabilities are more likely to have encounters with the criminal justice system, whether it is as a victim, a witness or a perpetrator. There is an increased likelihood of:

• Experiencing physical, mental, and/or sexual abuse (Bryen, N.D., 2003, & Togher, M., 2010)
• Experiencing miscommunications with law enforcement officers, and/or the judicial system
• Lacking disability-related supports (Collier, B., 2006)
• Being questioned by law enforcement (Rava, J., 2017)
• Incarceration

To the team's knowledge, despite a variety of legislation, no formal training exists for local law enforcement officers across Canada on how to effectively communicate with people who have speech, language and/or communication disabilities.

The pilot project involved a 3-hour  presentation for local law enforcement officers and administrative staff. There were various presentation formats used, including:

• Lectures
• Videos
• Case studies
• Interactive sessions

Focus of training content

• Indicators of potential speech, language and/or communication disabilities
• Background information about specific disabilities that may impact communication
• The differences between brain injury and intoxication were emphasized
• The availability and importance of Communication Intermediaries for situations where formal interaction could be scheduled
• Universal communication techniques and strategies were highlighted for in-the-moment interactions

Course audit

This course was audited by a Senior Accessibility advisor from National Headquarters, RCMP and it was found that:

The course was remarkable and resonated with the work that the RCMP is doing on Accessibility. It was engaging on different levels as it was very interactive and the instructors engaged the audience with their excellent knowledge of their subject matter. The instructors also had a very professional manner and their subject matter aligned to the examples that they presented to the audience. The use of communication devices during the pilot also highlighted the requirement and usefulness of these devices in the engagement with persons with communication issues.

The introduction of a former Winnipeg police officer with communication challenges due to a disability was instrumental in highlighting the uniqueness of this course. Everyone was impacted by his struggles and his courage in overcoming the challenges he faced through the use of advanced communication devices. The scenario exercises also highlighted this. There are plans underway to make this course available to all police officers in the RCMP, so that there is greater awareness of individuals with disabilities with communication difficulties may be understood.

Virtual Remote Interpretation service for sign language interpretation

The RCMP is committed to supporting the federal government's goal to create a barrier-free Canada by January 1, 2040. To address accessibility-related concerns, the RCMP's Anti-Racism, Equity, Diversity, and Inclusion Secretariat will oversee the acquisition and rollout of an on-demand Virtual Remote Interpretation service for sign language interpretation. Assessments and reviews of current products are already underway, and the pilot phase of the RCMP's Virtual Remote Interpretation program is set to launch in several detachments across British Columbia in early 2025.

Desired outcome

To recruit, retain and promote persons with disabilities and offer timely workplace accommodations.

Barriers identified in the Accessibility Plan

• A lack of effective employment equity analysis and benchmarking of recruiting, retention and promotions rates for employees with disabilities
• Lack of equity, diversity, and inclusion training and disability management
• Lack of disability recruitment milestones for Public Service Employees, Regular Members, Civilian Members and students
• Inefficient staffing practices recruitment of persons with disabilities

How have we progressed in removing or preventing barriers identified in the Accessibility Plan?

In 2024, the RCMP continues to work towards the development of a software system that will capture EDI data that will support the organization in conducting employment equity analysis. Analysis will be conducted of the RCMP HR systems and stakeholder sessions are being held to inform the software. Once the software is set up, this will be effective in identifying where systemic barriers exist in staffing processes at the corporate and hiring manager levels, as well as possible solutions.

The RCMP continues to participate in the Government of Canada’s modernization of the self-identification questionnaire and inclusion campaign software systems set up process, and has participated in all stakeholder meetings. The data collected through this new questionnaire will better describe the organization workforce employment equity and diversity, inform recruitment and retention goals, shed light on diversity gaps, and inform RCMP programs and policies.

RCMP Labour Relations Advisors continued their training in disability management, the Government of Canada Workplace Accessibility Passport and Accommodation throughout 2023-24. The training is led by facilitators from the RCMP's Accessibility and Disability Network, who are certified as trainers by the Government of Canada Accessibility Office. The Network continues to be a source of consultation for this training.

The following RCMP Staffing initiatives continue to have a positive impact on accessibility:

• In 2020, sub-delegation training moved from in-class, facilitator-led, set schedule to online, self-directed/paced, on demand, which enables the learner to have greater control over the learning experience
  • Access for persons with physical and learning disabilities improved as the use of Agora in the design/delivery of training meant adoption of industry-standard look and feel (in contrast to non-expert designed PowerPoint decks), which improves accessibility for some with learning/cognitive/visual disabilities
• In 2021, Inclusive Hiring Practices for a Diverse Workforce (COR120) was integrated in the sub-delegation curriculum
• In 2023, rolled out changes to policy, delegation framework in response to July 1 coming into force of Public Service Employment Act changes related to bias and barriers in assessment

In 2024, RCMP Corporate Staffing actively participated in the Anti-Racism, Equity, Diversity and Inclusion Secretariat-led Diversity Retention and Employee Advancement Model workshops by delivering presentations on the promotion process and career planning for all categories of employees. Members of the Corporate Staffing Policies and Promotions team attended these events, in person, ensuring they were present to answer participants' questions and to take part in exchanges to better understand employee experiences to inform future efforts to identify and remove biases and barriers. As the employer's return to office mandate is implemented, a strategic consideration from Corporate Staffing would be the need to analyse the impact on persons with disabilities and their participation in staffing processes and subsequent appointments. Corporate Staffing anticipates challenges in promoting the public service as an accessible workplace, and in attracting persons with disabilities talent

The RCMP is also making progress in terms of self-identification/inclusion campaign under the guidance of the Treasury Board Secretariat and other initiatives to improve information about diverse groups, including employees and potential employees with disabilities.

As part of Treasury Board Secretariat's commitment to the 2023 Office of the Auditor General report, it is anticipated that the Treasury Board Secretariat Self-identification initiative will be launching by December 2024. Self-identification is an opportunity for employees to voluntarily identify as belonging to one or more of the four designated groups listed in the Employment Equity Act which includes visible minorities, Aboriginal peoples, persons with disabilities, and women. Self-identification gives a demographic portrait of the employment equity representation workforce within RCMP. The data collected is used to identify the specific barriers or issues the employees from the designated groups face and helps RCMP plan for the future, monitor progress and take action to maintain workforce representation. RCMP is currently working on a communication plan and will launch a blitz campaign to encourage new and current employees to fill out the questionnaire as accurately as possible. Communication pieces are currently being developed such a Frequently Asked Questions for employees and manager's toolkit to support the campaign and encouraging all employees to participate on the accuracy profile of RCMP workforce.

Desired outcome

To have welcoming, barrier-free access to RCMP buildings, offices and facilities across the country.

Barriers identified in the Accessibility Plan

Barriers are faced by clients and employees with respect to:

• Accessible parking places not available
• Accessible pathways and doorways
• Accessible washrooms
• Accessible issues with service animals in the workplace

How have we progressed in removing or preventing barriers identified in the Accessibility Plan?

The RCMP's Real Property and Environmental Management Branch's Property Management Manual requires that RCMP-owned and leased facilities are accessible and barrier free and meet the requirements of the Standard on Barrier-Free Access to Real Property as outlined in the Directive on the Management of Real Property as outlined in Appendix D: Standard on Barrier-Free Access to Real Property. In addition, RCMP Real Property has developed a common design for small-sized detachments which includes inclusive locker room and barrier-free access features. To date, 20 RCMP detachments currently have operational inclusive washrooms, and more than 20 additional projects are planned.

In November 2023, Real Property and Environmental Management Branch signed a Memorandum of Understanding with Accessibility Standards Canada to assist in the creation of common progressive, research-based built environment accessibility best practices and standards to be implemented, where feasible, in RCMP facilities and sites. This agreement allows Real Property to regularly consult Accessibility Standards Canada on standards and best practices to improve technical standards and guidance for the RCMP real property community and make our facilities more accessible.

Real Property and Environmental Management Branch is also engaging with Public Services and Procurement Canada to develop a multi-year plan to complete facility accessibility audits, with a focus on public access space and facilities where the RCMP has specific duty to accommodate requirements.

Desired outcome

The overall desired result for Designs and Delivery of Services and Programs is to ensure In-person, phone and online client services are accessible for persons with disabilities.

Barriers identified in the Accessibility Plan

• Availability of disability management services for Public Service employees
• Modest understanding of Accommodation, Disability and Disability Management by RCMP Managers, Supervisors and Labour relations Advisors
• Disability Management seen as adversarial by management and employees

How have we progressed in removing or preventing barriers identified in the Accessibility Plan?

In 2024, RCMP Duty to Accommodate guidelines is being updated and consulted upon with persons with disabilities in this progress cycle. The Government of Canada Workplace Accessibility Passport has been also be launched in 2023-24 training cycle.

Future progress reports will see:

• training for managers on updated disability management guidelines
• program and policy review of, and update of, the Bias Free Policing Program and the Service Animal Program

Every organization in the federal public administration is subject to the Canada Labour Code, Part II: Occupational Health and Safety, and all federal government employees are covered for workplace accidents causing injury and diseases contracted on the job under the Government Employees Compensation Act, with the exception of regular force members of the Canadian Forces and police officers and civilian members of the RCMP. The three basic components of disability management are prevention, support for recovery, and accommodation.

At the RCMP, Labour Relations works closely with managers to coordinate the accommodation phase of disability management, which includes obtaining information to identify work-related barriers, exploring options for accommodation, and establishing a return to work plan. Public Service Employees have access to leave for injury on duty, workers compensation and long-term disability benefits (disability insurance). Represented employees also have the support of their union representatives to provide them with advice and guidance throughout the process. Currently, disability management is decentralized with the labour relations corporate policy centre operating as a centre of expertise for divisions.

Over the past year, the RCMP consulted with bargaining agents, employee networks and divisional labour relations to identify gaps and to develop options for strengthening disability management programming for public service employees. In order to promote a better understanding of the duty to accommodate, the Corporate Labour Relations Unit delivered training sessions on topics such as the newly launched Government of Canada Workplace Accessibility Passport in partnership with the RCMP Disability and Accessibility Employee Network. It has also developed tools, guidance and communication related to disability and other protected grounds such as family status.

The Chapter on the Duty to Accommodate (Public Service Employees) in the Public Service Manual was also updated, following consultation with bargaining agents via the National Policy Health and Safety Committee, and now includes the updated links and resources such as the Disability Management Handbook for Managers and the Workplace Accessibility Passport Guidance for Managers. This approach is tailored to ensure that labour relations practitioners and managers are equipped to address workplace barriers and enable the full participation of all employees.

All these activities have been achieved without increasing existing resources. The creation of a disability management unit or center to centralize these services will require moderate to significant investment, which is difficult during a period of budgetary restraint. Despite these challenges, the organization will continue to strive to create a positive work environment based on inclusiveness and equity.

The Government of Canada Workplace Accessibility Passport, lead by the Office of Public Service Accessibility (OPSA), is a key initiative aimed at improving inclusivity and removing barriers for individuals with disabilities within the workplace. This Passport allows employees to easily communicate their accessibility needs and ensures that accommodations are readily available across different sectors. In collaboration with the Office of Public Service Accessibility and the RCMP, the initiative includes a series of introduction and training sessions designed to educate RCMP employees, including managers and supervisors, on the effective use of the passport, which were delivered in the Fall of 2024. These sessions help ensure that officers and employees are equipped to meet accessibility requirements, and fostering a more inclusive environment in both workplace and community interactions. This partnership highlights the Government of Canada's broader commitment to creating accessible and equitable workplaces for all Canadians.

The RCMP delivered information sessions to 549 employees on the Accessibility Passport during 2023-24 (see below). Sessions will continue to be delivered in 2024-25.

Desired outcome

To ensure our organization has relevant, up-to-date technology and information management infrastructure that meet the needs of persons with disabilities.

Barriers identified in the Accessibility Plan

• Training and support for adaptive IT tools and technologies required
• Accessible documents in the workplace required
• Accessible Learning content required
• Detailed accessibility assessment of Human Resources Management Information System required

How have we progressed in removing or preventing barriers identified in the Accessibility Plan?

In 2024, the RCMP continues to create and maintain internal and external committees to implement and monitor progress. This will also kick start the process of creating an Information and Communication Technologies framework for accessibility, with input from employee networks. In the near future, processes will be put in place to enhance training and support for adaptive IT tools and technologies

National Learning Services within Learning and Development have been working towards creating accessible training since the Spring of 2022 and with the each passing year, the understanding of accessibility grows and the ability to overcome the challenges the RCMP faces improves.

In 2024, the focus became less about awareness and more about planning and laying the foundation for eLearning course conversion. National Learning Services has begun drafting the Accessible eLearning Strategy, the first of three strategies to address accessibility in learning within the RCMP.

Some of the work being done around computer applications systems and the challenges posed are as follows.

Microsoft Power Portal applications, which are being developed, not the older Java/WebLogic applications, have issues with accessibility and responsiveness, they do not work well on smaller devices like phones or tablets.

On the other hand, the older Java-based applications are mostly compliant with the Web Content Accessibility Guidelines, allowing for better control over how content is shown to users.

However, Microsoft Power Portal applications provide developers with much less control over the HTML code that determines how the content is displayed to users.

This lack of flexibility makes it harder to fix accessibility and design issues. In contrast our Java-based environments give developers almost full control over the content's HTML, allowing them to easily adjust and ensure that the applications meet accessibility and design standards.

Even properly applying the Web Experience Toolkit templates to the Power Portal applications has been challenging for the teams working on them. These applications are also non-responsive and struggle to work on smaller screen devices. In contrast, Java applications don't face these issues

On the Power Platform/Dynamics side, the RCMP is working with Microsoft to address accessibility issues. The RCMP (Martin Richer team) have a link that tracks the accessibility problems with Microsoft products, showing them as they get fixed.

For other teams, there's not enough oversight in the development process to make sure accessibility, security, and user experience are applied consistently. This means applications do their best to meet these goals, but without clear guidelines that fit our system. This is why the RCMP needs a Systems Architect to lead development and organize the custom development teams so they can work together toward shared goals. This is something that will be looked into.

Some teams understand the challenge of making government applications accessible using the Web Experience Toolkit, which gives these apps a consistent look. However, Web Experience Toolkit must be implemented correctly to ensure accessibility, and it's not just about using the templates as they are. Often, the focus on delivering features is stronger than the focus on accessibility or security. The RCMP needs to shift from its current "waterfall" method to a more flexible "agile" approach, with a focus on quality assurance and realistic timelines.

There is automated accessibility testing that can be done once our DevSecOps pipelines are approved. This will help ensure all applications are tested for accessibility during the build process. This article does a good job of explaining that accessibility testing can't be fully automated because automated tools can only check for known code patterns that miss accessibility features. The final test needs to be done on various devices to see how accessible the application really is. Some SaaS tools, like the one mentioned in the article, might help, but the RCMP needs to figure out what accessibility challenges users face. Then, development teams can start by addressing the needs of known users and grow from there.

The RCMP is looking at ways to work with Canadian Digital Services and the Communications Security Establishment to improve our development processes and DevSecOps implementations.

Desired outcome

To ensure accessibility criteria are considered when buying goods, services and facilities, and products include accessibility features where appropriate.

Barriers identified in the Accessibility Plan

• Need for procurement and contracting processes that reflect accessibility-related goods and services to support employees and clients with disabilities
• Lack of central fund for the purchase of workplace related goods and services to facilitate accommodation

How have we progressed in removing or preventing barriers identified in the Accessibility Plan?

The RCMP is continuing to create the governance structure to create and maintain internal and external committees to implement and monitor progress. Between 2023 through 2025, the RCMP will ensure accessibility criteria are fully understood and included as part of performance indicators. Here are some of the highlights for this year:

• The RCMP Procurement Strategy Review (PSR) form requires that the Procurement Officer documents procurement considerations related to accessibility by summarizing how the requirement includes accessibility criteria or otherwise indicate that an attestation, the Accessibility Justification form, signed by the client is on file.
• Direction provided to RCMP Procurement Officers is based on requirements identified in the Accessible Canada Act. The Act seeks to create a barrier-free Canada through the proactive identification, removal and prevention of accessibility barriers in seven priority areas, including the federal procurement of goods and services.
• The following resources are provided as references to consider when working with the business owner:
• PN-142 Procurement Requirements for Accessibility
• Accessibility Learning Series
• Accessibility Hub
• The National Procurement Policy Centre (NPPC), reviews accessibility considerations included in the PSR and provides feedback during quality control pre-reviews, including consideration of rationales for when accessibility does not apply. Procurement officers are also encouraged to send their Statutory Orders and Regulations (SOR) / Statement of Work (SOW) to the Accessible Procurement Resource Centre (APRC) for feedback on where accessibility considerations could be included.
• Training sessions on how to incorporate accessibility into procurements are offered on a regular basis by the Accessibility team at Public Services and Procurement Canada. NPPC encourages attendance at these learning sessions by sending reminders and meeting invitations to the Procurement community.
• In the most recent training session, APRC reminded the attendees that there is a wealth of information on their GCpedia page.
• Accessible Procurement Resource Centre is working on developing reference materials for Procurement Officers to use when developing solicitations for goods and services, which will include suggestions for common accessibility considerations. RCMP Procurement will leverage this materiel once available.

Desired outcome

To ensure the RCMP's transportation framework embeds accessibility and aligns with all accessibility requirements.

Barriers identified in the Accessibility Plan

• Lack of guidelines for accessible transportation to RCMP facilities in every region
• Updated review of transportation network

How have we progressed in removing or preventing barriers identified in the Accessibility Plan?

In 2024, the RCMP is continuing to create the governance structure to maintain internal and external networks to monitor progress. This will commence the review of the transportation framework including policies, programs, procedures and infrastructure (that is, vehicles). In the near future, the organization will update, streamline and improve processes for meeting the needs of employees with disabilities for adaptive transportation tools and technologies, including guidelines for accessible transportation in every region.

In an effort to meet the needs of employees with disabilities, the RCMP will consult with other similar operational government departments, the Persons with Disabilities networks and internally to assist in identifying accessibility strategies. Given the geographical dispersion of the RCMP over 700 detachments and policing across the country, often in remote and/or thousands of small communities with limited resources, the RCMP does not provide an internal transportation network for employees or the public. The public relies on locally provided transportation options in those communities should they wish or need to travel to an RCMP office. In communities where there is no transportation network the RCMP officer may choose to travel to the public's residence or business to conduct police work and or consider alternative methods to address accessible transportation when the need is known.

The RCMP provides transportation resources to its Police Officers in the performance of policing operations and limited transportation options for Public Service Employees for the performance of their duties, which on occasion may also include employees with accessibility needs. Based on this, consultation will be key in ensuring the success of the transportation pillar as it relates to the RCMP Accessibility Plan. It should also be noted that accessibility needs are currently addressed on a case-by-case basis while the RCMP continues to advance the transportation framework related to accessibility.