Skip to main content
Appendices /

Appendix C: Dreams Delayed Calls to Action

Printer-friendly version

Appendix C: Dreams Delayed Calls to Action
Monitoring and Evaluation

 

Action 15 – The Ministry of Citizenship and Multiculturalism Must Amend the Anti-Racism Act Regulation 267/18 and Data Standard – Immediate (1–2 years)

The OHRC calls on the Minister of Citizenship and Multiculturalism (MCM) immediately to review and amend the Anti-Racism Act (ARA) regulation 267/18 to designate the Ministry of Education as the primary authority for education data collection, instead of individual school boards. While the ARA and the Human Rights Code establish the legislative authority for data collection, the Minister should implement enhanced guidelines that go beyond the minimum standards. This should include establishing and mandating the use of a comprehensive template to collect and report race-based data, and enforcement mechanisms for non-compliance.

The Ministry must:

  1. Amend the ARA to mandate school boards to collect and disaggregate data on student demographics based on Code grounds and non-Code grounds, to measure academic achievement, EQAO results, suspensions, expulsions, exclusions, graduation rates.
  2. Amend the ARA to mandate school boards to collect, disaggregate, analyze, and publicly report data on their workforce representation and tenure, particularly on educators, to support diversity within their board. This includes a schedule for data collection, analysis, and reporting, and ensuring that disaggregated data is published on Open Data.
  3. Amend the ARA and Regulation 267/18 to include a compliance framework for collecting data and reporting timelines to guide the Ministry of Education and school boards and to designate the Ministry of Education as the authority for data collection in publicly funded education.
  4. Create resources for school boards on stakeholder partnerships for the data collection, analysis, action planning and monitoring processes.
  5. Collaborate with Statistics Canada to align data collection standards with current socio-demographic data collection practices.
 
Action 16 – The Ministry of Education Must Centralize and Standardize Data Collection, Analysis, and Reporting – Immediate (1–2 years)

The OHRC calls on the Ministry of Education to mandate a centralized and standardized process for all school boards to collect and publicly report demographic and Code-based data. This includes establishing and mandating the use of a comprehensive template to collect and report race-based data.

Monitoring, reporting, and preventing discrimination in the education systems are important accountability measures. Data collection and climate surveys using disaggregated data are effective tools to do so and should include information on who experiences discrimination by racialized group and their intersecting grounds of discrimination. They should also outline the nature of incidents and where they happen.

The Ministry of Education must:

  1. Review EQAO to include race-based data collection.
  2. Identify the essential disaggregated data that all school boards must collect on an annual basis, in addition to other relevant data specific to school boards, to show outcomes for Black students.
  3. Develop a robust monitoring framework to ensure school boards collect and use Code-based data to address the impact of racial disparities on the mental health of students.
  4. Equip school boards with expert resources to monitor consistency in the collection, quality, and analysis of their data.
  5. Work with the OCT to collect and publicly report data on the racial composition of the education professional body.
  6. Require school boards to record and publicly report on an annual basis the number of Black educators, staff, and students, and incidents of anti-Black racism in their board.
  7. Require school boards to use year-over-year data to identify and address patterns of anti-Black racism in their board, in collaboration with Black community organizations and families.
  8. Develop a framework that provides school boards with guidance to collect, analyze and report findings from biannual employee surveys. Data collected from these surveys may include, but is not limited to, employees’ day-to-day experiences, engagement, work environment, and applicable Code-based data. [13] 
  9. Require school boards to publicly release de-identified disaggregated data from the biannual employee survey that assesses their employment practices. This report should highlight important perspectives including, but not limited to, representation from historically marginalized groups, treatment in hiring, training experiences, and promotion. [14]
 
Action 17 – The Ministry of Education Must Publish Disaggregated Data on Ontario Data Catalogue – Immediate (1–2 years)

The OHRC calls on the Ministry of Education to publicly release all de-identified disaggregated data on Ontario Data Catalogue to allow access to the public, communities, and researchers.

 
Action 18 – The Ministry of Education Must Establish and Implement a Monitoring Framework – Immediate (1–2 years)

The OHRC calls on the Ministry of Education to establish a comprehensive provincial monitoring framework to ensure school boards effectively address disparities amongst students in educational outcomes. The framework should include, but not be limited to, benchmark data, qualitative and quantitative outcomes, and performance and compliance indicators.

The Ministry of Education must:

  1. Develop and implement an outcomes monitoring framework with indicators measuring progress and achievement on anti-discrimination.
  2. Require school boards to report annually on outcomes, disaggregated according to Code grounds, including:
     
    1. Educational achievement;
    2. Student well-being;
    3. Literacy, numeracy and graduation rates;
    4. Discipline, suspension, expulsion, and exclusion rates;
    5. Number of human rights-related complaints.
  3. Identify disparities, create approaches to address them and identify remedial measures for lack of compliance.
  4. Provide preventive support, including, but not limited to, Action 13, 24, 25 to school boards to assist them in meeting their obligations, including policy development and regular audits.
  5. Develop mechanisms to monitor and evaluate school boards’ initiatives and programs to hold school boards accountable.
 
Action 19 – The Ministry of Education Must Establish a Cross-Ministry Data and Monitoring Working Group – Immediate (1–2 years)

The OHRC calls on the Ministry of Education to establish a working group, in collaboration with the OHRC, the Anti-Racism Directorate, and other relevant community stakeholders, to review and update the outstanding recommendations from the Ministry of Education’s 2017 report Unlocking Student Potential Through Data.

The working group should develop a comprehensive plan to expand and enhance data governance, collection, analysis, and reporting within the public education system, and focus on implementing outstanding recommendations relating to data.

The working group must: 

  1. Develop a comprehensive plan based on  Unlocking Student Potential Through Data and implement the outstanding recommendations from the report. The plan should outline objectives, timelines, and deliverables for expanding and enhancing data governance, collection, analysis, and reporting within Ontario’s public education system.
  2. Develop a robust human rights monitoring framework to track progress on implementing recommendations.
  3. Evaluate and strengthen existing data governance frameworks within the public education system to ensure compliance with privacy laws and ethical guidelines.
  4. With guidance from the Information and Privacy Commission of Ontario, implement protocols for secure data storage, access, and sharing among relevant stakeholders.
  5. Conduct a thorough assessment of current data collection practices across all school boards to identify and address gaps and strengths and develop adaptable and consistent criteria for data collection for rollout across systems.
  6. Work with researchers, subject experts, and communities to develop strategies to identify and address discrimination or disproportionality among Code-protected individuals in the education system.
  7. Ensure an intersectional analysis is incorporated into existing and new data related recommendations to understand how vulnerable students are affected.
  8. Collaborate with Statistics Canada and relevant institutions to map, retrieve, maintain, and, to the extent permitted by law, share reliable, disaggregated data on Black representation over defined periods of time.
  9. Engage with diverse stakeholders including Black educators, students, parents/guardians, community organizations, and advocacy groups to seek input through consultations to ensure that the plan and indicator framework are inclusive, culturally sensitive, and responsive to community needs.
  10. Establish mechanisms for continuous monitoring and evaluation by the Ministry of Education and MCM on data-related initiatives and human rights indicators, as well as compliance management and operationalisation of oversight.
  11. Publicly publish a report on the results.
 
Action 20 – Unions Must Establish and Implement a Monitoring Framework – Immediate (1–2 years)

The OHRC calls on unions to monitor and evaluate all initiatives relating to their accountability framework guided by benchmark data, qualitative and quantitative outcomes, and performance and compliance indicators.

 
Action 21 – Faculties of Education Must Establish and Implement a Monitoring Framework – Immediate (1–2 years)

The OHRC calls on Faculties of Education in Ontario, in partnership with their post-secondary institution and associated human rights offices, to establish a monitoring framework that includes audit, reporting, and evaluation to measure the impact of initiatives and programs implemented by the faculties.

 
Action 22 – Education Duty-Holders Must Review and Update Complaints Procedures and Processes – Immediate (1–2 years)

The OHRC calls on all educational organizations, including school boards and unions, to review and update complaints procedures to receive, investigate, and resolve complaints of discrimination and harassment.

The complaints procedures should establish an anti-racism protocol for recognizing, acknowledging, tracking, measuring, investigating, and responding to incidents of discrimination, harassment, and poisoned environment reported by students, educators, staff, parents, or the school community. These mechanisms should also provide programs, interventions, and other supports for students and educators targeted by racism, witnesses of racism, and individuals who have engaged in racist behaviors, delivered by trained professionals such as social workers and psychologists. There should also be an effective internal complaint resolution process guided by the OHRC’s Policy and Guidelines on Racism and Racial Discrimination.[15]

Education organizations must implement robust data collection on complaints to monitor and address systemic issues and share data about discrimination and harassment complaints with unions. Key considerations should include:

  1. The number of human rights complaints received, disaggregated by Code grounds.
  2. Whether the complaint was from a student, educator, education worker, or other staff.
  3. The name of the school in the complaint.
  4. The number of internal investigations relating to human rights, disaggregated based on Code grounds.
  5. The number of applications filed with the Human Rights Tribunal of Ontario.

The Ministry of Education must:

  1. Mandate school boards to co-develop a school-based human rights complaints policy, procedure, and process with parents/guardians, caregivers, and members of the broader school community. This includes procedures for addressing issues with school policies or potential discriminatory suspensions, expulsions, and exclusions of children, detailing all recourse. The complaints procedure must consider the existing institutional barriers which impact victims of discrimination. Comprehensive data and reporting requirements should be publicly available.
  2. Mandate school boards to inform parents/guardians and caregivers about school human rights complaints policy, procedure, and process. This includes procedures to address issues with school policies and discriminatory use of discipline practices, including but not limited to, suspensions, expulsions, and exclusions. School boards must also inform parents/guardians and caregivers about their right to file an application with the Human Rights Tribunal of Ontario or a complaint with the Ontario College of Teachers.
 
Action 23 – Education Duty-Holders Must Develop an Early Intervention System for Racial Discrimination and Harassment – Intermediate (3–5 years)

The OHRC calls on the Ministry of Education to work with school boards to develop and implement an Early Intervention System (EIS) to track and address potential racial discrimination and harassment complaints reported within the board or schools.

Early intervention systems, also known as early warning systems, can help school boards to quickly identify and prevent potential human rights issues before they happen. This can be done through the collection and analysis of race-based data and identification of patterns of behaviour to alert supervisors of potential issues that must be addressed.

The EIS would help school boards to proactively address racial and other Code-based discrimination and harassment to ensure safe learning and working environments for all students and educators.

The Ministry of Education in partnership with the relevant education partners must: 

  1. Develop and implement an EIS for school boards to prevent racial and other Code-based discrimination and harassment by administrators, educators, or education workers.
  2. Ensure the EIS aligns with leading practices for data collection, privacy protection, and fairness in monitoring potential misconduct.
  3. Integrate Code-based data into the EIS to effectively monitor and analyze incidents of discrimination and harassment.
  4. Develop procedures to capture and assess data on behaviors or incidents of anti-Black discrimination and harassment.
  5. Engage with the community, including Black students, families, and advocacy groups for input into the procedures and to receive feedback on the effectiveness of the EIS.
  6. Use data to publicly report on the effectiveness of school boards preventing racial discrimination and harassment using EIS.

School boards must:

  1. Use the EIS to promptly identify patterns of behavior or incidents that may indicate racial discrimination or harassment.