Accessibility Plan (2023 to 2025): Pillar 4 to pillar 7

Goals and performance measures

Our priority is to ensure that CBSA Communications products and tools are compliant with existing accessibility standards and guidelines (for example, Policy on Communications and Federal Identity, web content accessibility guidelines, etc.).

The following goals are key for Communications over the next 3 years:

1. All CBSA information is produced and distributed in the most accessible manner possible

   Performance measures:

   CBSA communications products are at least 90% compliant with the Government of Canada’s Accessibility Standard.

2. CBSA audience (external and internal) can equally and equitably access and use all communications products, including websites, videos, social media and graphics

   Performance measures:

   All CBSA communications products are compliant will all other GoC directives on communications and accessibility.

   Note: It is almost impossible to obtain 100% compliance due to the constantly changing nature of the web environment. The CBSA at all times strives towards 100% compliance.

Barriers

Barriers in communication are those that limit an employee or client to receiving the required information needed. Some of the well-known barriers are below:

Government jargon

Government language, particularly legal language can be confusing and intimidating to people. The use of plain language, including on forms will help to improve understanding, allowing everyone to participate more equitably.

Access to alternative means of communication

Having options to alternative means of communication such as assistive listening devices, or speech-to-text tools and software will aid those with hearing impediments or learning disabilities. This is particularly important in the work environment as well as on the frontline, as it reduces reliance on getting support from others and allows individuals to participate independently. Knowledge and awareness is also key for non-verbal communication with persons with disabilities. Access to American Sign Language (ASL) or langue des signes québécoise (LSQ) can further assist internal and external clients.

Medium of communication

While digital communications has increased in importance and makes information more accessible to broad audiences, it’s important to acknowledge that not all people use social media or the internet. The CBSA uses a redundancy model to communicate important information on multiple platforms so that it can reach all Canadians. Collaboration with media outlets is important for those who prefer more familiar sources of communication (e.g. news channels).

Document accessibility

The successful use of screen readers by those who are visually impaired requires that documents be accessible and organized logically. This allows the screen readers to interpret and read aloud effectively the content for those who have visual impairments. This includes using headings, a single column layout and avoiding tables that can make it difficult for screen readers to know what sentence to read next. This applies to all documents, including Word, PDFs and forms.

Action plan

The Communications Directorate is eager to continue working with stakeholders to reduce and eliminate barriers. Investments will be required to allow for the hiring of additional resources to support additional communications audits and to address new barriers found.

Some examples of what could be done should resources be identified and allocated to the Communications Directorate for further accessibility improvements are listed below, in order of the sponsoring branch:

Strategic Policy Branch (SPB) and E-Communications

1. Within the next 4-6 months, engage outside resource to perform a “snapshot” audit of both the external website and Atlas. This would provide a benchmark of compliance of the site and would also provide a report with recommendations for fixes to ensure compliance
2. Between 2023 to 2025, establish a detailed project plan to prioritize work and complete accessibility initiatives on the Web

SPB and Creative Services

1. Between 2023 to 2025, assess current audio-visual material to determine scope, timing and cost required to amend material This would, as above provide a benchmark for compliance with recommendations and costs (as needed). This would assist in the development of future plans and priorities
2. Between 2023 to 2025, plan activities, prioritize work and lead resources to complete work on audio/visual products and the CBSA Daily

Human Resources Branch and Culture Directorate

From 2023 onward, quarterly delivery of plain language and masterclass plain language classes (piloted in Q1 2023 to 2024 fiscal year, and delivered for accessibility in Q2 of 2023 to 2024 fiscal year) geared toward accessible communications to employees across the agency

Accessibility and adaptive technology program scope

The Program was initiated in January 2022 with the mandate to pioneer barrier-free access to the agency’s information, tools and technology, and to respond to long wait times for IT accommodations and a lack of adaptive technologies for persons with disabilities.

This new program has 2 areas of focus:

1. The program prioritizes the research and investment into modern adaptive hardware and software technologies that are used by persons with vision, hearing, speech, or mobility limitations; and the implementation of agile, collaborative and streamlined processes and procedures when it comes to adaptive technologies, to remove barriers and to reduce wait times and access constraints for persons with disabilities. This program, which promotes the new frontier for accessibility and inclusion, is paramount to meet the needs of the current employees and the future planned hires for years to come
2. The IT accessibility competency centre fosters an accessibility-first mindset with respect to IT solutions, seeking to build capacity and expertise in modern accessibility standards. Within this competency centre, an accessibility framework and training program will be developed and implemented, ensuring that agency employees from this point on, are equipped to design and deliver applications and services that are accessible for everyone

Accessibility compliance project scope

The Accessible Canada Act created Accessibility Standards Canada, whose mandate is to develop accessibility standards. As a requirement of these upcoming legislative accessibility regulations, all existing CBSA applications and commercial-off-the-shelf (COTS) solutions will require evaluation and updating to meet accessibility standards. Furthermore, and from this point on, all newly purchased and developed IT products and services must meet or exceed accessibility standards.

The compliance project will be launched in fiscal year 2022-23 to oversee the coordination of the work of CBSA IT stakeholders to help them identify, prioritize and evaluate their current IT assets for compliance. To support this initiative while we continue to build internal capacity in our Accessibility and Adaptive Technology Program teams, training opportunities with leaders in the field of accessibility will be facilitated. Professional services contracts for IT accessibility coaches will also be leveraged to support our IT teams in their commitments to creating more inclusive environments.

The technological scope of this project includes in-flight projects and new major systems launched after 2022, and all regional and national CBSA internal and public-facing IT solutions, as well as all IT tools used by CBSA employees and clients, including:

• Mainframe application interfaces, on all platforms, that interact with CBSA employees and clients
• CBSA in-house developed IT solutions and IT tools that are on various platforms, including java applications
• CBSA in-house modified IT solutions and IT tools that were acquired initially as an open source, a COTS or software developed by vendors or Other Government Departments (OGD)
• IT solutions and IT tools that are not CBSA in-house developed or modified, open source, COTS and software developed by vendors or OGD. Although it is a vendor’s or an OGD’s responsibility to provide accessibility-compliant products, the Accessibility and Adaptive Technology Program will facilitate this compliance work with stakeholders, OGD and the vendors
• Facilitate training for accessibility features on digital communication and collaboration tools for CBSA employees

Goals and performance measures

1. IT priority 1: Adaptive Technology Program: Improve accessibility of adaptive technology solutions.
2. IT priority 2: Accessibility Competency Centre: IM/IT technical resources are equipped to design and deliver applications and services that are accessible for everyone.
3. IT priority 3: IT Accessibility compliance project: All agency IT applications and services are accessibility compliant.

These will be accomplished through the following goals:

1. Make information technology usable by all

   Performance measures:

   1. 100% of all in-scope internal tools and applications meet accessibility standards by 2040
   2. Baseline standards are set for identifying IT applications and tools
   3. Data collection methods are defined
2. Build and provide subject matter expertise on IT Accessibility

   Performance measures:

   1. An Accessibility Competency Centre within Information, Science and Technology Branch (ISTB) has been fully staffed and its services are available
   2. Training and tools are provided to clients
   3. Learning pathways are developed and outlined by IT function
   4. 2 awareness sessions for IT stakeholders are held per month
3. IT colleagues are aware of accessibility requirements, how it applies to their work, and where to go for information and guidance

   Performance measures:

   IT colleagues are surveyed and > 65% respond favourably. (This number will increase once the baseline is established)

4. Increase the timely availability of adaptive technologies

   Performance measures:

   1. A new, defined intake process to request adaptive technologies is created, documented and communicated
   2. Service standards for Intake Process are defined. Baseline created with regular reporting
   3. Intake Process is promoted with hiring managers
   4. 75% of requests are resolved within service standards 75% of the time
5. Employees with disabilities have and are satisfied with the IT tools, technology and equipment that they need to do their job

   Performance measures:

   1. Public Service Employee Survey (PSES) results show improvement in satisfaction rate greater than 10% from baseline 2020 PSES results on employee satisfaction with access to IT accommodations
   2. The Accessibility and Adaptive Technology Program follows up with employees via email within 15 working days of deploying technology solution to gauge satisfaction and address any outstanding questions
   3. 6 months after the Intake Process is defined and published, a survey will be sent to employees to gauge overall satisfaction with the process. Satisfaction reported at 80% or higher
6. Accessibility features are enabled on devices provided to agency employees from the start, including digital communication and collaboration tools

   Performance measures:

   Number of tickets opened to have features enabled decreases by 85% by 2025. (Tickets for support to use the features will not be included in this count)

Barriers

Barriers in information and communication technology can prevent employees and clients with disabilities from fully participating in the workplace and society. Some examples of these potential barriers are:

Access to adaptive technologies

The current process for accessing adaptive technologies at the CBSA is not well known therefore presents challenges for employees who need adaptive technologies to do their work effectively. Access to adaptive technologies is also limited, as security certifications do not exist for all available software and hardware. In the interim, an SLA exists with AAACT which is able to loan adaptive tools and technologies while CBSA acquires its own.

Knowledge and awareness

Lack of knowledge and awareness of what tools, equipment, and technologies are available to support employees with disabilities limits the capacity to have an accessibility-first mindset. Through increased training and development, the Accessibility and Adaptive Technology Program team will continue to build this technical competency to better support employees and clients.

Timeliness of the process

Currently, there is a gap in the onboarding process for individuals who need adaptive technologies. Sometimes, employees may go for extended periods of time without having access to the tools and equipment needed. This can be due to a combination of factors including red tape, lack of management awareness, and limited inventory. A review of the onboarding process to consider time required for equipping employees with adaptive needs will help to ensure that employees are equipped on-time.

Technology and mobile application accessibility

The increasing use of technologies and mobile applications can create inadvertent barriers to individuals with disabilities. For example, biometric iris scanners would pose a challenge to individuals with synthetic eyes. Mobile applications can also present barriers if not designed to be inclusive of those with visual or mobility impairments. The development of the ArriveCan application during the pandemic represented a live test case of challenges that persons with disabilities can experience. Mitigations include clear instructions as well as having redundant options such as paper forms available to support diverse needs.

Action plan

1. Existing and net new applications and services are accessibility compliant:
   1. Baseline compliance (2021 to 2023, and ongoing) - evaluate existing IT products for accessibility compliance
   2. Implement an accessibility compliance project to achieve compliance with TBS-mandated IT accessibility standards (2022 to 2025, and ongoing)
   3. Develop an action plan for improving the accessibility of individual IT programs and services (2022 to 2025)
   4. Implement a professional services contract for accessibility experts to support IT community (2022 to 2025, in-progress)
   5. Implement a contract for professional accessibility training to support IT community (2022 to 2025)
2. Adaptive tools and technologies are available and meet the needs of employees with disabilities:
   1. Establish clear, streamlined processes with defined service standards, to provide adaptive IT tools and technologies to employees who require adaptive IT tools and technologies, including assessment, certification of applications and software, procurement and installation (2022 to 2024 and ongoing: an initial process has been defined and is monitored for effectiveness)
   2. Ongoingly, implement a sustainable and robust Accessibility and Adaptive Technology Program (AATP) by developing knowledge on adaptive technologies through targeted training which includes research, online training, communities of practice (2021 to 2023, internal to the AATP)
   3. Provide employees with timely, efficient access to adaptive/assistive technology, without creating additional barriers (2021 to 2025, internal for ISTB employees)
3. Improve IT Accessibility Governance:
   1. Support ISTB in ensuring accessibility standards are applied for new IT product procurement processes (2022 to 2025)
   2. Support ISTB in ensuring accessibility standards are introduced and “baked” in to project management governance for new IT projects (2022 to 2025)
4. IM/IT technical resources are equipped to design and deliver applications and services that are accessible for everyone:
   1. SMSS will facilitate training and raise awareness to foster an accessibility-first mindset with respect to digital and information-technology solutions (2021 to 2024, in-progress)
   2. SMSS will lead the development of an IT Accessibility Competency Centre providing IM/IT professionals with tools, guidance and training for the development of accessible applications and services (2022 to 2025, in-progress)
   3. Together, SMSS and AATP will improve awareness and access to existing accessibility resources (e.g. checklists for documents, tools and resources currently on ATLAS and Accessibility Assessment ToolKit (AATK) tool, once available, through email blasts, newsletters, training sessions, etc. (2022 to 2025, ongoing)
5. SMSS and HRB together will consult with persons with disabilities (2021 to 2025, and ongoing):

   Performance measures:

   1. Engage employees with disabilities on the accessibility of information tools and technology through surveys and consultations
   2. Staff key positions with persons with disabilities to understand inherently how to address the barriers
   3. Clients will be periodically surveyed on their interactions with the AATP and the support they have been provided
6. Increase program knowledge on accessibility issues:

   Performance measures:

   Develop knowledge about different abilities and disabilities and accommodation solutions in the workplace, through training and consulting persons with disabilities (2021 to 2025, and ongoing)

Goals and performance measures

CBSA’s Policy and programs pillar have 6 key goals for implementation over the upcoming 3 years:

1. The CBSA creates barrier-free policies and programs for employees and clients
2. Clients of the CBSA have access to agency services regardless of ability or disability
3. Agency programs and activities are in compliance with the act and accessible transportation regulations
4. All corporate policies and practices are fully accessible, and people with disabilities are fully integrated into agency operations
5. Agency employees are equipped to develop and manage programs and services that are accessible
6. Policies are informed by the communities that are impacted by the policies

Performance measures include the following:

1. The percentage of employees and clients with disabilities who never or rarely face barriers when accessing CBSA programs, information, and support
2. Conducting surveys and incorporating feedback loops/employee consultation cycles to obtain input on the advancement and improvement of the accessibility of programs and policies
3. Consulting with the program and policy owners to determine the percentage of policies and programs that have been reviewed and updated based on accessibility guidelines
4. Ensuring that feedback from the public is responded to within the established CBSA Service standards

Barriers

The CBSA policies and programs may unfairly discriminate and can prevent individuals from participating fully in their interactions with the agency. These, at times, are unintentionally present within the agency.

The following have been identified as barriers hindering our ability to align with the Government of Canada’s Accessibility Standard.

Knowledge gaps

The concepts being promoted are new to most employees within the branches. New employees also need to be familiarized with CBSA’s accessibility approach. The Government has implemented the use of Gender-based Analysis Plus (GBA Plus) as an analytical method to analyze policies and programs with a diverse lens to understand how various groups could be potentially impacted by our programs and services. The CBSA has a dedicated GBA Plus centre of expertise, as well as made available GBA Plus training for policy advisors and analysts.

Unconscious biases

Unconscious biases negatively impact the community. Being aware of unconscious biases is an important step towards embracing diversity and inclusion, and ensuring our policies and procedures are accessible. There is a need for employees to recognize their own personal biases, learn how to avoid unconscious bias when making decisions, and review their actions, behaviours and beliefs to mitigate biases.

Policies and programs are outdated

In addition to not necessarily being accessible, some of the content of the agency’s policies and programs are outdated (e.g. Enforcement Manual). Updating policy content requires a significant amount of effort and time. This adds an extra layer of complexity as we strive to meet the accessibility guidelines.

Action plan

Several branches have developed multi-year Equity, Diversity and Inclusion (EDI) Strategies. They work towards creating a safe and inclusive work environment for all, including persons with disabilities (status: while some branch strategies have been approved, several are still in the development/approval phase).

The Intelligence and Enforcement Branch has created a Diversity and Inclusion Hub to house various tools and links to assist employees with integrating accessibility standards into day to day activities and help with policy review/development with a lens on accessibility.

Additionally, documents and processes will need to be reviewed to ensure we comply with the act.

Travellers Branch (TB), Commercial and Trade Branch (CTB), Intelligence and Enforcement Branch (IEB) are responsible for the following activities:

1. CBSA will continue to offer the Accessible Transportation Obligations training for frontline employees to meet the accessible transportation regulations (2023 to 2024 fiscal year, Q4)
2. Identify options for obtaining suitable training for staff to ensure that the necessary skills are in place to reflect accessibility concerns in new and modified policies and programs (2023 to 2024 fiscal year, Q4)
3. Develop accessibility awareness guidance and tools to support staff who draft policies and programs (2023 to 2025, and ongoing)
4. Create an inventory of policies and programs, such as sections of the Enforcement Manual (CBSA and IRCC) and all operational bulletins (CBSA) across the Branches to identify the current scope of work (2023 to 2025).
5. Identify programs, policies and supporting documentation that anticipate change or replacement in the near future (2023 to 2025)
6. Develop a mechanism to ensure that new and revised policies, programs and its supporting materials (e.g. Operational Bulletins) are confirmed as meeting the new accessibility standards before introduction (2024 to 2025)
7. Prioritize policies and programs for review based upon the inventory and planned updates, as well as new policies and programs (annually)
8. Review new and modified materials, over a 3 year period, to test the approach and determine how accessible they are according to ACA standards and accessible transportation regulations (2023 to 2025)
9. Build a schedule for the subsequent 3 years, 2026 to 2029 (2025 to 2026 fiscal year)
10. Develop performance indicators, both quantitative and qualitative, to form the basis for assessing future progress once fully implemented (ongoing)

Goals and performance measures

The CBSA provides services to the public in 3 business lines:

1. Travellers
2. Commercial and Trade
3. Intelligence and Enforcement

Currently, the agency is undergoing a significant border modernization initiative which will transform its business and operations to improve client experience. As the CBSA modernizes its programs and services, there is an opportunity to review its business processes and systems with an accessibility lens. Some examples of these modernization activities include:

1. Traveller Modernization: where travellers will be able to be processed quicker, as declarations are made in advance in applications such as ArriveCan, and can use eGate lanes or speak remotely with a Border Services Officer from their vehicle
2. CBSA Assessment and Revenue Management (CARM) Project: where the process for importing goods into Canada will be simplified and will result in reduced costs and improved consistency and compliance with trade rules
3. Gordie Howe International Bridge port of entry (GHIB POE): will be our flagship port of entry (POE), which has inclusivity at the centre of its design

The ability for our frontline officers to be able to deliver inclusive services will be contingent on the progress of the other 6 pillars.

Over the next 3 years, the plans and priorities for service delivery include:

1. increasing workforce representation of persons with disabilities in the operations and frontlines
2. improving knowledge and awareness of inclusive practices and unconscious bias
3. improving transportation service provider personnel training to facilitate equal access to safe, respectful and dignified transportation services and assistance as per the accessible transportation regulations
4. developing service-oriented policies for assisting persons with disabilities, upon request, with communication needs, and accessible border and security screening processes
5. ensuring clients are aware of their rights and can provide feedback, which will be used to help inform corrective action

Barriers

The barriers on the service delivery front have for the most part been captured through the other areas of this plan.

Technology and systems

In the modernization of its business, there is an opportunity to adopt technologies that will help facilitate improved accessibility. However, there is also a risk of unknown and unintended consequences for persons with disabilities, and it is important to ensure that user testing also includes persons with disabilities in the design and development.

People

CBSA has close to 6,000 frontline officers who service over 1,200 different access points across the country and abroad. Attitudinal barriers and unconscious bias have an adverse effect on persons with disabilities. The CBSA is counteracting this by making sure that all employees receive training on unconscious bias, but also through our cultural transformation initiative which seeks to build a more understanding and empathetic workforce.

Language and communication

Specific to clients who are hard of hearing and rely on sign language, these clients may experience a barrier as POEs are not equipped with officers who know American Sign Language (ASL) or langue des signes québécoise (LSQ). This is an area of opportunity for the CBSA to use either a combination of contracted resources for interpretation, or to use technology to help facilitate communication with those who are hard of hearing.

Action plan

The service delivery pillar will not have its own action plan as part of the inaugural CBSA accessibility plan. This first CBSA accessibility plan will first focus on developing and implementing actions and tools in the other 6 pillars and, once ready to deploy, they will directly impact the service delivery pillar. It is at that point that the service delivery pillar will have its own plan.

The federal Nothing Without Us strategy identified that an increased awareness of accessibility and disability inclusion is needed. To develop the knowledge and implementation capacities among all levels of the public service, new learning events and activities are being developed and offered by Office of Public Service Accessibility (OPSA), which CBSA is making available to its employees. CBSA is promoting these OPSA initiatives while at the same time developing its own internal accessibility resources for the benefit of all CBSA employees.