May 2025. We responded to the Equality, Human Rights and Civil Justice Committee’s Inquiry into the implementation of this Act.
The Children and Young People’s Commissioner Scotland is a listed authority in the British Sign Language (Scotland) Act 2015. Our submission is based on our experiences preparing Our British Sign Language (BSL) Plan 2024-30[1] and meeting the other duties associated with the Act. We have drawn upon some of the views shared with us by BSL users during this work; we have not conducted any engagement with BSL users specifically on this Inquiry and have not therefore offered responses to the Committee’s questions on BSL users’ experiences of BSL Plans.
Developing our BSL Plan
We worked with Solar Bear[2], Scotland’s Deaf Youth Theatre, both when we were developing our Strategic Plan 2024-2028[3] and to develop our BSL Plan 2024-30. We also engaged with the National Deaf Children’s Society (NDCS) and with the British Deaf Association (BDA). Their views informed our initial draft, and we then asked young BSL users for feedback and redrafted our Plan accordingly.
The views of children and young people are important to us; we have a statutory obligation to include their views in our work.[4] We have dedicated participation staff and our whole team are experienced in working directly with children and young people. As an organisation that prioritises participation skills, this gives us an advantage in terms of capacity to review and develop our BSL Plan.
Consulting BSL users
We are aware that all listed authorities will have developed their BSL Plans to similar timescales and that all authorities delivering high quality participation could result in a significant consultation burden on a relatively small group of BSL users. Many listed authorities will be asking similar questions and we would suggest that some co-ordination around general issues affecting all public authorities would free capacity – both within the BSL community (and those who support them) and in public authorities, to consult on specific issues or improvements.
Challenges for small listed authorities
We note that good quality participation work with BSL users presents significant challenges that may result in barriers for smaller listed authorities. The financial cost of good quality participation with BSL users can be significant due to the cost of interpreting. Working with interpreters requires careful planning and additional time and there can be issues with availability of interpreters.
Developing BSL resources presents unique challenges, compared to translations of written resources. We have committed to extending the range of resources we have available in BSL; as with other small organisations, there will always need to be prioritisation.
Our preference has been to engage young BSL users as presenters for our resources – but this means that we need both a presenter and an interpreter and the process takes significantly more time than producing written translations. We suspect that other listed authorities will have less experience of this type of work, and may find the process particularly challenging.
Issues raised by young BSL users
We spoke with children and young people from Solar Bear as part of the participation work which informed our Strategic Plan 2024-28. They told us a lot about their experiences in school.
They often felt that their choice of communication (i.e. BSL) was not supported by staff in schools. They experienced inappropriate behaviour from staff, including being grabbed to get their attention. Some teachers became frustrated if they were asked to repeat themselves. Their choice of subjects was sometimes limited because of the extent of support they needed – for example not being allowed to study a foreign language. They thought that better Deaf awareness in schools would help address teachers’ understanding of their needs and help reduce the bullying some of them experience.
Ongoing work
As part of our ongoing work on education, we’re working with a school for Deaf children as part of our ongoing work on children’s experiences of education.
We are providing lessons in BSL to participation, communications and corporate services staff to strengthen the office’s ability to work with young BSL users. All staff have received BSL awareness training.
[1] CYPCS, 2024. Our British Sign Language (BSL) Plan 2024-30. https://www.cypcs.org.uk/news-and-stories/our-bsl-plan-is-launched-today-to-protect-and-promote-the-rights-of-young-bsl-users/
[2] Solar Bear. https://solarbear.org.uk/
[3] CYPCS, 2024/ Our Plan 2024-2028https://www.cypcs.org.uk/resources/our-plan-2024-28/
[4] Commissioner for Children and Young People (Scotland) Act 2003 section 6.