Sign Language Bill ISL Video

SUMMARY OF WRITTEN SUBMISSION
FROM BRITISH DEAF ASSOCIATION

(NORTHERN IRELAND) –
Sign Language Bill

The Northern Ireland Assembly is
debating the Sign Language Bill.

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

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

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

what that included.

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

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

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

languages of Northern Ireland?

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

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

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

such as the Disability Discrimination Act
or Human Rights Acts.

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

is already given equal status.

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

developing deaf culture?

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

linguistic minority matter.
However, we notice that decisions

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

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

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

to invest in developing
Deaf leadership in these areas.

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

Deaf children will become
a statutory provision.

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

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

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

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

new ways of working.

We also said the Department for
Communities should support members

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

leadership roles in designing and
delivering policies to implement

access to sign language.

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

information and services accessible
to members of the deaf community

is sufficient?

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

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

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

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

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

situation or crisis.

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

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

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

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

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

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

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

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

responsibilities over the
implementation of the Bill.

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

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

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

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

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

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

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

we believe it needs both individual
views and those of the

Deaf community as a whole.

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

best practice advised to
various organisations?

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

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

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

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

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

both BSL and ISL interpreter
support across NI.

7) Do you support the provision for
the Department for Communities to

make further regulations in the future?

BDA agrees that a flexible approach is
appropriate because all organisations

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

Identifying issues and putting in
regulations to deal with these issues

is practical and welcomed.

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

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

Deaf community should be
included in this.

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

an appropriate length of time?

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

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

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

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

to highlight any issues and
allow remedial action.

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

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

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

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

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

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

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

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

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

and families seeking this service.

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

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

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

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

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

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

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

which could cause confusion.

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

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

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

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

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

Yes, BDA agrees with the definitions.

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

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

deaf people face barriers every day
stemming from communication issues.

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

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

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

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

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

circumstances and in their individual
language journeys, and BDA agrees the

definition is inclusive for all.