Strategic Initiatives

6. Analysis and Conclusions

The average Canadian takes it for granted that he or she can look up the number of federal department or agency in the blue pages of the telephone directory or on the Internet, make a phone call to that organization, and get the information sought within a reasonable period. The results of this study show that is not the case for Canadians who, as a result of a disability, cannot use the regular telephone system. For them, there is only a fifty-fifty chance that they will find a TTY number listed. And when a TTY is listed, there is only a one-in-three chance that they will be able to complete a call successfully. The results of this review confirm previous test results.

This inadequate level of service persists despite the fact the Government of Canada has publicly committed itself to providing, and is legally required to provide, equality of service for all.

• Results for Canadians: A Management Framework for the Government of Canada commits the Government of Canada to achieving a significant, quantifiable improvement in client service satisfaction.

• The Communications Policy of the Government of Canada commits all federal departments and agencies to providing communications services in an equitable and accessible manner, taking into account the differing needs of the Canadian public.

• The Canadian Human Rights Act and the Canadian Charter of Rights and Freedoms prohibit discrimination based on disability and require accommodation of special needs short of undue hardship.

During this study, some federal organizations indicated that demand for TTY service was low. This is an interesting observation, but it is not a justification for not providing equitable service access. Advocacy groups indicated that TTY users have become so frustrated with trying to make TTY calls that they have simply given up. Instead, they ask the advocacy groups, or a hearing friend or family member, to make calls for them.

Even if true demand was low, and there is no proof of this, that would not be justification for providing inadequate services. The law and jurisprudence on this issue are clear: the number of people requiring accommodation does not determine whether accommodation should be provided. Only undue hardship is recognized as a justification for not accommodating a legitimate need. As noted earlier, the marginal cost of ensuring adequate communication with people who cannot use the regular telephone system is small and unlikely to pose undue hardship to any federal organization.

Based on this study, there appear to be two main reasons for the current situation.

• Lack of adequate policies, procedures and guidelines to ensure that the right to equitable access is met: As noted previously, the Charter, the Canadian Human Rights Act and TBS policies all include requirements for equitable access to government programs and services. However, there are no clear laws, policies or guidelines governing the provision of communications services specifically to people who cannot use the regular telephone network. In the absence of such rules, federal organizations do not know what is expected of them and citizens do not know what they can expect of the government. There is a lack of accountability. As a result, citizens have little or no recourse when they fail to receive adequate service.

• Failure to properly manage communications services for those who cannot use the regular telephone system: In the study, among the 64 organizations that listed a TTY number, only 30% had lines that actually worked when a test call was made. This is obviously an unacceptable service level that would certainly not be tolerated in any other aspect of a federal organization’s operations. The study indicates that operators are inadequately trained in the use of TTY, that they sometimes do not know the common protocols of TTY communication, and that little or no effort is made to ensure service quality. Despite the fact that many new technologies exist that could facilitate or complement TTY communication, little progress has been made in introducing these new technologies.

In summary, the problem of inadequate availability and accessibility of services for people who are Deaf, deafened or hard of hearing, or have a speech impediment, still exists. Since there is no standardized framework of guidelines or best practices, each institution uses its own approach, which creates inconsistency and confusion.

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