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3. Developing organizational policies, programs and procedures

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A complete strategy to prevent and address human rights issues should include:

  1. A plan for preventing, reviewing and removing barriers
  2. Anti-harassment and anti-discrimination policies
  3. An internal complaints procedure
  4. An accommodation policy and procedure
  5. An education and training program.

An effective strategy will combine all of these elements. For example, while it is an essential part of any human rights strategy, an education and training program on its own will not remove underlying systemic barriers. On the other hand, without education and training, it will be difficult to ensure organizational support for, and compliance with, human rights policies, programs and procedures.

No strategy will be effective without strong, visible and ongoing commitment from the senior levels of the organization.

It is helpful when designing any human rights plan, policy or procedure, to get input from all parts of the organization. For example, input from employees will be invaluable in developing and implementing workplace anti-harassment and anti-discrimination policies, plans or procedures. In a unionized workplace, the union should be a key partner in developing and implementing any human rights strategies. Housing providers may wish to consult tenants, and service providers to seek the views of their clients.

In some cases it would also be wise, where feasible, to seek advice or input from community organizations representing certain groups such as racialized persons, women, people with disabilities, etc. For example, public service organizations that are dealing with complex or systemic barriers may wish to consult with the community when identifying strategies and best practices. This step will help identify issues and effective solutions, and will also increase buy-in and commitment to the policy, plan or procedure.

Policies, plans and procedures must consider the size, complexity, and culture of an organization.[9]For example, the complaints procedure for a small organization will probably be simpler than that for a large, multi-site, unionized organization.

Sound communication strategies are essential to the success of any human rights plan, policy or procedure. Employees, tenants or customers must clearly understand the content of the strategy and their rights and responsibilities, why the strategy was developed and how it will be implemented. Information should be readily accessible and easy to understand.

Identify and address issues or factors that may cause opposition or resistance to the strategy. It is important to regularly remind existing employees, tenants and clients about organizational human rights policies and procedures, as well as to ensure that individuals who are new to the organization receive orientation and training.

All policies, plans and procedures require regular review and revision to make sure they:

  • Reflect the current state of human rights law and policy
  • Take into account changes in organizational structures or resources
  • Address new human rights issues emerging within the organization
  • Continue to be effective.

Organizations may want to seek assistance from lawyers or other experts in developing policies, procedures or education programs that will effectively meet their needs. The more complex the organization or the human rights issues, the more likely it will be advisable to seek specialized assistance.

[9] Wedley v. Northview Co-operative Homes Inc., 2008 HRTO 13 (CanLII)

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