1 00:00:08,103 --> 00:00:14,043 SUMMARY OF WRITTEN SUBMISSION FROM BRITISH DEAF ASSOCIATION 2 00:00:14,043 --> 00:00:18,043 (NORTHERN IRELAND) – Sign Language Bill 3 00:00:18,950 --> 00:00:24,376 The Northern Ireland Assembly is debating the Sign Language Bill. 4 00:00:24,909 --> 00:00:33,199 To help them do this, its Communities Committee asked for feedback from any 5 00:00:33,199 --> 00:00:42,437 person or group – either via video on WhatsApp or in writing. 6 00:00:42,997 --> 00:00:51,517 The BDA (NI) submitted a written response and this is a summary of 7 00:00:51,517 --> 00:00:53,671 what that included. 8 00:00:54,633 --> 00:01:04,669 BDA fully agrees with the proposed new law with one exception (more on that later). 9 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. 10 00:01:20,808 --> 00:01:32,438 1) Do you feel Clause 1 goes far enough in formally recognising BSL and ISL as 11 00:01:32,438 --> 00:01:34,082 languages of Northern Ireland? 12 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 13 00:01:46,859 --> 00:01:57,199 the same rights as other spoken languages such as Irish and Ulster Scots while not 14 00:01:57,199 --> 00:02:04,569 affecting or impacting other important laws that might apply to an individual - 15 00:02:04,569 --> 00:02:11,129 such as the Disability Discrimination Act or Human Rights Acts. 16 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 17 00:02:17,769 --> 00:02:25,035 is already given equal status. 18 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 19 00:02:41,556 --> 00:02:43,746 developing deaf culture? 20 00:02:44,282 --> 00:02:50,942 BDA welcomes the approach of viewing signing not as a disability issue but a 21 00:02:50,942 --> 00:02:55,472 linguistic minority matter. However, we notice that decisions 22 00:02:55,472 --> 00:03:02,012 are often made in relation to deaf services or sign language services without meaningful 23 00:03:02,012 --> 00:03:08,872 deaf input. We want to see a more robust way of including Deaf signers in 24 00:03:08,872 --> 00:03:15,512 the process of planning, delivering and evaluating. We want to see a commitment 25 00:03:15,512 --> 00:03:20,795 to invest in developing Deaf leadership in these areas. 26 00:03:20,978 --> 00:03:25,848 We also welcome the proposal that sign language classes for families with 27 00:03:25,848 --> 00:03:31,368 Deaf children will become a statutory provision. 28 00:03:32,505 --> 00:03:39,607 BDA advised on the need for Deaf signers to be able to use technological advances, 29 00:03:39,607 --> 00:03:46,099 in the same way VRS became crucial during the Covid pandemic and increased 30 00:03:46,099 --> 00:03:51,939 use of BSL/ISL in the media and schools. We also repeated the important of 31 00:03:51,939 --> 00:03:57,719 Deaf signers being involved and leading at all stages of the introduction of these 32 00:03:57,719 --> 00:03:59,339 new ways of working. 33 00:03:59,806 --> 00:04:05,035 We also said the Department for Communities should support members 34 00:04:05,035 --> 00:04:10,385 of the deaf community to develop their skills and capacities towards taking 35 00:04:10,385 --> 00:04:18,585 leadership roles in designing and delivering policies to implement 36 00:04:18,585 --> 00:04:19,937 access to sign language. 37 00:04:26,164 --> 00:04:36,154 3) Do you think the duty placed on prescribed organisations to make the 38 00:04:36,154 --> 00:04:41,564 information and services accessible to members of the deaf community 39 00:04:41,564 --> 00:04:42,621 is sufficient? 40 00:04:43,890 --> 00:04:51,342 BDA acknowledge the Bill will place a responsibility on “prescribed” government 41 00:04:51,342 --> 00:05:01,172 departments to draw up Action plans in consultation with Deaf people on what 42 00:05:01,172 --> 00:05:12,572 should be translated, and in what priority order. We accept not everything 43 00:05:12,572 --> 00:05:19,592 needs to be or can be translated, but Deaf signers should lead on creating 44 00:05:19,592 --> 00:05:29,392 clear guidance on what is important. This is particularly true in an emergency 45 00:05:29,392 --> 00:05:32,850 situation or crisis. 46 00:05:34,666 --> 00:05:41,436 Interpreters should be provided at no extra cost to the Deaf signer and 47 00:05:41,436 --> 00:05:52,248 this can be a mix of face-to-face and VRS/VRI. 48 00:05:54,448 --> 00:06:02,748 Finally, again, BDA emphasised the need to involve Deaf people at all stages 49 00:06:02,748 --> 00:06:10,642 of development and implementation, and for a commitment to develop Deaf leadership. 50 00:06:16,532 --> 00:06:27,182 4) Do you support the approach taken by Clause 4 that DfC is responsible for 51 00:06:27,182 --> 00:06:33,796 creating the list of public bodies who the Act will apply to? 52 00:06:34,989 --> 00:06:43,719 BDA NI believes that the Department for Communities is best placed to do this. 53 00:06:43,719 --> 00:06:47,719 They have a long history of working with the Deaf sector and will have 54 00:06:47,719 --> 00:06:51,052 responsibilities over the implementation of the Bill. 55 00:06:58,468 --> 00:07:08,858 5) Do you support the approach to consultation required in Clause 5 that 56 00:07:08,858 --> 00:07:21,778 DfC must issue guidance on implementing the Bill through consulting with stakeholders 57 00:07:23,525 --> 00:07:27,525 It is very important that consultation takes place so organisations are prepared 58 99:59:59,999 --> 99:59:59,999 to take on their obligations under the Act. Although DfC will have authority to issue 59 99:59:59,999 --> 99:59:59,999 guidance, and review guidance, BDA wants to see the Bill going further 60 99:59:59,999 --> 99:59:59,999 by stating how often and when these consultations and reviews should happen. 61 99:59:59,999 --> 99:59:59,999 We also ask for further clarification on how Deaf communities will be consulted - 62 99:59:59,999 --> 99:59:59,999 we believe it needs both individual views and those of the 63 99:59:59,999 --> 99:59:59,999 Deaf community as a whole. 64 99:59:59,999 --> 99:59:59,999 6) Do you support the approach taken in this clause where DfC should give 65 99:59:59,999 --> 99:59:59,999 best practice advised to various organisations? 66 99:59:59,999 --> 99:59:59,999 BDA referred to the Irish Sign Language Act 2017: after three years, 52% of Irish public bodies 67 99:59:59,999 --> 99:59:59,999 were still not aware of their responsibilities under the Act. To avoid this happening in 68 99:59:59,999 --> 99:59:59,999 Northern Ireland, BDA recommends a robust programme of best practice guidance. 69 99:59:59,999 --> 99:59:59,999 This way, all departments should know exactly what they need to do, and their 70 99:59:59,999 --> 99:59:59,999 actions plans are produced in conjunction with Deaf input and there is availability of 71 99:59:59,999 --> 99:59:59,999 both BSL and ISL interpreter support across NI. 72 99:59:59,999 --> 99:59:59,999 7) Do you support the provision for the Department for Communities to make 73 99:59:59,999 --> 99:59:59,999 make further regulations in the future? 74 99:59:59,999 --> 99:59:59,999 BDA agrees that a flexible approach is appropriate because all organisations 75 99:59:59,999 --> 99:59:59,999 will be on a learning journey as they navigate this new legislation. 76 99:59:59,999 --> 99:59:59,999 Identifying issues and putting in regulations to deal with these issues 77 99:59:59,999 --> 99:59:59,999 is practical and welcomed. 78 99:59:59,999 --> 99:59:59,999 8) Do you feel the level of consultation required to bring in regulations is sufficient? 79 99:59:59,999 --> 99:59:59,999 Yes, BDA is clear that both individuals and organisations representing the 80 99:59:59,999 --> 99:59:59,999 Deaf community should be included in this. 81 99:59:59,999 --> 99:59:59,999 9) Do you think evaluating the impact of the Bill in a report every five years is 82 99:59:59,999 --> 99:59:59,999 an appropriate length of time? 83 99:59:59,999 --> 99:59:59,999 BDA carefully considered what would be the most appropriate amount of time. 84 99:59:59,999 --> 99:59:59,999 We took into account experience from both Scotland and Ireland’s implementation 85 99:59:59,999 --> 99:59:59,999 of their legislation. We believe 5 years is a reasonable time period, but we think 86 99:59:59,999 --> 99:59:59,999 there should be annual reports submitted to DfC during this 5 year period 87 99:59:59,999 --> 99:59:59,999 to highlight any issues and allow remedial action. 88 99:59:59,999 --> 99:59:59,999 10) Do you support the creation of a scheme for accrediting BSL and ISL teachers? 89 99:59:59,999 --> 99:59:59,999 There is a need for a scheme for BSL/ISL teachers and assessors. 90 99:59:59,999 --> 99:59:59,999 We recommend it is based on one of two successful models already in existence: 91 99:59:59,999 --> 99:59:59,999 the Association of British Sign Language Teachers and Assessors (ABSLTA); 92 99:59:59,999 --> 99:59:59,999 or the National Registers of Communication Professionals Working with Deaf and Deafblind 93 99:59:59,999 --> 99:59:59,999 (UK) (NRCPD). A separate scheme for supporting deaf teachers would be very 94 99:59:59,999 --> 99:59:59,999 valuable. This can offer networking, sharing of ideas, support etc. 95 99:59:59,999 --> 99:59:59,999 Creating a list of qualified teachers that could identify if they teach ISL or BSL, 96 99:59:59,999 --> 99:59:59,999 what levels, what ages etc would be very useful for people, schools, 97 99:59:59,999 --> 99:59:59,999 and families seeking this service. 98 99:59:59,999 --> 99:59:59,999 *Do you support the creation of a scheme for accrediting BSL and ISL interpreters? 99 99:59:59,999 --> 99:59:59,999 This is the one area mentioned in the introduction where BDA does NOT 100 99:59:59,999 --> 99:59:59,999 support the suggested wording. This is because it implies creating a whole 101 99:59:59,999 --> 99:59:59,999 new scheme for accreditation. BDA says there is already a system that 102 99:59:59,999 --> 99:59:59,999 covers the whole of the UK and is fit for purpose - the National Registers of 103 99:59:59,999 --> 99:59:59,999 Communication Professionals Working with Deaf and Deafblind People (UK) (NRCPD). 104 99:59:59,999 --> 99:59:59,999 Creating a second new scheme specifically for Northern Ireland is an unnecessary duplication 105 99:59:59,999 --> 99:59:59,999 which could cause confusion. 106 99:59:59,999 --> 99:59:59,999 11) Do you agree with the definition of the deaf community provided for in the Bill? 107 99:59:59,999 --> 99:59:59,999 BDA is conscious of the sensitivity in use of language here. There is no formal 108 99:59:59,999 --> 99:59:59,999 definition of ‘deaf community’ and no deaf person has to view themselves as part of it. 109 99:59:59,999 --> 99:59:59,999 For the purpose of this Bill, we believe the proposed wording is appropriate. 110 99:59:59,999 --> 99:59:59,999 12) Do you agree with the definition of BSL and ISL provided for in the Bill? 111 99:59:59,999 --> 99:59:59,999 Yes, BDA agrees with the definitions. 112 99:59:59,999 --> 99:59:59,999 13) Do you agree with the definition of “everyday reliance” provided in the Bill? 113 99:59:59,999 --> 99:59:59,999 BDA supports the proposed definition. But we want to make it clear that many 114 99:59:59,999 --> 99:59:59,999 deaf people face barriers every day stemming from communication issues. 115 99:59:59,999 --> 99:59:59,999 These issues exist even within families, for example where deaf children are born 116 99:59:59,999 --> 99:59:59,999 to hearing families. The importance of programmes such as Family Signing 117 99:59:59,999 --> 99:59:59,999 in the Home is absolutely critical for giving the best start to the next generation 118 99:59:59,999 --> 99:59:59,999 of deaf children and importantly, for supporting their families too. 119 99:59:59,999 --> 99:59:59,999 NI Deaf communities have a wide and rich range of variations in personal 120 99:59:59,999 --> 99:59:59,999 circumstances and in their individual language journeys, and BDA agrees the 121 99:59:59,999 --> 99:59:59,999 definition is inclusive for all.