BSL-06 Velindre University NHS Trust

Senedd Cymru | Welsh Parliament

Bil Aelod Arfaethedig – Mark Isherwood AS | Proposed Member Bill - Mark Isherwood MS

Datblygu'r Bil Iaith Arwyddion Prydain (BSL) (Cymru) | Development of the British Sign Language (BSL) (Wales) Bill

Ymateb gan: Ymddiriedolaeth GIG Prifysgol Felindre | Evidence from: Velindre University NHS Trust

The need for legislation

The British Sign Language Act 2022 requires the UK Government to issue guidance about the promotion and facilitation of the use of British Sign Language (BSL). This however only applies in England and not to the Welsh Government or public bodies in Wales such as councils or the NHS.  The British Sign Language (BSL) (Wales) Bill aims to place equivalent specific duties on the Welsh Government and public bodies in Wales.

Question 1: Do you think there is a need for this legislation? Please provide reasons for your answer.

 

Yes. 

 

Access to health services and employment opportunities is difficult for deaf people and BSL users.

Question 2: Do you agree or disagree with the goals that the Bill seeks to achieve? Please provide reasons for your answer.

 

Agree. 

 

Legislation shapes organisational outcomes.  If implemented with proportionality, this will develop better services and life opportunities for deaf people.

British Sign Language

Question 3: Do you agree that the Bill should include proposals to promote and facilitate the use of BSL and its tactile forms?

Yes

Question 4: Do you agree that the Bill should support the various Welsh regional dialects of BSL?

 

Yes

Question 5: Do you think that the term ‘BSL users’ should be replaced with ‘BSL signers’, recognising that BSL is a language which includes both deaf and hearing signers? Please provide reasons for your answer.

 

Yes.

 

This is a more positive description of people.

Question 6: Do you think that the term ‘deaf BSL signers’ can be used when referring to BSL users/signers who are medically or audiologically deaf?  Please provide reasons for your answer.

 

Yes

Deaf Communities

Question 7: Do you agree or disagree that deaf communities:

a)     currently have a voice in the design and delivery of the public services that they use? Please tick the answer that most applies and provide any comments.

 

Neither agree or disagree.

 

Current shortage of people with lived experience in influential roles.

b)    should have a formalised voice in the design and delivery of the public services that they use, especially ones targeted at deaf people. Please tick the answer that most applies and provide any comments.

 

Strongly agree.

 

It is essential to have insight from people who are deaf and the Deaf community in designing services.

Question 8: Are there any specific communication methods used by deaf people that you would like the Bill to reference/include?

 

Barriers that exist for deaf people

Question 9: What do you believe are the main barriers that currently exist for deaf people and/or their families in the following areas. Please tick all that apply and provide information/examples on each area:

 

Education; Health; Social Care; Transport; Other Public Services used by deaf people and their families; Workplace.

 

Barriers exist for deaf people in all these areas.  Velindre University NHS Trust is a provider of health services and an employer and therefore is most affected in Health and Workplace.  In terms of access Health services, it can be difficult for deaf people to ask questions about their care and treatment when the system relies on phone calls and if the patient needs to have an interpreter with them during a consultation and treatment.  In terms of the workplace, some systems are not fully suited to deaf people, for example some training packages.  Access to interpreters is difficult as there are not enough qualified interpreters available for comprehensive support.  Many external conference providers do not provide BSL signing as a routine element of organising their event and the onus is put on the deaf person to try and organise it, which will be in addition to any conversational support they require in order to attend.

Establishing a BSL Commissioner for Wales

The Bill proposes to establish a BSL Commissioner who would promote and facilitate the use of BSL, and would have the same powers as other minority language Commissioners such as in the Welsh Language (Wales) Measure 2011.

Question 10: Do you agree or disagree with the proposal to establish a BSL Commissioner for Wales, and, do you have any different suggestions or alternatives? Please provide reasons for your answer.

 

Yes.

 

The proposal to establish a BSL Commissioner would support the NHS in achieving equality of health outcomes.  The Commissioner must be a fluent BSL signer who is able to communicate with deaf people in BSL and understand the implications of being deaf.  However, the requirements must be applied with proportionality taking into account the current resources of BSL skills within the workforce and the wider community.  There is a large piece of work in re-designing services to include BSL as standard which will take time.  There are many interdependencies between services and organisations which need support from a central point – potentially a Commissioner’s office – if this is to succeed.

Question 11: The proposed remit of the Commissioner would be to:

§    formulate BSL standards;

§    establish a BSL Advisory Panel;

§    produce reports every 5 years in BSL, Welsh and English on the position of BSL in that period;

§    provide guidance and a process for public bodies to promote and facilitate BSL in their respective domains;

§    establish a procedure for the investigation of complaints.

Do you agree with the proposed remit of the Commissioner, and are there any other provisions you would like to include in the Commissioner’s remit? Please provide reasons for your answer.

 

Yes.

 

The Advisory Panel must include deaf people and others who are fluent BSL signers.

Question 12: Do you agree that the BSL Commissioner and the BSL Advisory Panel members should be fluent users/signers?

 

Yes

 

Question 13: Do you think that the proposed BSL Commissioner and Advisory Panel should prioritise the following. Please tick all that apply and provide reasons for your answer.

 

§  Enabling deaf users/signers to lead the development of policies and implementation of services for BSL users/signers;

§  Early years language support for deaf children and their families;

§  Improving BSL provision in education;

§  Access to interpreters in public services.

1 and 4 are the most relevant to our service.   We are already struggling to access sufficient interpreters within the employment field which impacts on the quality of communication and participation in conferences and external meetings.   A focus on early years and education is fundamental in:

1.  Affording deaf children equal access to education; and

2. Creating the skills Wales needs for creating accessible health services in the future.

Question 14: Do you agree or disagree with the proposal to place a duty on the Welsh Government to prepare and publish an annual BSL report? Please provide reasons for your answer.

 

Yes

Question 15: Are there any other issues that you would like to raise about the Bill and the accompanying Explanatory Memorandum?

 

Velindre University NHS is supportive of this Bill. However, Trust is not yet able to fully meet all the provisions of the Bill.  Therefore, we would request that:

 

1.     The regulations are applied with proportionality with consideration of relative impact of changes.  The stringency of application should be increased over time as the Trust’s capabilities develop.

 

2.    There is recognition of the issues that lie outside the Trust’s control and support will be given for those areas to be improved, for example developing BSL skills across the wider community and the growth of the interpreter workforce.