BSL-107 Adult Learning Wales

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: Addysg Oedolion Cymru | Evidence from: Adult Learning Wales

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. The introduction of legislation in Wales would help ensure that there is consistency in the standard of service delivery for users of BSL in Wales.

In education, Adult Learning Wales has seen firsthand the barriers that BSL users can encounter when trying to gain formal qualifications such as the Level 3 award in education and training (AET). Experience has shown that the rigidity of an assessment system designed around written and spoken English, can hinder the progress of those BSL users who wish to be able to teach a subject through BSL.

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

Adult Learning Wales agrees with the goals that the Bill seeks to achieve. By bringing the barriers that D/deaf people encounter under greater scrutiny, there is a clear opportunity to address any disparity between BSL users and those accessing services through Welsh and English. As a society we have a duty to address these barriers to reduce social isolation, eliminate discrimination, improve job opportunities and deliver equal access to essential services.

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.

Use of the phrase BSL signers would be clearer for describing both deaf and hearing signers and more inclusive. There needs to be a clear distinction between those who rely on BSL as their first language (BSL users) and those without a hearing impairment who have learnt BSL to communicate with and support family members, friends or the wider deaf community.

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.

It would be helpful to have this distinction, as it would make it clearer to show who the Bill is serving in specific situations. It may also make it clearer for those service providers upon whom specific duties may be placed.

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.

Maybe not as much as they should. There will be consultation with those who specialise in the area, but is there any feedback from lived experiences?

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

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

Closed captions, online forums, social media.

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; Workplace.

In Further Education, the availability of frontline staff trained in BSL is challenging. In many cases organisations are dependent on buying-in the services of BSL interpreters and translators. This approach comes at a significant cost and it is currently more lucrative for BSL interpreters to remain self-employed than to be employed by an organisation. There needs to be ongoing government investment to support service providers with training staff to a service level standard.

Barriers for people entering the work place: Length of time it can take for individuals to go through the Access to Workplace; potentially need to look at early access grants or additional funding for organisation to access to ensure support such as a interpreter or translator for a deaf employee is easily accessible and can be put in place from day one.

Marketing to BSL users, funding/training to communicate and make sure we are engaging with the user. There are a limited number of signers available and they come at a cost eg video production.

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

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.

ALW agrees with the proposed remit of the Commissioner.

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

Yes.

The remit described above does not necessarily require post holders to be fluent users/signers, however, we recognise the importance of lived experience when formulating policy etc.

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.

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.

The requirement to produce an annual report would help drive improvements in service delivery. It also provides a benchmark to monitor progress against.

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