1 00:00:07,693 --> 00:00:16,386 The Northern Ireland Assembly is debating the Sign Language Bill. 2 00:00:16,386 --> 00:00:23,989 To help them do this, its Communities Committee asked for feedback from any 3 00:00:23,989 --> 00:00:35,067 person or group – either via video on WhatsApp or in writing. 4 00:00:35,632 --> 00:00:43,807 The BDA (NI) submitted a written response and this is a summary of 5 00:00:43,807 --> 00:00:45,541 what that included. 6 00:00:45,796 --> 00:00:58,109 BDA fully agrees with the proposed new law with one exception (more on that later). 7 00:00:58,584 --> 00:01:03,700 However, we are calling for the Bill to go even further and will give more details below. 8 00:01:10,346 --> 00:01:19,587 1) Do you feel Clause 1 goes far enough in formally recognising BSL and ISL as 9 00:01:19,587 --> 00:01:21,621 languages of Northern Ireland? 10 00:01:22,309 --> 00:01:32,124 BDA believes yes Clause 1 of the Bill is strong enough. The Bill will give Sign Language 11 00:01:32,124 --> 00:01:40,576 the same rights as other spoken languages such as Irish and Ulster Scots while not 12 00:01:40,576 --> 00:01:45,439 affecting or impacting other important laws that might apply to an individual - 13 00:01:45,439 --> 00:01:50,592 such as the Disability Discrimination Act or Human Rights Acts. 14 00:01:51,347 --> 00:02:00,827 The Act will also bring NI in line with other parts of the UK where Sign Language 15 00:02:00,827 --> 00:02:04,954 is already given equal status. 16 00:02:11,903 --> 00:02:23,463 2) Do you feel Clause 2 goes far enough in promoting the use of BSL and ISL and 17 00:02:23,463 --> 00:02:25,653 developing deaf culture? 18 00:02:26,980 --> 00:02:36,480 BDA welcomes the approach of viewing signing not as a disability issue but a 19 00:02:36,480 --> 00:02:43,190 linguistic minority matter. However, we notice that decisions 20 00:02:43,190 --> 00:02:48,660 are often made in relation to deaf services or sign language services without meaningful 21 00:02:48,660 --> 00:02:57,780 deaf input. We want to see a more robust way of including Deaf signers in 22 00:02:57,780 --> 00:03:06,180 the process of planning, delivering and evaluating. We want to see a commitment 23 00:03:06,180 --> 00:03:11,162 to invest in developing Deaf leadership in these areas. 24 00:03:11,608 --> 00:03:16,940 We also welcome the proposal that sign language classes for families with 25 00:03:16,940 --> 00:03:21,222 Deaf children will become a statutory provision. 26 00:03:21,897 --> 00:03:32,359 BDA advised on the need for Deaf signers to be able to use technological advances, 27 00:03:32,359 --> 00:03:45,461 in the same way VRS became crucial during the Covid pandemic and increased 28 00:03:45,461 --> 00:03:57,771 use of BSL/ISL in the media and schools. We also repeated the importance of 29 00:03:57,771 --> 00:04:03,796 Deaf signers being involved and leading at all stages of the introduction of these 30 00:04:03,796 --> 00:04:07,438 new ways of working. 31 00:04:08,980 --> 00:04:14,293 We also said the Department for Communities should support members 32 00:04:14,293 --> 00:04:19,241 of the deaf community to develop their skills and capacities towards taking 33 00:04:19,241 --> 00:04:26,515 leadership roles in designing and delivering policies to implement 34 00:04:26,515 --> 00:04:29,028 access to sign language. 35 00:04:37,711 --> 00:04:48,363 3) Do you think the duty placed on prescribed organisations to make the 36 00:04:48,363 --> 00:04:52,390 information and services accessible to members of the deaf community 37 00:04:52,390 --> 00:04:55,457 is sufficient? 38 00:04:56,779 --> 00:05:06,949 BDA acknowledge the Bill will place a responsibility on “prescribed” government 39 00:05:06,949 --> 00:05:14,299 departments to draw up Action plans in consultation with Deaf people on what 40 00:05:14,299 --> 00:05:20,982 should be translated, and in what priority order. We accept not everything 41 00:05:20,982 --> 00:05:28,112 needs to be or can be translated, but Deaf signers should lead on creating 42 00:05:28,112 --> 00:05:39,612 clear guidance on what is important. This is particularly true in an emergency 43 00:05:39,612 --> 00:05:43,150 situation or crisis. 44 00:05:44,644 --> 00:05:54,196 Interpreters should be provided at no extra cost to the Deaf signer and 45 00:05:54,196 --> 00:05:59,908 this can be a mix of face-to-face and VRS/VRI. 46 00:06:00,683 --> 00:06:07,738 Finally, again, BDA emphasised the need to involve Deaf people at all stages 47 00:06:07,738 --> 00:06:15,938 of development and implementation, and for a commitment to develop Deaf leadership. 48 00:06:22,622 --> 00:06:35,692 4) Do you support the approach taken by Clause 4 that DfC is responsible for 49 00:06:35,692 --> 00:06:46,715 creating the list of public bodies who the Act will apply to? 50 00:06:47,747 --> 00:06:54,949 BDA NI believes that the Department for Communities is best placed to do this. 51 00:06:54,949 --> 00:06:59,559 They have a long history of working with the Deaf sector and will have 52 00:06:59,559 --> 00:07:04,673 responsibilities over the implementation of the Bill. 53 00:07:11,932 --> 00:07:19,528 5) Do you support the approach to consultation required in Clause 5 that 54 00:07:19,528 --> 00:07:31,440 DfC must issue guidance on implementing the Bill through consulting with stakeholders 55 00:07:33,107 --> 00:07:41,724 It is very important that consultation takes place so organisations are prepared 56 00:07:41,724 --> 00:07:50,568 to take on their obligations under the Act. Although DfC will have authority to issue 57 00:07:50,568 --> 00:07:59,855 guidance, and review guidance, BDA wants to see the Bill going further 58 00:07:59,855 --> 00:08:05,991 by stating how often and when these consultations and reviews should happen. 59 00:08:06,482 --> 00:08:12,768 We also ask for further clarification on how Deaf communities will be consulted - 60 00:08:12,768 --> 00:08:17,830 we believe it needs both individual views and those of the 61 00:08:17,830 --> 00:08:21,286 Deaf community as a whole. 62 00:08:28,861 --> 00:08:38,002 6) Do you support the approach taken in this clause where DfC should give 63 00:08:38,002 --> 00:08:45,077 best practice advised to various organisations? 64 00:08:46,914 --> 00:09:01,745 BDA referred to the Irish Sign Language Act 2017: after three years, 52% of Irish public bodies 65 00:09:01,745 --> 00:09:08,713 were still not aware of their responsibilities under the Act. To avoid this happening in 66 00:09:08,713 --> 00:09:19,023 Northern Ireland, BDA recommends a robust programme of best practice guidance. 67 00:09:19,736 --> 00:09:24,954 This way, all departments should know exactly what they need to do, and their 68 00:09:24,954 --> 00:09:31,355 actions plans are produced in conjunction with Deaf input and there is availability of 69 00:09:31,355 --> 00:09:35,774 both BSL and ISL interpreter support across NI. 70 00:09:43,382 --> 00:09:48,947 7) Do you support the provision for the Department for Communities to 71 00:09:48,947 --> 00:09:56,607 make further regulations in the future? 72 00:09:58,769 --> 00:10:08,481 BDA agrees that a flexible approach is appropriate because all organisations 73 00:10:08,481 --> 00:10:16,148 will be on a learning journey as they navigate this new legislation. 74 00:10:16,148 --> 00:10:23,963 Identifying issues and putting in regulations to deal with these issues 75 00:10:23,963 --> 00:10:28,513 is practical and welcomed. 76 00:10:36,456 --> 00:10:51,574 8) Do you feel the level of consultation required to bring in regulations is sufficient? 77 00:10:51,574 --> 00:10:58,963 Yes, BDA is clear that both individuals and organisations representing the 78 00:10:58,963 --> 00:11:01,463 Deaf community should be included in this. 79 00:11:08,429 --> 00:11:15,893 9) Do you think evaluating the impact of the Bill in a report every five years is 80 00:11:15,893 --> 00:11:22,843 an appropriate length of time? 81 00:11:24,173 --> 00:11:33,532 BDA carefully considered what would be the most appropriate amount of time. 82 00:11:33,532 --> 00:11:37,943 We took into account experience from both Scotland and Ireland’s implementation 83 00:11:37,943 --> 00:11:46,873 of their legislation. We believe 5 years is a reasonable time period, but we think 84 00:11:46,873 --> 00:11:55,393 there should be annual reports submitted to DfC during this 5 year period 85 00:11:55,393 --> 00:12:02,714 to highlight any issues and allow remedial action. 86 00:12:09,647 --> 00:12:18,131 10) Do you support the creation of a scheme for accrediting BSL and ISL teachers? 87 00:12:18,131 --> 00:12:23,155 There is a need for a scheme for BSL/ISL teachers and assessors. 88 00:12:23,155 --> 00:12:33,785 We recommend it is based on one of two successful models already in existence: 89 00:12:33,785 --> 00:12:45,075 the Association of British Sign Language Teachers and Assessors (ABSLTA); 90 00:12:45,075 --> 00:12:51,995 or the National Registers of Communication Professionals Working with Deaf and Deafblind 91 00:12:51,995 --> 00:13:00,765 (UK) (NRCPD). A separate scheme for supporting deaf teachers would be very 92 00:13:00,765 --> 00:13:10,731 valuable. This can offer networking, sharing of ideas, support etc. 93 00:13:11,270 --> 00:13:18,001 Creating a list of qualified teachers that could identify if they teach ISL or BSL, 94 00:13:18,001 --> 00:13:26,861 what levels, what ages etc would be very useful for people, schools, 95 00:13:26,861 --> 00:13:29,157 and families seeking this service. 96 00:13:31,169 --> 00:13:43,109 *Do you support the creation of a scheme for accrediting BSL and ISL interpreters? 97 00:13:44,214 --> 00:13:48,883 This is the one area mentioned in the introduction where BDA does NOT 98 00:13:48,883 --> 00:13:56,723 support the suggested wording. This is because it implies creating a whole 99 00:13:56,723 --> 00:14:09,663 new scheme for accreditation. BDA says there is already a system that 100 00:14:09,663 --> 00:14:14,141 covers the whole of the UK and is fit for purpose - the National Registers of 101 00:14:14,141 --> 00:14:19,361 Communication Professionals Working with Deaf and Deafblind People (UK) (NRCPD). 102 00:14:19,361 --> 00:14:26,616 Creating a second new scheme specifically for Northern Ireland is an unnecessary duplication 103 00:14:26,616 --> 00:14:28,311 which could cause confusion. 104 00:14:35,715 --> 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.