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The Northern Ireland Assembly is [br]debating the Sign Language Bill.

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To help them do this, its Communities[br]Committee asked for feedback from any

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person or group – either via video [br]on WhatsApp or in writing.

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The BDA (NI) submitted a written [br]response and this is a summary of

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what that included.

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BDA fully agrees with the proposed new [br]law with one exception (more on that later).

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However, we are calling for the Bill to [br]go even further and will give more details below.

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1)	Do you feel Clause 1 goes far enough [br]in formally recognising BSL and ISL as

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languages of Northern Ireland?

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BDA believes yes Clause 1 of the Bill is [br]strong enough. The Bill will give Sign Language

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the same rights as other spoken languages [br]such as Irish and Ulster Scots while not

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affecting or impacting other important [br]laws that might apply to an individual -

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such as the Disability Discrimination Act [br]or Human Rights Acts.

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The Act will also bring NI in line with [br]other parts of the UK where Sign Language

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is already given equal status.

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2)	Do you feel Clause 2 goes far enough[br]in promoting the use of BSL and ISL and

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developing deaf culture?

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BDA welcomes the approach of viewing [br]signing not as a disability issue but a

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linguistic minority matter. [br]However, we notice that decisions

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are often made in relation to deaf services [br]or sign language services without meaningful

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deaf input. We want to see a more [br]robust way of including Deaf signers in

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the process of planning, delivering and [br]evaluating. We want to see a commitment

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to invest in developing [br]Deaf leadership in these areas.

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We also welcome the proposal that [br]sign language classes for families with

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Deaf children will become [br]a statutory provision.

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BDA advised on the need for Deaf signers [br]to be able to use technological advances,

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in the same way VRS became crucial [br]during the Covid pandemic and increased

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use of BSL/ISL in the media and schools. [br]We also repeated the importance of

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Deaf signers being involved and leading [br]at all stages of the introduction of these

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new ways of working.

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We also said the Department for [br]Communities should support members

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of the deaf community to develop their [br]skills and capacities towards taking

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leadership roles in designing and [br]delivering policies to implement

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access to sign language.

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3)	Do you think the duty placed on [br]prescribed organisations to make the

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information and services accessible [br]to members of the deaf community

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is sufficient?

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BDA acknowledge the Bill will place a [br]responsibility on “prescribed” government

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departments to draw up Action plans [br]in consultation with Deaf people on what

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should be translated, and in what [br]priority order. We accept not everything

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needs to be or can be translated, [br]but Deaf signers should lead on creating

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clear guidance on what is important. [br]This is particularly true in an emergency

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situation or crisis.

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Interpreters should be provided at [br]no extra cost to the Deaf signer and

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this can be a mix of face-to-face [br]and VRS/VRI.

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Finally, again, BDA emphasised the [br]need to involve Deaf people at all stages

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of development and implementation, [br]and for a commitment to develop Deaf leadership.

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4)	Do you support the approach taken [br]by Clause 4 that DfC is responsible for

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creating the list of public bodies [br]who the Act will apply to?

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BDA NI believes that the Department for [br]Communities is best placed to do this.

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They have a long history of working[br]with the Deaf sector and will have

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responsibilities over the [br]implementation of the Bill.

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5)	Do you support the approach to [br]consultation required in Clause 5 that

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DfC must issue guidance on implementing [br]the Bill through consulting with stakeholders

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It is very important that consultation [br]takes place so organisations are prepared

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to take on their obligations under the Act. [br]Although DfC will have authority to issue

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guidance, and review guidance,[br]BDA wants to see the Bill going further

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by stating how often and when these [br]consultations and reviews should happen.

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We also ask for further clarification on [br]how Deaf communities will be consulted -

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we believe it needs both individual [br]views and those of the

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Deaf community as a whole.

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6)	Do you support the approach taken[br]in this clause where DfC should give

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best practice advised to [br]various organisations?

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BDA referred to the Irish Sign Language Act 2017: [br]after three years, 52% of Irish public bodies

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were still not aware of their responsibilities [br]under the Act. To avoid this happening in

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Northern Ireland, BDA recommends a [br]robust programme of best practice guidance.

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This way, all departments should know [br]exactly what they need to do, and their

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actions plans are produced in conjunction [br]with Deaf input and there is availability of

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both BSL and ISL interpreter [br]support across NI.

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7)	Do you support the provision for [br]the Department for Communities to

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make further regulations in the future?

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BDA agrees that a flexible approach is [br]appropriate because all organisations

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will be on a learning journey as they [br]navigate this new legislation.

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Identifying issues and putting in [br]regulations to deal with these issues

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is practical and welcomed.

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8)	Do you feel the level of consultation [br]required to bring in regulations is sufficient?

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Yes, BDA is clear that both individuals [br]and organisations representing the

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Deaf community should be [br]included in this.

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9)	Do you think evaluating the impact [br]of the Bill in a report every five years is

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an appropriate length of time?

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BDA carefully considered what would [br]be the most appropriate amount of time.

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We took into account experience from [br]both Scotland and Ireland’s implementation

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of their legislation. We believe 5 years [br]is a reasonable time period, but we think

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there should be annual reports [br]submitted to DfC during this 5 year period

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to highlight any issues and [br]allow remedial action.

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10)	Do you support the creation of a [br]scheme for accrediting BSL and ISL teachers?

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There is a need for a scheme for [br]BSL/ISL teachers and assessors.

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We recommend it is based on one [br]of two successful models already in existence:

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the Association of British Sign Language [br]Teachers and Assessors (ABSLTA);

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or the National Registers of Communication [br]Professionals Working with Deaf and Deafblind

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(UK) (NRCPD). A separate scheme for [br]supporting deaf teachers would be very

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valuable. This can offer networking, [br]sharing of ideas, support etc.

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Creating a list of qualified teachers that [br]could identify if they teach ISL or BSL,

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what levels, what ages etc would be [br]very useful for people, schools,

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and families seeking this service.

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*Do you support the creation of a [br]scheme for accrediting BSL and ISL interpreters?

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This is the one area mentioned in the[br]introduction where BDA does NOT

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support the suggested wording. [br]This is because it implies creating a whole

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new scheme for accreditation. [br]BDA says there is already a system that

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covers the whole of the UK and is [br]fit for purpose - the National Registers of

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Communication Professionals Working [br]with Deaf and Deafblind People (UK) (NRCPD).

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Creating a second new scheme specifically [br]for Northern Ireland is an unnecessary duplication

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which could cause confusion.

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11)	Do you agree with the definition of the [br]deaf community provided for in the Bill?

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BDA is conscious of the sensitivity in [br]use of language here. There is no formal

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definition of ‘deaf community’ and no [br]deaf person has to view themselves as part of it.

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For the purpose of this Bill, we believe [br]the proposed wording is appropriate.

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12)	Do you agree with the definition [br]of BSL and ISL provided for in the Bill?

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Yes, BDA agrees with the definitions.

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13)	Do you agree with the definition [br]of “everyday reliance” provided in the Bill?

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BDA supports the proposed definition. [br]But we want to make it clear that many

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deaf people face barriers every day [br]stemming from communication issues.

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These issues exist even within families, [br]for example where deaf children are born

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to hearing families. The importance of [br]programmes such as Family Signing

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in the Home is absolutely critical for [br]giving the best start to the next generation

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of deaf children and importantly,[br]for supporting their families too.

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NI Deaf communities have a wide and [br]rich range of variations in personal

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circumstances and in their individual [br]language journeys, and BDA agrees the

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definition is inclusive for all.