0:00:07.693,0:00:16.386 The Northern Ireland Assembly is [br]debating the Sign Language Bill. 0:00:16.386,0:00:23.989 To help them do this, its Communities[br]Committee asked for feedback from any 0:00:23.989,0:00:35.067 person or group – either via video [br]on WhatsApp or in writing. 0:00:35.632,0:00:43.807 The BDA (NI) submitted a written [br]response and this is a summary of 0:00:43.807,0:00:45.541 what that included. 0:00:45.796,0:00:58.109 BDA fully agrees with the proposed new [br]law with one exception (more on that later). 0:00:58.584,0:01:03.700 However, we are calling for the Bill to [br]go even further and will give more details below. 0:01:10.346,0:01:19.587 1) Do you feel Clause 1 goes far enough [br]in formally recognising BSL and ISL as 0:01:19.587,0:01:21.621 languages of Northern Ireland? 0:01:22.309,0:01:32.124 BDA believes yes Clause 1 of the Bill is [br]strong enough. The Bill will give Sign Language 0:01:32.124,0:01:40.576 the same rights as other spoken languages [br]such as Irish and Ulster Scots while not 0:01:40.576,0:01:45.439 affecting or impacting other important [br]laws that might apply to an individual - 0:01:45.439,0:01:50.592 such as the Disability Discrimination Act [br]or Human Rights Acts. 0:01:51.347,0:02:00.827 The Act will also bring NI in line with [br]other parts of the UK where Sign Language 0:02:00.827,0:02:04.954 is already given equal status. 0:02:11.903,0:02:23.463 2) Do you feel Clause 2 goes far enough[br]in promoting the use of BSL and ISL and 0:02:23.463,0:02:25.653 developing deaf culture? 0:02:26.980,0:02:36.480 BDA welcomes the approach of viewing [br]signing not as a disability issue but a 0:02:36.480,0:02:43.190 linguistic minority matter. [br]However, we notice that decisions 0:02:43.190,0:02:48.660 are often made in relation to deaf services [br]or sign language services without meaningful 0:02:48.660,0:02:57.780 deaf input. We want to see a more [br]robust way of including Deaf signers in 0:02:57.780,0:03:06.180 the process of planning, delivering and [br]evaluating. We want to see a commitment 0:03:06.180,0:03:11.162 to invest in developing [br]Deaf leadership in these areas. 0:03:11.608,0:03:16.940 We also welcome the proposal that [br]sign language classes for families with 0:03:16.940,0:03:21.222 Deaf children will become [br]a statutory provision. 0:03:21.897,0:03:32.359 BDA advised on the need for Deaf signers [br]to be able to use technological advances, 0:03:32.359,0:03:45.461 in the same way VRS became crucial [br]during the Covid pandemic and increased 0:03:45.461,0:03:57.771 use of BSL/ISL in the media and schools. [br]We also repeated the importance of 0:03:57.771,0:04:03.796 Deaf signers being involved and leading [br]at all stages of the introduction of these 0:04:03.796,0:04:07.438 new ways of working. 0:04:08.980,0:04:14.293 We also said the Department for [br]Communities should support members 0:04:14.293,0:04:19.241 of the deaf community to develop their [br]skills and capacities towards taking 0:04:19.241,0:04:26.515 leadership roles in designing and [br]delivering policies to implement 0:04:26.515,0:04:29.028 access to sign language. 0:04:37.711,0:04:48.363 3) Do you think the duty placed on [br]prescribed organisations to make the 0:04:48.363,0:04:52.390 information and services accessible [br]to members of the deaf community 0:04:52.390,0:04:55.457 is sufficient? 0:04:56.779,0:05:06.949 BDA acknowledge the Bill will place a [br]responsibility on “prescribed” government 0:05:06.949,0:05:14.299 departments to draw up Action plans [br]in consultation with Deaf people on what 0:05:14.299,0:05:20.982 should be translated, and in what [br]priority order. We accept not everything 0:05:20.982,0:05:28.112 needs to be or can be translated, [br]but Deaf signers should lead on creating 0:05:28.112,0:05:39.612 clear guidance on what is important. [br]This is particularly true in an emergency 0:05:39.612,0:05:43.150 situation or crisis. 0:05:44.644,0:05:54.196 Interpreters should be provided at [br]no extra cost to the Deaf signer and 0:05:54.196,0:05:59.908 this can be a mix of face-to-face [br]and VRS/VRI. 0:06:00.683,0:06:07.738 Finally, again, BDA emphasised the [br]need to involve Deaf people at all stages 0:06:07.738,0:06:15.938 of development and implementation, [br]and for a commitment to develop Deaf leadership. 0:06:22.622,0:06:35.692 4) Do you support the approach taken [br]by Clause 4 that DfC is responsible for 0:06:35.692,0:06:46.715 creating the list of public bodies [br]who the Act will apply to? 0:06:47.747,0:06:54.949 BDA NI believes that the Department for [br]Communities is best placed to do this. 0:06:54.949,0:06:59.559 They have a long history of working[br]with the Deaf sector and will have 0:06:59.559,0:07:04.673 responsibilities over the [br]implementation of the Bill. 0:07:11.932,0:07:19.528 5) Do you support the approach to [br]consultation required in Clause 5 that 0:07:19.528,0:07:31.440 DfC must issue guidance on implementing [br]the Bill through consulting with stakeholders 0:07:33.107,0:07:41.724 It is very important that consultation [br]takes place so organisations are prepared 0:07:41.724,0:07:50.568 to take on their obligations under the Act. [br]Although DfC will have authority to issue 0:07:50.568,0:07:59.855 guidance, and review guidance,[br]BDA wants to see the Bill going further 0:07:59.855,0:08:05.991 by stating how often and when these [br]consultations and reviews should happen. 0:08:06.482,0:08:12.768 We also ask for further clarification on [br]how Deaf communities will be consulted - 0:08:12.768,0:08:17.830 we believe it needs both individual [br]views and those of the 0:08:17.830,0:08:21.286 Deaf community as a whole. 0:08:28.861,0:08:34.701 6) Do you support the approach taken[br]in this clause where DfC should give 0:08:35.312,0:08:39.312 best practice advised to [br]various organisations? 0:08:42.164,0:08:55.105 BDA referred to the Irish Sign Language Act 2017: [br]after three years, 52% of Irish public bodies 0:08:55.105,0:09:02.765 were still not aware of their responsibilities [br]under the Act. To avoid this happening in 0:09:02.765,0:09:10.313 Northern Ireland, BDA recommends a [br]robust programme of best practice guidance. 0:09:10.918,0:09:18.198 This way, all departments should know [br]exactly what they need to do, and their 0:09:18.198,0:09:25.388 actions plans are produced in conjunction [br]with Deaf input and there is availability of 0:09:25.388,0:09:31.258 both BSL and ISL interpreter [br]support across NI. 0:09:37.797,0:09:47.357 7) Do you support the provision for [br]the Department for Communities to 0:09:47.357,0:09:50.494 make further regulations in the future? 0:09:51.315,0:09:57.601 BDA agrees that a flexible approach is [br]appropriate because all organisations 0:09:57.601,0:10:04.331 will be on a learning journey as they [br]navigate this new legislation. 0:10:04.331,0:10:10.901 Identifying issues and putting in [br]regulations to deal with these issues 0:10:10.901,0:10:14.901 is practical and welcomed. 0:10:21.003,0:10:34.549 8) Do you feel the level of consultation [br]required to bring in regulations is sufficient? 0:10:36.224,0:10:46.321 Yes, BDA is clear that both individuals [br]and organisations representing the 0:10:46.321,0:10:50.321 Deaf community should be [br]included in this. 0:10:57.013,0:11:06.663 9) Do you think evaluating the impact [br]of the Bill in a report every five years is 0:11:06.663,0:11:10.043 an appropriate length of time? 0:11:11.599,0:11:17.879 BDA carefully considered what would [br]be the most appropriate amount of time. 0:11:18.913,0:11:25.333 We took into account experience from [br]both Scotland and Ireland’s implementation 0:11:25.333,0:11:32.833 of their legislation. We believe 5 years [br]is a reasonable time period, but we think 0:11:32.833,0:11:41.843 there should be annual reports [br]submitted to DfC during this 5 year period 0:11:41.843,0:11:49.503 to highlight any issues and [br]allow remedial action. 0:11:55.921,0:12:06.711 10) Do you support the creation of a [br]scheme for accrediting BSL and ISL teachers? 0:12:10.331,0:12:16.761 There is a need for a scheme for [br]BSL/ISL teachers and assessors. 0:12:17.645,0:12:26.115 We recommend it is based on one [br]of two successful models already in existence: 0:12:26.115,0:12:34.715 the Association of British Sign Language [br]Teachers and Assessors (ABSLTA); 0:12:34.715,0:12:42.955 or the National Registers of Communication [br]Professionals Working with Deaf and Deafblind 0:12:42.955,0:12:53.765 (UK) (NRCPD). A separate scheme for [br]supporting deaf teachers would be very 0:12:53.765,0:13:04.760 valuable. This can offer networking, [br]sharing of ideas, support etc. 0:13:05.561,0:13:14.761 Creating a list of qualified teachers that [br]could identify if they teach ISL or BSL, 0:13:14.761,0:13:22.361 what levels, what ages etc would be [br]very useful for people, schools, 0:13:22.361,0:13:24.762 and families seeking this service. 0:13:26.757,0:13:36.617 *Do you support the creation of a [br]scheme for accrediting BSL and ISL interpreters? 0:13:37.183,0:13:42.603 This is the one area mentioned in the[br]introduction where BDA does NOT 0:13:42.603,0:13:50.723 support the suggested wording. [br]This is because it implies creating a whole 0:13:50.723,0:14:00.653 new scheme for accreditation. [br]BDA says there is already a system that 0:14:00.653,0:14:07.953 covers the whole of the UK and is [br]fit for purpose - the National Registers of 0:14:07.953,0:14:15.073 Communication Professionals Working [br]with Deaf and Deafblind People (UK) (NRCPD). 0:14:15.461,0:14:24.991 Creating a second new scheme specifically [br]for Northern Ireland is an unnecessary duplication 0:14:24.991,0:14:27.321 which could cause confusion. 0:14:34.571,0:14:44.181 11) Do you agree with the definition of the [br]deaf community provided for in the Bill? 0:14:45.171,0:14:52.821 BDA is conscious of the sensitivity in [br]use of language here. There is no formal 0:14:52.821,0:15:01.871 definition of ‘deaf community’ and no [br]deaf person has to view themselves as part of it. 0:15:02.315,0:15:09.064 For the purpose of this Bill, we believe [br]the proposed wording is appropriate. 0:15:16.848,0:15:28.638 12) Do you agree with the definition [br]of BSL and ISL provided for in the Bill? 0:15:29.953,0:15:33.953 Yes, BDA agrees with the definitions. 0:15:41.065,0:15:51.125 13) Do you agree with the definition [br]of “everyday reliance” provided in the Bill? 0:15:52.538,0:15:59.299 BDA supports the proposed definition. [br]But we want to make it clear that many 0:15:59.299,0:16:07.269 deaf people face barriers every day [br]stemming from communication issues. 0:16:07.912,0:16:15.242 These issues exist even within families, [br]for example where deaf children are born 0:16:15.242,0:16:20.622 to hearing families. The importance of [br]programmes such as Family Signing 0:16:20.622,0:16:30.232 in the Home is absolutely critical for [br]giving the best start to the next generation 0:16:30.232,0:16:38.826 of deaf children and importantly,[br]for supporting their families too. 0:16:39.411,0:16:45.481 NI Deaf communities have a wide and [br]rich range of variations in personal 0:16:45.481,0:16:53.021 circumstances and in their individual [br]language journeys, and BDA agrees the 0:16:53.021,0:16:56.241 definition is inclusive for all.