WEBVTT 00:00:08.103 --> 00:00:14.043 SUMMARY OF WRITTEN SUBMISSION FROM BRITISH DEAF ASSOCIATION 00:00:14.043 --> 00:00:18.043 (NORTHERN IRELAND) – Sign Language Bill 00:00:18.950 --> 00:00:24.376 The Northern Ireland Assembly is debating the Sign Language Bill. 00:00:24.909 --> 00:00:33.199 To help them do this, its Communities Committee asked for feedback from any 00:00:33.199 --> 00:00:42.437 person or group – either via video on WhatsApp or in writing. 00:00:42.997 --> 00:00:51.517 The BDA (NI) submitted a written response and this is a summary of 00:00:51.517 --> 00:00:53.671 what that included. 00:00:54.633 --> 00:01:04.669 BDA fully agrees with the proposed new law with one exception (more on that later). 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. 00:01:20.808 --> 00:01:32.438 1) Do you feel Clause 1 goes far enough in formally recognising BSL and ISL as 00:01:32.438 --> 00:01:34.082 languages of Northern Ireland? 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 00:01:46.859 --> 00:01:57.199 the same rights as other spoken languages such as Irish and Ulster Scots while not 00:01:57.199 --> 00:02:04.569 affecting or impacting other important laws that might apply to an individual - 00:02:04.569 --> 00:02:11.129 such as the Disability Discrimination Act or Human Rights Acts. 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 00:02:17.769 --> 00:02:25.035 is already given equal status. 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 00:02:41.556 --> 00:02:43.746 developing deaf culture? 00:02:44.282 --> 00:02:50.942 BDA welcomes the approach of viewing signing not as a disability issue but a 00:02:50.942 --> 00:02:55.472 linguistic minority matter. However, we notice that decisions 00:02:55.472 --> 00:03:02.012 are often made in relation to deaf services or sign language services without meaningful 00:03:02.012 --> 00:03:08.872 deaf input. We want to see a more robust way of including Deaf signers in 00:03:08.872 --> 00:03:15.512 the process of planning, delivering and evaluating. We want to see a commitment 00:03:15.512 --> 00:03:20.795 to invest in developing Deaf leadership in these areas. 00:03:20.978 --> 00:03:25.848 We also welcome the proposal that sign language classes for families with 00:03:25.848 --> 00:03:31.368 Deaf children will become a statutory provision. 00:03:32.505 --> 00:03:39.607 BDA advised on the need for Deaf signers to be able to use technological advances, 00:03:39.607 --> 00:03:46.099 in the same way VRS became crucial during the Covid pandemic and increased 00:03:46.099 --> 00:03:51.939 use of BSL/ISL in the media and schools. We also repeated the important of 00:03:51.939 --> 00:03:57.719 Deaf signers being involved and leading at all stages of the introduction of these 00:03:57.719 --> 00:03:59.339 new ways of working. 00:03:59.806 --> 00:04:05.035 We also said the Department for Communities should support members 00:04:05.035 --> 00:04:10.385 of the deaf community to develop their skills and capacities towards taking 00:04:10.385 --> 00:04:18.585 leadership roles in designing and delivering policies to implement 00:04:18.585 --> 00:04:19.937 access to sign language. 00:04:26.164 --> 00:04:36.154 3) Do you think the duty placed on prescribed organisations to make the 00:04:36.154 --> 00:04:41.564 information and services accessible to members of the deaf community 00:04:41.564 --> 00:04:42.621 is sufficient? 00:04:43.890 --> 00:04:51.342 BDA acknowledge the Bill will place a responsibility on “prescribed” government 00:04:51.342 --> 00:05:01.172 departments to draw up Action plans in consultation with Deaf people on what 00:05:01.172 --> 00:05:12.572 should be translated, and in what priority order. We accept not everything 00:05:12.572 --> 00:05:19.592 needs to be or can be translated, but Deaf signers should lead on creating 00:05:19.592 --> 00:05:29.392 clear guidance on what is important. This is particularly true in an emergency 00:05:29.392 --> 00:05:32.850 situation or crisis. 00:05:34.666 --> 00:05:41.436 Interpreters should be provided at no extra cost to the Deaf signer and 00:05:41.436 --> 00:05:52.248 this can be a mix of face-to-face and VRS/VRI. 00:05:54.448 --> 00:06:02.748 Finally, again, BDA emphasised the need to involve Deaf people at all stages 00:06:02.748 --> 00:06:10.642 of development and implementation, and for a commitment to develop Deaf leadership. 00:06:16.532 --> 00:06:27.182 4) Do you support the approach taken by Clause 4 that DfC is responsible for 00:06:27.182 --> 00:06:33.796 creating the list of public bodies who the Act will apply to? 00:06:34.989 --> 00:06:43.719 BDA NI believes that the Department for Communities is best placed to do this. 00:06:43.719 --> 00:06:47.719 They have a long history of working with the Deaf sector and will have 00:06:47.719 --> 00:06:51.052 responsibilities over the implementation of the Bill. 00:06:58.468 --> 00:07:08.858 5) Do you support the approach to consultation required in Clause 5 that 00:07:08.858 --> 00:07:21.778 DfC must issue guidance on implementing the Bill through consulting with stakeholders 00:07:23.525 --> 00:07:27.525 It is very important that consultation takes place so organisations are prepared 99:59:59.999 --> 99:59:59.999 to take on their obligations under the Act. Although DfC will have authority to issue 99:59:59.999 --> 99:59:59.999 guidance, and review guidance, BDA wants to see the Bill going further 99:59:59.999 --> 99:59:59.999 by stating how often and when these consultations and reviews should happen. 99:59:59.999 --> 99:59:59.999 We also ask for further clarification on how Deaf communities will be consulted - 99:59:59.999 --> 99:59:59.999 we believe it needs both individual views and those of the 99:59:59.999 --> 99:59:59.999 Deaf community as a whole. 99:59:59.999 --> 99:59:59.999 6) Do you support the approach taken in this clause where DfC should give 99:59:59.999 --> 99:59:59.999 best practice advised to various organisations? 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 99:59:59.999 --> 99:59:59.999 were still not aware of their responsibilities under the Act. To avoid this happening in 99:59:59.999 --> 99:59:59.999 Northern Ireland, BDA recommends a robust programme of best practice guidance. 99:59:59.999 --> 99:59:59.999 This way, all departments should know exactly what they need to do, and their 99:59:59.999 --> 99:59:59.999 actions plans are produced in conjunction with Deaf input and there is availability of 99:59:59.999 --> 99:59:59.999 both BSL and ISL interpreter support across NI. 99:59:59.999 --> 99:59:59.999 7) Do you support the provision for the Department for Communities to make 99:59:59.999 --> 99:59:59.999 make further regulations in the future? 99:59:59.999 --> 99:59:59.999 BDA agrees that a flexible approach is appropriate because all organisations 99:59:59.999 --> 99:59:59.999 will be on a learning journey as they navigate this new legislation. 99:59:59.999 --> 99:59:59.999 Identifying issues and putting in regulations to deal with these issues 99:59:59.999 --> 99:59:59.999 is practical and welcomed. 99:59:59.999 --> 99:59:59.999 8) Do you feel the level of consultation required to bring in regulations is sufficient? 99:59:59.999 --> 99:59:59.999 Yes, BDA is clear that both individuals and organisations representing the 99:59:59.999 --> 99:59:59.999 Deaf community should be included in this. 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 99:59:59.999 --> 99:59:59.999 an appropriate length of time? 99:59:59.999 --> 99:59:59.999 BDA carefully considered what would be the most appropriate amount of time. 99:59:59.999 --> 99:59:59.999 We took into account experience from both Scotland and Ireland’s implementation 99:59:59.999 --> 99:59:59.999 of their legislation. We believe 5 years is a reasonable time period, but we think 99:59:59.999 --> 99:59:59.999 there should be annual reports submitted to DfC during this 5 year period 99:59:59.999 --> 99:59:59.999 to highlight any issues and allow remedial action. 99:59:59.999 --> 99:59:59.999 10) Do you support the creation of a scheme for accrediting BSL and ISL teachers? 99:59:59.999 --> 99:59:59.999 There is a need for a scheme for BSL/ISL teachers and assessors. 99:59:59.999 --> 99:59:59.999 We recommend it is based on one of two successful models already in existence: 99:59:59.999 --> 99:59:59.999 the Association of British Sign Language Teachers and Assessors (ABSLTA); 99:59:59.999 --> 99:59:59.999 or the National Registers of Communication Professionals Working with Deaf and Deafblind 99:59:59.999 --> 99:59:59.999 (UK) (NRCPD). A separate scheme for supporting deaf teachers would be very 99:59:59.999 --> 99:59:59.999 valuable. This can offer networking, sharing of ideas, support etc. 99:59:59.999 --> 99:59:59.999 Creating a list of qualified teachers that could identify if they teach ISL or BSL, 99:59:59.999 --> 99:59:59.999 what levels, what ages etc would be very useful for people, schools, 99:59:59.999 --> 99:59:59.999 and families seeking this service. 99:59:59.999 --> 99:59:59.999 *Do you support the creation of a scheme for accrediting BSL and ISL interpreters? 99:59:59.999 --> 99:59:59.999 This is the one area mentioned in the introduction where BDA does NOT 99:59:59.999 --> 99:59:59.999 support the suggested wording. This is because it implies creating a whole 99:59:59.999 --> 99:59:59.999 new scheme for accreditation. BDA says there is already a system that 99:59:59.999 --> 99:59:59.999 covers the whole of the UK and is fit for purpose - the National Registers of 99:59:59.999 --> 99:59:59.999 Communication Professionals Working with Deaf and Deafblind People (UK) (NRCPD). 99:59:59.999 --> 99:59:59.999 Creating a second new scheme specifically for Northern Ireland is an unnecessary duplication 99:59:59.999 --> 99:59:59.999 which could cause confusion. 99:59:59.999 --> 99:59:59.999 11) Do you agree with the definition of the deaf community provided for in the Bill? 99:59:59.999 --> 99:59:59.999 BDA is conscious of the sensitivity in use of language here. There is no formal 99:59:59.999 --> 99:59:59.999 definition of ‘deaf community’ and no deaf person has to view themselves as part of it. 99:59:59.999 --> 99:59:59.999 For the purpose of this Bill, we believe the proposed wording is appropriate. 99:59:59.999 --> 99:59:59.999 12) Do you agree with the definition of BSL and ISL provided for in the Bill? 99:59:59.999 --> 99:59:59.999 Yes, BDA agrees with the definitions. 99:59:59.999 --> 99:59:59.999 13) Do you agree with the definition of “everyday reliance” provided in the Bill? 99:59:59.999 --> 99:59:59.999 BDA supports the proposed definition. But we want to make it clear that many 99:59:59.999 --> 99:59:59.999 deaf people face barriers every day stemming from communication issues. 99:59:59.999 --> 99:59:59.999 These issues exist even within families, for example where deaf children are born 99:59:59.999 --> 99:59:59.999 to hearing families. The importance of programmes such as Family Signing 99:59:59.999 --> 99:59:59.999 in the Home is absolutely critical for giving the best start to the next generation 99:59:59.999 --> 99:59:59.999 of deaf children and importantly, for supporting their families too. 99:59:59.999 --> 99:59:59.999 NI Deaf communities have a wide and rich range of variations in personal 99:59:59.999 --> 99:59:59.999 circumstances and in their individual language journeys, and BDA agrees the 99:59:59.999 --> 99:59:59.999 definition is inclusive for all.