Multi-Year Accessibility Plan Progress Report

MILITARY POLICE COMPLAINTS COMMISSION OF CANADA

Multi-Year Accessibility Plan Progress Report

January 1, 2023 to December 31, 2023

© His Majesty the King in Right of Canada, represented by the Military Police Complaints Commission of Canada, 2023

Catalogue No. DP2-8E-PDF | ISSN 2817‑2175


Table of Contents


Message from the Chairperson

I am pleased to present the Military Police Complaints Commission’s (MPCC) first Accessibility Action Plan Progress Report. This report provides updates on the MPCC’s advancement in implementing improvements as identified in the Accessible Canada Act and ensuring that it remains barrier-free and a leader in accessibility.

As a small administrative tribunal, the MPCC has long held that requests for accommodation from people with disabilities must be accommodated. This applies to employees and the public it serves. It is a core tenet for fair and unfettered access to administrative justice and for access to a safe workplace.  Over the years, the MPCC has made changes to its physical workspace to accommodate people with disabilities, including transforming its office space into an accessible workspace and replacing push button door openers with a touchless system. It has remained flexible and open in how it receives complaints against the military police, and how it communicates with the people it serves.

The goals we have set for ourselves in our Multi-Year Accessibility Plan allow us to proactively monitor and make improvements in each of the priority areas identified in the Accessible Canada Act, namely employment, built environment, information and communication technologies, other communications, the procurement of goods and services and the design and delivery of programs and services.

While the MPCC currently surpasses the Government of Canada’s 2025 target of 7% of its employees identifying as persons with disabilities, with 14.3% of staff identifying as persons with disabilities, more remains to be done. In the coming years, we are committed to strengthening our internal processes, as we strive to become more inclusive and accessible to the benefit of those we serve. We remain steadfast in using an approach that is trauma-informed, incorporating GBA++ principles, and viewing our work through an equity, diversity and inclusion lens.

I look forward to working with our partners in the Government of Canada to ensure that the important goals of the Accessible Canada Act are met. We warmly welcome all feedback and comments on this progress report and the steps we have taken to increase accessibility for all.  

Me Tammy Tremblay, MSM, CD, LL.M

Chairperson


General

The Military Police Complaints Commission of Canada (MPCC) is a civilian, quasi-judicial oversight agency that operates at arm’s length from the Government of Canada. The MPCC derives its mandate from Part IV of Canada's National Defence Act (NDA). While it reports to Parliament through the Minister of National Defence, the MPCC is both administratively and legally independent from the Department of National Defence and the Canadian Armed Forces.  The MPCC is formally part of the Core Public Administration under the Institution Schedule I.1 and of the HR Schedule IV of the Financial Administration Act (FAA).

The MPCC regularly monitors and evaluates feedback concerning accessibility and ensures that it is incorporated into its plans when possible. Please reference Annex A: Feedback process at the Military Police Complaints Commission of Canada for more information on our feedback process.

Contact us

Contact the Senior Director, Corporate Services to:

  • provide feedback or ask questions
  • request the accessibility plan in an alternative format.
  • request descriptions of the MPCC’s feedback process in an alternative format
By mail

Military Police Complaints Commission of Canada
Attention: Senior Director, Corporate Services
270 Albert Street, 10th Floor
Ottawa, ON, K1P 5G8

By phone
  • Toll-free: 1-800-632-0566
  • Local: 613-947-5625

Operating hours are Monday to Friday from 8 a.m. to 4 p.m. ET, excluding statutory holidays.

By email: reception@mpcc-cppm.gc.ca

Feedback can be submitted either with an identified contact or anonymously. We will acknowledge the receipt of all accessibility feedback in the same means by which it is received unless the feedback is received anonymously.

Feedback can be submitted either with an identified contact or anonymously. We will acknowledge the receipt of all accessibility feedback in the same means by which it is received unless the feedback is received anonymously.

Accessibility Statement

The Military Police Complaints Commission strives to be an organization that exhibits fairness and impartiality, inspires trust, and contributes to a climate of confidence in military policing. The MPCC strives to be barrier-free, accessible and inclusive to all and is committed to providing accessible and inclusive services for all employees, clients, complainants, subjects and other stakeholders. MPCC will review and develop its programs, policies, directives and services with the intent to continually improve.

Progress

The Military Police Complaints’ Commission’s (MPCC) three-year Accessibility Report was prepared in consultation with a third-party consultation firm, and with the input of subject matter experts within the MPCC, external stakeholders and people with disabilities. The MPCC is a small agency with approximately 31 full-time employees and three part-time members. The implementation of its Accessibility Report is done in accordance with its resources and needs. As of March 2023, 14.3% of the MPCC’s employees identified as a person with a disability.

To attain the goals of the Accessible Canada Act, the MPCC began its progress on proactively identifying, removing, and preventing barriers in six (6) of the seven (7) priority areas:

Employment

The MPCC is dedicated to implementing government-wide initiatives and increasing representation of persons with disabilities across all occupational groups and levels. As such, the MPCC is committed to removing and preventing barriers to recruitment, retention, and the promotion of persons with disabilities. The MPCC’s Human Resources recruitment continues to actively offer accommodation throughout the assessment phases, up to and including the letter of offer.  Once hired, employees who subsequently identify a need for accommodations can submit a request to their manager who in turn will reach out to the various members of the corporate services team for action.  Various other measures are in place to support people with disabilities in helping ensure their full participation in the workplace. Some examples:

  • Emergency protocols for floor evacuations at the MPCC include consideration for employees with disabilities.
  • All documents posted on the website are accessible.
  • Alternative formats and communication supports are provided when requested by a user or employee.
  • The development of policies and procedures are made in consideration of accessibility, GBA++ and equity, diversity and inclusion practices.
  • Where operationally feasible, the MPCC continues to facilitate telework and flexible work arrangements to accommodate the needs of all employees.

Goal

Continued efforts should be made to increase MPCC employee’s awareness on accessibility upon appointment and thereafter, so they are aware of their rights to accommodation.

Action Target Timeline Status

Review and determine general training/information sessions, tools, or communication strategy to increase employees’ and managers’ awareness and knowledge on accessibility.

2023

The MPCC is currently reviewing its internal Learning Directive to identify appropriate training for employees and managers related to accessibility. The goal is to determine which training activities will be mandatory for MPCC employees and managers holding supervisory positions, to support growing employees’ awareness about accessibility and accommodations.

In 2023, our Human Resources (HR) department researched and liaised with other departments to identify best practices in terms of training, in particular about accessibility, equity, diversity and inclusion. It also sought feedback from employees to better understand learning needs and understand barriers to learning.

We anticipate that the review and updates will be complete in 2024 and a new list of mandatory training will be rolled out to employees.

Additionally, throughout the year, HR used Teams as an accessible tool to share resources with employees periodically about accessibility; mental health; and equity, diversity and inclusion.

Adopt the GC Workplace Accessibility Passport which is a tool for public service employees and applicants to document and support measures and tools they need to succeed in the workplace. 2023

The MPCC adhered to the GC Workplace Accessibility Passport and participates in the interdepartmental working group that was launched this fall.

In the next year, the MPCC will hold information sessions for its employees to promote the use of the passport.

Review and determine targeted training to employees who are tasked to draft / publish public documents to ensure that these meet the accessibility standards for communication.

2023-2024

This action item is ongoing. HR has researched appropriate training for its employees and continues its effort to find appropriate learning for those who require it. This year, HR amended job descriptions to ensure accountability in ensuring that accessibility standards were met.

Additional goals:

  • While the MPCC currently exceeds the Government of Canada target employment rate for people with disabilities, it strives to support the government-wide initiative to increase representation across the Public Service. As such, the MPCC targets and considers hiring people with disabilities when it conducts hiring processes, to advance the overall Government of Canada strategy.
  • The MPCC continues to offer ergonomic assessments and does not require medical certificates, in order to support employees who require it.

Built Environment

The MPCC continues to pursue an accessible built environment. As such, the MPCC works with employees, building owners, and Public Services and Procurement Canada (PSPC) to achieve the highest level of accessibility in the current office space.  The office of the MPCC is in downtown Ottawa, in a building owned by a private company, where the government space is leased by PSPC.  The MPCC is one of many tenants that share some of the common areas, such as the entrance to the building, lobby area, elevators, washroom facilities and parking. The building includes a wheelchair ramp and power door operators at the entrance. Power operated doors are also available at the MPCC office entrances and at the washroom entrances.  Washrooms include an accessible stall. MPCC workstations are equipped with power sit/stand desks and ergonomic office chairs allowing an accessible desk set-up to respond to employee accommodations.

Goal

There are no identified barriers under MPCC’s responsibility.

Action Target Timeline Progress

An external subject matter expert (SME) will be engaged to provide recommendations to continuously improve office accessibility.

2023

This year, the MPCC engaged with PSPC to enquire about having a subject matter expert provide recommendations for the continuous improvement of the MPCC’s physical offices located downtown Ottawa. The MPCC does not currently have access to an accessibility review from PSPC; however, PSPC was able to provide valuable information to guide the MPCC with future needs.

The MPCC will continue to organise monthly walk throughs of its office space by its Occupational Health and Safety Committee to identify accessibility issues. We will monitor and track any accessibility issues for action.

The MPCC received feedback this year about one of its two boardrooms, which caused accessibility issues for persons with reduced mobility, given the layout of the boardroom and the placement of bookshelves around the boardroom table. The MPCC is currently addressing this feedback by removing the books and bookshelves and moving them to a different location in the office, to free up space around the boardroom. This will address the accessibility issue.

We will use the inclusive design checklist for accessibility considerations (including design, safety, ergonomics, and signage). 2023

In consultation with other government departments, the MPCC is currently developing a Disability Consideration Checklist to aid in identifying accessibility consideration on an ongoing basis.

Information and Communication Technologies (ICT)

The MPCC webpage is a sub-page of the Government of Canada website. The pages are templated and follow a specified structure.  MPCC employees can add content to the webpage which provides a mechanism to file complaints with the MPCC. The MPCC does not have an intranet page.

Goal

Content added to the webpage must be accessible and the MPCC must increase its internal expertise and capacity in creating accessible documents.

Action Target Timeline Progress

Ensure all content posted to the webpage is compliant to Web Content Accessibility Guidelines (WCAG) requirements.

2023-2024

The MPCC has reviewed the content of its external webpage (to note, the MPCC does not have an intranet). Currently, the MPCC meets all the WCGA 2.0 requirements.

The MPCC will proceed this year to review the content of the external webpage to ensure it meets the 2.1 requirements.

This work will be ongoing as new requirements are introduced.

Review systems, software, and equipment to ensure that they are accessible. Where they are not accessible, the MPCC will develop a plan to remediate the accessibility shortfalls.

2025

The MPCC is currently at the review stage of this action item. We are reviewing our systems, software and equipment to ensure they meet the Government of Canada’s Guidelines on Making IT Usable by All.

The MPCC will:

  • Ensure that accessibility features are enabled for their IT solutions and equipment.
  • Leverage enterprise tools and capacity to ensure that internal-facing IT solutions and equipment are accessible for public servants.
  • Work with Shared Service Canada and its Accessibility, Accommodation and Adaptive Computer Technology (AAACT) Program to identify and deploy accessible tools and technology, and to remove remaining accessibility barriers associated with IT.
  • Leverage our existing in-house accessibility programs when meeting Government of Canada accessibility requirements.
  • Work in the open and use open-source software to support others in efforts to develop accessible common IT systems across departments, agencies and organisations.

Ensure that accessibility considerations are included in the MPCC ICT plan.

2025

The MPCC is working on updating its IT Asset Management and Planning Policy.

The MPCC currently consists of approximately 31 full-time employees and 3 part-time members. In addition, the MPCC provides a combination of equipment and network access to multiple contractors, in particular to investigators who are external consultants.  The number of investigators that are under contract will vary depending on the MPCC’s operational needs. While it currently has not received any requests for accommodations, the MPCC is working on updating its policy to ensure that accessibility considerations are added to it, particularly while it reviews its infrastructure modernization needs.

Communications other than ICT

The MPCC is dedicated to ensuring all its internal and external communications are accessible. This includes ensuring that MPCC communications are written in plain and accessible language.

Goals

  1. Develop formal processes to provide alternative formats and communication supports in a timely matter, upon request by a user or employee.
  2. Reduce the technical and/or sector specific language used in public-facing reports and documents.
Action Target Timeline Progress

Develop an internal process and information on providing alternative formats and communication supports.

2024

This action item will be addressed next calendar year (2024)

Identify and adopt standards for public-facing communications to be in plain language.

2024

This action item will be addressed next calendar year (2024)

Evaluate current public-facing documents for clarity and plain language and provide plain language versions where necessary.

2024

This work in underway. Web pages have been modified and are currently at the validation stage. We expect them to be translated and posted in 2024.

As well, in 2023, the MPCC’s legal counsel team, as well as all members, received customized training through the Canadian Institute for the Administrative of Justice on how to write accessible decisions The focus of the learning was on the structure of our reports, using plain language and inclusive writing, the whole aimed at improving the accessibility of our reports.

Additional goals:

  • The MPCC will promote accessible and inclusive internal and external communications practices in compliance with the latest Web Content Accessibility Guidelines (WCAG).
  • IT will review the MPCC website to ensure that it meets Web Content Accessibility Guidelines (WCAG) 2.1 (2018) (including: no red/green colours, which are difficult for those with colour blindness; increase contrast between colours in bar graphs; avoiding split/merged cells in tables).

The Procurement of Goods, Services and Facilities

PSPC is a key partner in achieving accessibility at the MPCC. As such, the MPCC will implement procurement principles, rules, and practices with the goal of advancing accessibility objectives.

Goals

Provide external consultants (investigators and others) accessibility-related training prior to being contracted and interacting with MPCC employees and clients.

Action Target Timeline Progress

Provide accessibility training as needed to contractors and investigators as needed.

2023

This action item will be addressed in 2024.

The design and delivery of programs and services

As an organization that offers services to members of the public, the Military Police, the Canadian Armed Forces and to other stakeholders, the MPCC must consider accessibility in the delivery of our programs and services. A fundamental aspect in achieving this is through feedback and by implementing meaningful accessibility improvements.

Goals

No barriers were identified at this time.

Action Target Timeline Progress

Establish processes to provide complainants, subjects, and other stakeholders with alternate formats of their Final Reports which includes the MPCC Findings and Recommendations when requested.

2024

Currently, Final Reports can be sent via email, mail, E-post, or picked up at the MPCC at the request of party. In 2024, the MPCC will explore offering reports in other accessible formats.

Conduct additional external survey with our clients to assess the current state of accessibility with respect to the delivery of our programs and services.

2025

To be addressed in early 2025

When applicable, consult with people with disabilities prior to new policies and procedures to be implemented.

Ongoing

Given its small size, the MPCC is evaluating how to access stakeholder groups.

Adopt standards for public-facing communications to be in plain language.

2024

To be addressed in 2024.

Additional actions:

  • This year, our staff and members received training on trauma-informed practices. The Registry function also reviewed its internal protocols to ensure that a trauma-informed approach was taken when dealing with potential complainants.

Transportation

This priority area under the Act is not applicable to the MPCC.

Consultations

The MPCC’s three-year plan was prepared with the help of an external consultant by first completing an environmental scan to ensure understanding of “central agencies” and other government departments’ accessibility initiatives, and to review existing related policies and procedures. The exercise helped identify existing practices and initiatives that could be adopted as best practices across the organization. Consultations were conducted in three parts:

  1. Subject matter experts at the MPCC were consulted in facilitated focus groups with their knowledge of employment practices, procurement, facilities, digital resources, communications, and the design and delivery of good and services. Questions regarding accessibility barriers, current accommodation practices, and priorities for remediation were discussed and responses have been used to inform this plan.
  2. External Stakeholders, including military family members, law firms and other stakeholders were invited to respond to a survey question about access to services, information and resources as well as accessibility barriers.
  3. Accessible Canada Act Review Committee: The MPCC Accessibility Plan was also reviewed by the consultation firm’s standing Accessible Canada Act Review Committee. Consultation Group members are individuals with lived experience with disabilities, and knowledge of accessibility issues.

For the current Progress Report, the MPCC conducted an internal survey with staff, asking:

  1. Do you feel that your accommodation needs at the MPCC are met, whether it be in the office or in support of your virtual work?
  2. Do you feel like the MPCC is meeting its commitments as laid out in the Multi-Year Accessibility Plan?
  3. What could the MPCC be doing differently to make the workplace (physical or virtual) more accessible for you and/or your colleagues, and for the public?
  4. If you have an accessibility concern at the MPCC, do you know who to speak to?
  5. Are you a person with a disability and do you feel like your needs are being accommodated?

Each of the questions allowed for comments, to maximise the information received from MPCC staff. In total, we received 23 anonymous responses (on a total of 31 FTE, and 3 part-time members).

What we heard

Question Answers Comments

Do you feel that your accommodation needs at the MPCC are met, whether it be in the office or in support of your virtual work?

Yes: 91%

No: 0%

N/A: 9%

Employees noted that:

  • The flexibility of the MPCC in offering remote and hybrid work and flexible schedules was key to accommodating disabilities.
  • Ergonomic assessments were helpful in ensuring a safe workspace.
  • Specific disability needs were met2
  • The MPCC is an inclusive and reliable organization that cares for its employees.

Do you feel like the MPCC is meeting its commitments as laid out in the Multi-Year Accessibility Plan?

Yes: 78%

No: 0%

Not sure: 22%

Employees noted that:

  • The MPCC takes its responsibility to offer accessible services seriously.
  • The MPCC takes employee needs into consideration when organising activities and training.
  • The MPCC makes strong efforts to accommodate employees with disabilities and provides the tools that employees with disabilities need for their work

What could the MPCC be doing differently to make the workplace (physical or virtual) more accessible for you and/or your colleagues, and for the public?

Employees noted that:

  • Improvements could be made to the website.

If you have an accessibility concern at the MPCC, do you know who to speak to?

Yes: 74%

No: 26%

The MPCC will ensure that employees know how to report an accessibility concern through internal communications.

Are you a person with a disability and do you feel like your needs are being accommodated?

No disability: 74%

Yes, disability and needs are accommodated: 26%

Yes, disability and needs are not accommodated: 0%

Feedback

Employees and members of the public are encouraged to share their feedback, anonymously or otherwise, about our Accessibility Action Plan, barriers experienced, or any matter related to accessibility. Individuals can consult the Accessibility Feedback Process (Annex A) for other ways to provide feedback and how we use the feedback we receive.

The MPCC received little feedback in 2023. There are three instances where the MPCC received requests for assistance due to a disability:

Because of the small size of the MPCC, we are not able to provide statistics with regards to employee feedback to avoid identifying employees, in accordance with the Privacy Act. We note however that we received requests for ergonomic assessments, which we are all conducted, and their recommendations implemented.

GLOSSARY

Accessibility:

The degree to which a product, service, program, or environment is available to be used or accessed easily by persons with and without disabilities. Improving accessibility helps everyone participate fully and equally in society and realize their full potential.

Accommodation (adjustment):

Any change in the working environment that allows a person with functional limitations in their abilities to do their job. Changes can include:

Accommodations (adjustments) can be temporary, periodic, or long-term, depending on the employee’s situation or changes in the workplace.

Barrier

According to the Accessible Canada Act the definition “means anything—including anything physical, architectural, technological or attitudinal, anything that is based on information or communications or anything that is the result of a policy or a practice—that hinders the full and equal participation in society of persons with an impairment, including a physical, mental, intellectual, cognitive, learning, communication or sensory impairment or a functional limitation.”

Disability

According to the Accessible Canada Act, the definition “means any impairment, including a physical, mental, intellectual, cognitive, learning, communication or sensory impairment—or a functional limitation—whether permanent, temporary or episodic in nature, or evident or not, that, in interaction with a barrier, hinders a person’s full and equal participation in society.”

ICT (information and Communication Technology)

“An extensional term for information technology (IT) that stresses the role of unified communications and the integration of telecommunications (telephone lines and wireless signals) and computers, as well as necessary enterprise software, middleware, storage and audiovisual, that enable users to access, store, transmit, understand and manipulate information.”

Persons with disabilities

Persons who have a long-term or recurring physical, mental, sensory, psychiatric, or learning impairment and who a) consider themselves to be disadvantaged in employment by reason of that impairment, or b) believe that an employer or potential employer is likely to consider them to be disadvantaged in employment by reason of that impairment.

Persons with disabilities include persons whose functional limitations owing to their impairment have been accommodated in their current job or workplace.

Quasi-judicial

“means ‘court like’. It includes the actions of non-judicial bodies, such as administrative agencies, exercising their functions and powers in a judicial manner. In deciding whether an action or proceeding is ‘quasi-judicial’, a range of factors may be considered. These include whether a proceeding’s purpose is to make a determination or finding concerning a matter, the truth of which is of public concern.”

Web Content Accessibility Guideline (WCAG)

The WCAG documents explain how to make web content more accessible to people with disabilities. Web “content” generally refers to the information in a web page or web application, including:

The Web Content Accessibility Guidelines (WCAG) are part of a series of web accessibility guidelines published by the Web Accessibility Initiative (WAI) of the World Wide Web Consortium (W3C), the main international standards organization for the Internet. They are a set of recommendations for making Web content more accessible, primarily for people with disabilities.

Annex A : Feedback process at the Military Police Complaints Commission of Canada

The MPCC will also review the feedback and assess how the MPCC can improve its accessibility from the feedback received, wherever possible.

Furthermore, all feedback will be retained in our record data management system and referenced in that year’s progress report. We do not identify individuals in our reports.

Annex B: MPCC’s accessibility action plan at a glance

Action

Timeline
(Calendar year)

Employment

Review and determine general training/information sessions, tools, or communication strategy to increase employees’ and managers’ awareness and knowledge on accessibility.

2023

Adopt the GC Workplace Accessibility Passport which is a tool for public service employees and applicants to document and support measures and tools they need to succeed in the workplace.

2023

Review and determine targeted training to employees who are tasked to draft / publish public documents to ensure that these meet the accessibility standards for communication. 

2023-2024 (based on availability of training)

Built Environment

An external subject matter expert will be engaged to provide recommendations to continuously improve office accessibility.

2023

We will use the inclusive design checklist for accessibility considerations (including design, safety, ergonomics, and signage).

2023

Information and Communication Technologies (ICT)

Ensure all content posted to the webpage is compliant to Web Content Accessibility Guidelines (WCAG) requirements.

2023-2024

Review systems, software, and equipment to ensure that they are accessible. Where they are not accessible, the MPCC will develop a plan to remediate the accessibility shortfalls.

Begin in 2023 and complete by 2025

Ensure that accessibility considerations are included in the MPCC ICT plan.

Begin in 2023 and complete by 2025

Communications other than ICT

Develop an internal process and information on providing alternative formats and communicative supports.

2024

Identify and adopt standards for public-facing communications to be in plain language.

2024

Evaluate current public-facing documents for clarity and plain language and provide plain language versions where necessary.

2024

The Procurement of Goods, Services and Facilities

Provide accessibility training as needed to contractors and investigators as needed.

2023

The design and delivery of programs and services

Establish processes to provide complainants, subjects, and other stakeholders with alternate formats of their Final Reports which includes the MPCC Findings and Recommendations when requested.

2024

Conduct additional external survey with our clients to assess the current state of accessibility with respect to the delivery of our programs and services.

2025

When applicable, consult with people with disabilities prior to new policies and procedures to be implemented.

When applicable

Adopt standards for public-facing communications to be in plain language.

2024

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