0:00:08.103,0:00:14.043 SUMMARY OF WRITTEN SUBMISSION [br]FROM BRITISH DEAF ASSOCIATION 0:00:14.043,0:00:18.043 (NORTHERN IRELAND) –[br]Sign Language Bill 0:00:18.950,0:00:24.376 The Northern Ireland Assembly is [br]debating the Sign Language Bill. 0:00:24.909,0:00:33.199 To help them do this, its Communities[br]Committee asked for feedback from any 0:00:33.199,0:00:42.437 person or group – either via video [br]on WhatsApp or in writing. 0:00:42.997,0:00:51.517 The BDA (NI) submitted a written [br]response and this is a summary of 0:00:51.517,0:00:53.671 what that included. 0:00:54.633,0:01:04.669 BDA fully agrees with the proposed new [br]law with one exception (more on that later). 0:01:05.863,0:01:13.434 However, we are calling for the Bill to [br]go even further and will give more details below. 0:01:20.808,0:01:32.438 1) Do you feel Clause 1 goes far enough [br]in formally recognising BSL and ISL as 0:01:32.438,0:01:34.082 languages of Northern Ireland? 0:01:35.929,0:01:46.859 BDA believes yes Clause 1 of the Bill is [br]strong enough. The Bill will give Sign Language 0:01:46.859,0:01:57.199 the same rights as other spoken languages [br]such as Irish and Ulster Scots while not 0:01:57.199,0:02:04.569 affecting or impacting other important [br]laws that might apply to an individual - 0:02:04.569,0:02:11.129 such as the Disability Discrimination Act [br]or Human Rights Acts. 0:02:11.719,0:02:17.769 The Act will also bring NI in line with [br]other parts of the UK where Sign Language 0:02:17.769,0:02:25.035 is already given equal status. 0:02:32.826,0:02:41.556 2) Do you feel Clause 2 goes far enough[br]in promoting the use of BSL and ISL and 0:02:41.556,0:02:43.746 developing deaf culture? 0:02:44.282,0:02:50.942 BDA welcomes the approach of viewing [br]signing not as a disability issue but a 0:02:50.942,0:02:55.472 linguistic minority matter. [br]However, we notice that decisions 0:02:55.472,0:03:02.012 are often made in relation to deaf services [br]or sign language services without meaningful 0:03:02.012,0:03:08.872 deaf input. We want to see a more [br]robust way of including Deaf signers in 0:03:08.872,0:03:15.512 the process of planning, delivering and [br]evaluating. We want to see a commitment 0:03:15.512,0:03:20.795 to invest in developing [br]Deaf leadership in these areas. 0:03:20.978,0:03:25.848 We also welcome the proposal that [br]sign language classes for families with 0:03:25.848,0:03:31.368 Deaf children will become [br]a statutory provision. 0:03:32.505,0:03:39.607 BDA advised on the need for Deaf signers [br]to be able to use technological advances, 0:03:39.607,0:03:46.099 in the same way VRS became crucial [br]during the Covid pandemic and increased 0:03:46.099,0:03:51.939 use of BSL/ISL in the media and schools. [br]We also repeated the important of 0:03:51.939,0:03:57.719 Deaf signers being involved and leading [br]at all stages of the introduction of these 0:03:57.719,0:03:59.339 new ways of working. 0:03:59.806,0:04:05.035 We also said the Department for [br]Communities should support members 0:04:05.035,0:04:10.385 of the deaf community to develop their [br]skills and capacities towards taking 0:04:10.385,0:04:18.585 leadership roles in designing and [br]delivering policies to implement 0:04:18.585,0:04:19.937 access to sign language. 0:04:26.164,0:04:36.154 3) Do you think the duty placed on [br]prescribed organisations to make the 0:04:36.154,0:04:41.564 information and services accessible [br]to members of the deaf community 0:04:41.564,0:04:42.621 is sufficient? 0:04:43.890,0:04:51.342 BDA acknowledge the Bill will place a [br]responsibility on “prescribed” government 0:04:51.342,0:05:01.172 departments to draw up Action plans [br]in consultation with Deaf people on what 0:05:01.172,0:05:12.572 should be translated, and in what [br]priority order. We accept not everything 0:05:12.572,0:05:19.592 needs to be or can be translated, [br]but Deaf signers should lead on creating 0:05:19.592,0:05:29.392 clear guidance on what is important. [br]This is particularly true in an emergency 0:05:29.392,0:05:32.850 situation or crisis. 0:05:34.666,0:05:41.436 Interpreters should be provided at [br]no extra cost to the Deaf signer and 0:05:41.436,0:05:52.248 this can be a mix of face-to-face [br]and VRS/VRI. 0:05:54.448,0:06:02.748 Finally, again, BDA emphasised the [br]need to involve Deaf people at all stages 0:06:02.748,0:06:10.642 of development and implementation, [br]and for a commitment to develop Deaf leadership. 0:06:16.532,0:06:27.182 4) Do you support the approach taken [br]by Clause 4 that DfC is responsible for 0:06:27.182,0:06:33.796 creating the list of public bodies [br]who the Act will apply to? 0:06:34.989,0:06:43.719 BDA NI believes that the Department for [br]Communities is best placed to do this. 0:06:43.719,0:06:47.719 They have a long history of working[br]with the Deaf sector and will have 0:06:47.719,0:06:51.052 responsibilities over the [br]implementation of the Bill. 0:06:58.468,0:07:08.858 5) Do you support the approach to [br]consultation required in Clause 5 that 0:07:08.858,0:07:21.778 DfC must issue guidance on implementing [br]the Bill through consulting with stakeholders 0:07:23.525,0:07:27.525 It is very important that consultation [br]takes place so organisations are prepared 9:59:59.000,9:59:59.000 to take on their obligations under the Act. [br]Although DfC will have authority to issue 9:59:59.000,9:59:59.000 guidance, and review guidance,[br]BDA wants to see the Bill going further 9:59:59.000,9:59:59.000 by stating how often and when these [br]consultations and reviews should happen. 9:59:59.000,9:59:59.000 We also ask for further clarification on [br]how Deaf communities will be consulted - 9:59:59.000,9:59:59.000 we believe it needs both individual [br]views and those of the 9:59:59.000,9:59:59.000 Deaf community as a whole. 9:59:59.000,9:59:59.000 6) Do you support the approach taken[br]in this clause where DfC should give 9:59:59.000,9:59:59.000 best practice advised to [br]various organisations? 9:59:59.000,9:59:59.000 BDA referred to the Irish Sign Language Act 2017: [br]after three years, 52% of Irish public bodies 9:59:59.000,9:59:59.000 were still not aware of their responsibilities [br]under the Act. To avoid this happening in 9:59:59.000,9:59:59.000 Northern Ireland, BDA recommends a [br]robust programme of best practice guidance. 9:59:59.000,9:59:59.000 This way, all departments should know [br]exactly what they need to do, and their 9:59:59.000,9:59:59.000 actions plans are produced in conjunction [br]with Deaf input and there is availability of 9:59:59.000,9:59:59.000 both BSL and ISL interpreter [br]support across NI. 9:59:59.000,9:59:59.000 7) Do you support the provision for [br]the Department for Communities to make 9:59:59.000,9:59:59.000 make further regulations in the future? 9:59:59.000,9:59:59.000 BDA agrees that a flexible approach is [br]appropriate because all organisations 9:59:59.000,9:59:59.000 will be on a learning journey as they [br]navigate this new legislation. 9:59:59.000,9:59:59.000 Identifying issues and putting in [br]regulations to deal with these issues 9:59:59.000,9:59:59.000 is practical and welcomed. 9:59:59.000,9:59:59.000 8) Do you feel the level of consultation [br]required to bring in regulations is sufficient? 9:59:59.000,9:59:59.000 Yes, BDA is clear that both individuals [br]and organisations representing the 9:59:59.000,9:59:59.000 Deaf community should be [br]included in this. 9:59:59.000,9:59:59.000 9) Do you think evaluating the impact [br]of the Bill in a report every five years is 9:59:59.000,9:59:59.000 an appropriate length of time? 9:59:59.000,9:59:59.000 BDA carefully considered what would [br]be the most appropriate amount of time. 9:59:59.000,9:59:59.000 We took into account experience from [br]both Scotland and Ireland’s implementation 9:59:59.000,9:59:59.000 of their legislation. We believe 5 years [br]is a reasonable time period, but we think 9:59:59.000,9:59:59.000 there should be annual reports [br]submitted to DfC during this 5 year period 9:59:59.000,9:59:59.000 to highlight any issues and [br]allow remedial action. 9:59:59.000,9:59:59.000 10) Do you support the creation of a [br]scheme for accrediting BSL and ISL teachers? 9:59:59.000,9:59:59.000 There is a need for a scheme for [br]BSL/ISL teachers and assessors. 9:59:59.000,9:59:59.000 We recommend it is based on one [br]of two successful models already in existence: 9:59:59.000,9:59:59.000 the Association of British Sign Language [br]Teachers and Assessors (ABSLTA); 9:59:59.000,9:59:59.000 or the National Registers of Communication [br]Professionals Working with Deaf and Deafblind 9:59:59.000,9:59:59.000 (UK) (NRCPD). A separate scheme for [br]supporting deaf teachers would be very 9:59:59.000,9:59:59.000 valuable. This can offer networking, [br]sharing of ideas, support etc. 9:59:59.000,9:59:59.000 Creating a list of qualified teachers that [br]could identify if they teach ISL or BSL, 9:59:59.000,9:59:59.000 what levels, what ages etc would be [br]very useful for people, schools, 9:59:59.000,9:59:59.000 and families seeking this service. 9:59:59.000,9:59:59.000 *Do you support the creation of a [br]scheme for accrediting BSL and ISL interpreters? 9:59:59.000,9:59:59.000 This is the one area mentioned in the[br]introduction where BDA does NOT 9:59:59.000,9:59:59.000 support the suggested wording. [br]This is because it implies creating a whole 9:59:59.000,9:59:59.000 new scheme for accreditation. [br]BDA says there is already a system that 9:59:59.000,9:59:59.000 covers the whole of the UK and is [br]fit for purpose - the National Registers of 9:59:59.000,9:59:59.000 Communication Professionals Working [br]with Deaf and Deafblind People (UK) (NRCPD). 9:59:59.000,9:59:59.000 Creating a second new scheme specifically [br]for Northern Ireland is an unnecessary duplication 9:59:59.000,9:59:59.000 which could cause confusion. 9:59:59.000,9:59:59.000 11) Do you agree with the definition of the [br]deaf community provided for in the Bill? 9:59:59.000,9:59:59.000 BDA is conscious of the sensitivity in [br]use of language here. There is no formal 9:59:59.000,9:59:59.000 definition of ‘deaf community’ and no [br]deaf person has to view themselves as part of it. 9:59:59.000,9:59:59.000 For the purpose of this Bill, we believe [br]the proposed wording is appropriate. 9:59:59.000,9:59:59.000 12) Do you agree with the definition [br]of BSL and ISL provided for in the Bill? 9:59:59.000,9:59:59.000 Yes, BDA agrees with the definitions. 9:59:59.000,9:59:59.000 13) Do you agree with the definition [br]of “everyday reliance” provided in the Bill? 9:59:59.000,9:59:59.000 BDA supports the proposed definition. [br]But we want to make it clear that many 9:59:59.000,9:59:59.000 deaf people face barriers every day [br]stemming from communication issues. 9:59:59.000,9:59:59.000 These issues exist even within families, [br]for example where deaf children are born 9:59:59.000,9:59:59.000 to hearing families. The importance of [br]programmes such as Family Signing 9:59:59.000,9:59:59.000 in the Home is absolutely critical for [br]giving the best start to the next generation 9:59:59.000,9:59:59.000 of deaf children and importantly,[br]for supporting their families too. 9:59:59.000,9:59:59.000 NI Deaf communities have a wide and [br]rich range of variations in personal 9:59:59.000,9:59:59.000 circumstances and in their individual [br]language journeys, and BDA agrees the 9:59:59.000,9:59:59.000 definition is inclusive for all.