1 00:00:07,693 --> 00:00:16,386 The Northern Ireland Assembly is debating the Sign Language Bill. 2 00:00:16,386 --> 00:00:24,869 To help them do this, its Communities Committee asked for feedback from any 3 00:00:24,869 --> 00:00:42,437 person or group – either via video on WhatsApp or in writing. 4 00:00:42,997 --> 00:00:51,517 The BDA (NI) submitted a written response and this is a summary of 5 00:00:51,517 --> 00:00:53,671 what that included. 6 00:00:54,633 --> 00:01:04,669 BDA fully agrees with the proposed new law with one exception (more on that later). 7 00:01:05,863 --> 00:01:13,434 However, we are calling for the Bill to go even further and will give more details below. 8 00:01:20,808 --> 00:01:32,438 1) Do you feel Clause 1 goes far enough in formally recognising BSL and ISL as 9 00:01:32,438 --> 00:01:34,082 languages of Northern Ireland? 10 00:01:35,929 --> 00:01:46,859 BDA believes yes Clause 1 of the Bill is strong enough. The Bill will give Sign Language 11 00:01:46,859 --> 00:01:57,199 the same rights as other spoken languages such as Irish and Ulster Scots while not 12 00:01:57,199 --> 00:02:04,569 affecting or impacting other important laws that might apply to an individual - 13 00:02:04,569 --> 00:02:11,129 such as the Disability Discrimination Act or Human Rights Acts. 14 00:02:11,719 --> 00:02:17,769 The Act will also bring NI in line with other parts of the UK where Sign Language 15 00:02:17,769 --> 00:02:25,035 is already given equal status. 16 00:02:32,826 --> 00:02:41,556 2) Do you feel Clause 2 goes far enough in promoting the use of BSL and ISL and 17 00:02:41,556 --> 00:02:43,746 developing deaf culture? 18 00:02:44,282 --> 00:02:50,942 BDA welcomes the approach of viewing signing not as a disability issue but a 19 00:02:50,942 --> 00:02:55,472 linguistic minority matter. However, we notice that decisions 20 00:02:55,472 --> 00:03:02,012 are often made in relation to deaf services or sign language services without meaningful 21 00:03:02,012 --> 00:03:08,872 deaf input. We want to see a more robust way of including Deaf signers in 22 00:03:08,872 --> 00:03:15,512 the process of planning, delivering and evaluating. We want to see a commitment 23 00:03:15,512 --> 00:03:20,795 to invest in developing Deaf leadership in these areas. 24 00:03:20,978 --> 00:03:25,848 We also welcome the proposal that sign language classes for families with 25 00:03:25,848 --> 00:03:31,368 Deaf children will become a statutory provision. 26 00:03:32,505 --> 00:03:39,607 BDA advised on the need for Deaf signers to be able to use technological advances, 27 00:03:39,607 --> 00:03:46,099 in the same way VRS became crucial during the Covid pandemic and increased 28 00:03:46,099 --> 00:03:51,939 use of BSL/ISL in the media and schools. We also repeated the importance of 29 00:03:51,939 --> 00:03:57,719 Deaf signers being involved and leading at all stages of the introduction of these 30 00:03:57,719 --> 00:03:59,339 new ways of working. 31 00:03:59,806 --> 00:04:05,035 We also said the Department for Communities should support members 32 00:04:05,035 --> 00:04:10,385 of the deaf community to develop their skills and capacities towards taking 33 00:04:10,385 --> 00:04:18,585 leadership roles in designing and delivering policies to implement 34 00:04:18,585 --> 00:04:19,937 access to sign language. 35 00:04:26,164 --> 00:04:36,154 3) Do you think the duty placed on prescribed organisations to make the 36 00:04:36,154 --> 00:04:41,564 information and services accessible to members of the deaf community 37 00:04:41,564 --> 00:04:42,621 is sufficient? 38 00:04:43,890 --> 00:04:51,342 BDA acknowledge the Bill will place a responsibility on “prescribed” government 39 00:04:51,342 --> 00:05:01,172 departments to draw up Action plans in consultation with Deaf people on what 40 00:05:01,172 --> 00:05:12,572 should be translated, and in what priority order. We accept not everything 41 00:05:12,572 --> 00:05:19,592 needs to be or can be translated, but Deaf signers should lead on creating 42 00:05:19,592 --> 00:05:29,392 clear guidance on what is important. This is particularly true in an emergency 43 00:05:29,392 --> 00:05:32,850 situation or crisis. 44 00:05:34,666 --> 00:05:41,436 Interpreters should be provided at no extra cost to the Deaf signer and 45 00:05:41,436 --> 00:05:52,248 this can be a mix of face-to-face and VRS/VRI. 46 00:05:54,448 --> 00:06:02,748 Finally, again, BDA emphasised the need to involve Deaf people at all stages 47 00:06:02,748 --> 00:06:10,642 of development and implementation, and for a commitment to develop Deaf leadership. 48 00:06:16,532 --> 00:06:27,182 4) Do you support the approach taken by Clause 4 that DfC is responsible for 49 00:06:27,182 --> 00:06:33,796 creating the list of public bodies who the Act will apply to? 50 00:06:34,989 --> 00:06:43,719 BDA NI believes that the Department for Communities is best placed to do this. 51 00:06:43,719 --> 00:06:47,719 They have a long history of working with the Deaf sector and will have 52 00:06:47,719 --> 00:06:51,052 responsibilities over the implementation of the Bill. 53 00:06:58,468 --> 00:07:08,858 5) Do you support the approach to consultation required in Clause 5 that 54 00:07:08,858 --> 00:07:21,778 DfC must issue guidance on implementing the Bill through consulting with stakeholders 55 00:07:23,525 --> 00:07:29,985 It is very important that consultation takes place so organisations are prepared 56 00:07:29,985 --> 00:07:40,785 to take on their obligations under the Act. Although DfC will have authority to issue 57 00:07:40,785 --> 00:07:49,485 guidance, and review guidance, BDA wants to see the Bill going further 58 00:07:49,485 --> 00:07:59,260 by stating how often and when these consultations and reviews should happen. 59 00:08:00,078 --> 00:08:06,788 We also ask for further clarification on how Deaf communities will be consulted - 60 00:08:06,788 --> 00:08:13,748 we believe it needs both individual views and those of the 61 00:08:13,748 --> 00:08:17,998 Deaf community as a whole. 62 00:08:24,692 --> 00:08:35,312 6) Do you support the approach taken in this clause where DfC should give 63 00:08:35,312 --> 00:08:39,312 best practice advised to various organisations? 64 00:08:42,164 --> 00:08:55,105 BDA referred to the Irish Sign Language Act 2017: after three years, 52% of Irish public bodies 65 00:08:55,105 --> 00:09:02,765 were still not aware of their responsibilities under the Act. To avoid this happening in 66 00:09:02,765 --> 00:09:10,313 Northern Ireland, BDA recommends a robust programme of best practice guidance. 67 00:09:10,918 --> 00:09:18,198 This way, all departments should know exactly what they need to do, and their 68 00:09:18,198 --> 00:09:25,388 actions plans are produced in conjunction with Deaf input and there is availability of 69 00:09:25,388 --> 00:09:31,258 both BSL and ISL interpreter support across NI. 70 00:09:37,797 --> 00:09:47,357 7) Do you support the provision for the Department for Communities to 71 00:09:47,357 --> 00:09:50,494 make further regulations in the future? 72 00:09:51,315 --> 00:09:57,601 BDA agrees that a flexible approach is appropriate because all organisations 73 00:09:57,601 --> 00:10:04,331 will be on a learning journey as they navigate this new legislation. 74 00:10:04,331 --> 00:10:10,901 Identifying issues and putting in regulations to deal with these issues 75 00:10:10,901 --> 00:10:14,901 is practical and welcomed. 76 00:10:21,003 --> 00:10:34,549 8) Do you feel the level of consultation required to bring in regulations is sufficient? 77 00:10:36,224 --> 00:10:46,321 Yes, BDA is clear that both individuals and organisations representing the 78 00:10:46,321 --> 00:10:50,321 Deaf community should be included in this. 79 00:10:57,013 --> 00:11:06,663 9) Do you think evaluating the impact of the Bill in a report every five years is 80 00:11:06,663 --> 00:11:10,043 an appropriate length of time? 81 00:11:11,599 --> 00:11:17,879 BDA carefully considered what would be the most appropriate amount of time. 82 00:11:18,913 --> 00:11:25,333 We took into account experience from both Scotland and Ireland’s implementation 83 00:11:25,333 --> 00:11:32,833 of their legislation. We believe 5 years is a reasonable time period, but we think 84 00:11:32,833 --> 00:11:41,843 there should be annual reports submitted to DfC during this 5 year period 85 00:11:41,843 --> 00:11:49,503 to highlight any issues and allow remedial action. 86 00:11:55,921 --> 00:12:06,711 10) Do you support the creation of a scheme for accrediting BSL and ISL teachers? 87 00:12:10,331 --> 00:12:16,761 There is a need for a scheme for BSL/ISL teachers and assessors. 88 00:12:17,645 --> 00:12:26,115 We recommend it is based on one of two successful models already in existence: 89 00:12:26,115 --> 00:12:34,715 the Association of British Sign Language Teachers and Assessors (ABSLTA); 90 00:12:34,715 --> 00:12:42,955 or the National Registers of Communication Professionals Working with Deaf and Deafblind 91 00:12:42,955 --> 00:12:53,765 (UK) (NRCPD). A separate scheme for supporting deaf teachers would be very 92 00:12:53,765 --> 00:13:04,760 valuable. This can offer networking, sharing of ideas, support etc. 93 00:13:05,561 --> 00:13:14,761 Creating a list of qualified teachers that could identify if they teach ISL or BSL, 94 00:13:14,761 --> 00:13:22,361 what levels, what ages etc would be very useful for people, schools, 95 00:13:22,361 --> 00:13:24,762 and families seeking this service. 96 00:13:26,757 --> 00:13:36,617 *Do you support the creation of a scheme for accrediting BSL and ISL interpreters? 97 00:13:37,183 --> 00:13:42,603 This is the one area mentioned in the introduction where BDA does NOT 98 00:13:42,603 --> 00:13:50,723 support the suggested wording. This is because it implies creating a whole 99 00:13:50,723 --> 00:14:00,653 new scheme for accreditation. BDA says there is already a system that 100 00:14:00,653 --> 00:14:07,953 covers the whole of the UK and is fit for purpose - the National Registers of 101 00:14:07,953 --> 00:14:15,073 Communication Professionals Working with Deaf and Deafblind People (UK) (NRCPD). 102 00:14:15,461 --> 00:14:24,991 Creating a second new scheme specifically for Northern Ireland is an unnecessary duplication 103 00:14:24,991 --> 00:14:27,321 which could cause confusion. 104 00:14:34,571 --> 00:14:44,181 11) Do you agree with the definition of the deaf community provided for in the Bill? 105 00:14:45,171 --> 00:14:52,821 BDA is conscious of the sensitivity in use of language here. There is no formal 106 00:14:52,821 --> 00:15:01,871 definition of ‘deaf community’ and no deaf person has to view themselves as part of it. 107 00:15:02,315 --> 00:15:09,064 For the purpose of this Bill, we believe the proposed wording is appropriate. 108 00:15:16,848 --> 00:15:28,638 12) Do you agree with the definition of BSL and ISL provided for in the Bill? 109 00:15:29,953 --> 00:15:33,953 Yes, BDA agrees with the definitions. 110 00:15:41,065 --> 00:15:51,125 13) Do you agree with the definition of “everyday reliance” provided in the Bill? 111 00:15:52,538 --> 00:15:59,299 BDA supports the proposed definition. But we want to make it clear that many 112 00:15:59,299 --> 00:16:07,269 deaf people face barriers every day stemming from communication issues. 113 00:16:07,912 --> 00:16:15,242 These issues exist even within families, for example where deaf children are born 114 00:16:15,242 --> 00:16:20,622 to hearing families. The importance of programmes such as Family Signing 115 00:16:20,622 --> 00:16:30,232 in the Home is absolutely critical for giving the best start to the next generation 116 00:16:30,232 --> 00:16:38,826 of deaf children and importantly, for supporting their families too. 117 00:16:39,411 --> 00:16:45,481 NI Deaf communities have a wide and rich range of variations in personal 118 00:16:45,481 --> 00:16:53,021 circumstances and in their individual language journeys, and BDA agrees the 119 00:16:53,021 --> 00:16:56,241 definition is inclusive for all.