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SUMMARY OF WRITTEN SUBMISSION
FROM BRITISH DEAF ASSOCIATION
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(NORTHERN IRELAND) –
Sign Language Bill
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The Northern Ireland Assembly is
debating the Sign Language Bill.
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To help them do this, its Communities
Committee asked for feedback from any
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person or group – either via video
on WhatsApp or in writing.
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The BDA (NI) submitted a written
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
law with one exception (more on that later).
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However, we are calling for the Bill to
go even further and will give more details below.
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1) Do you feel Clause 1 goes far enough
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
strong enough. The Bill will give Sign Language
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the same rights as other spoken languages
such as Irish and Ulster Scots while not
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affecting or impacting other important
laws that might apply to an individual -
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such as the Disability Discrimination Act
or Human Rights Acts.
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The Act will also bring NI in line with
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
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
signing not as a disability issue but a
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linguistic minority matter.
However, we notice that decisions
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are often made in relation to deaf services
or sign language services without meaningful
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deaf input. We want to see a more
robust way of including Deaf signers in
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the process of planning, delivering and
evaluating. We want to see a commitment
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to invest in developing
Deaf leadership in these areas.
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We also welcome the proposal that
sign language classes for families with
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Deaf children will become
a statutory provision.
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BDA advised on the need for Deaf signers
to be able to use technological advances,
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in the same way VRS became crucial
during the Covid pandemic and increased
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use of BSL/ISL in the media and schools.
We also repeated the important of
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Deaf signers being involved and leading
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
Communities should support members
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of the deaf community to develop their
skills and capacities towards taking
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leadership roles in designing and
delivering policies to implement
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access to sign language.
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3) Do you think the duty placed on
prescribed organisations to make the
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information and services accessible
to members of the deaf community
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is sufficient?
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BDA acknowledge the Bill will place a
responsibility on “prescribed” government
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departments to draw up Action plans
in consultation with Deaf people on what
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should be translated, and in what
priority order. We accept not everything
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needs to be or can be translated,
but Deaf signers should lead on creating
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clear guidance on what is important.
This is particularly true in an emergency
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situation or crisis.
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Interpreters should be provided at
no extra cost to the Deaf signer and
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this can be a mix of face-to-face
and VRS/VRI.
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Finally, again, BDA emphasised the
need to involve Deaf people at all stages
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of development and implementation,
and for a commitment to develop Deaf leadership.
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4) Do you support the approach taken
by Clause 4 that DfC is responsible for
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creating the list of public bodies
who the Act will apply to?
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BDA NI believes that the Department for
Communities is best placed to do this.
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They have a long history of working
with the Deaf sector and will have
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responsibilities over the
implementation of the Bill.
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5) Do you support the approach to
consultation required in Clause 5 that
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DfC must issue guidance on implementing
the Bill through consulting with stakeholders
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It is very important that consultation
takes place so organisations are prepared
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to take on their obligations under the Act.
Although DfC will have authority to issue
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guidance, and review guidance,
BDA wants to see the Bill going further
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by stating how often and when these
consultations and reviews should happen.
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We also ask for further clarification on
how Deaf communities will be consulted -
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we believe it needs both individual
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
in this clause where DfC should give
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best practice advised to
various organisations?
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BDA referred to the Irish Sign Language Act 2017:
after three years, 52% of Irish public bodies
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were still not aware of their responsibilities
under the Act. To avoid this happening in
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Northern Ireland, BDA recommends a
robust programme of best practice guidance.
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This way, all departments should know
exactly what they need to do, and their
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actions plans are produced in conjunction
with Deaf input and there is availability of
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both BSL and ISL interpreter
support across NI.
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7) Do you support the provision for
the Department for Communities to make
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make further regulations in the future?
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BDA agrees that a flexible approach is
appropriate because all organisations
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will be on a learning journey as they
navigate this new legislation.
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Identifying issues and putting in
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
required to bring in regulations is sufficient?
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Yes, BDA is clear that both individuals
and organisations representing the
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Deaf community should be
included in this.
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9) Do you think evaluating the impact
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
be the most appropriate amount of time.
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We took into account experience from
both Scotland and Ireland’s implementation
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of their legislation. We believe 5 years
is a reasonable time period, but we think
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there should be annual reports
submitted to DfC during this 5 year period
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to highlight any issues and
allow remedial action.
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10) Do you support the creation of a
scheme for accrediting BSL and ISL teachers?