7. Best practices for police human rights organizational change

Police organizations across Ontario have responded to the changing needs of an increasingly diverse population for many years. These efforts have included training projects and, in some places, efforts to recruit members of underrepresented groups.

The TPS experience
The Toronto Police Service has recently undertaken the most comprehensive police effort in Ontario to respond to a wide variety of human rights concerns. This involved forming a partnership between the Toronto Police Services Board (TPSB), the Toronto Police Service (TPS) and the Ontario Human Rights Commission (OHRC) that ran from 2007 to 2010. A copy of the TPS/OHRC/TPSB Human Rights Project Charter is available on the OHRC website at www.ohrc.on.ca.

This innovative three-year partnership, the Human Rights Project Charter, aimed to identify and eliminate any discrimination that may exist in the employment and service policies of the Toronto Police Services Board and the practices of the Toronto Police Service. It was a systematic effort to address human rights concerns in the largest police service in Ontario.

This section shares lessons for human rights organizational change from the experience of the Toronto Police Services Human Rights Project. We recognize that the reality of a large urban police service like Toronto’s is not the same as that of smaller urban and rural police services in the rest of the province, nor of the province-wide services of the Ontario Provincial Police. We have made an effort to provide guidance more appropriate to the range of police services in the province.

7.1 Comprehensive organizational change strategy

Many police organizations have had experiences with comprehensive organizational change. They have used these strategies to address a variety of issues. However, such strategies have not been extensively used to address human rights matters. Human rights organizational change efforts, where these do exist, have often taken the shape of a formal time-limited project and/or training session for staff. However, this kind of change should not be limited to a single project or training session, because such efforts provide only temporary fixes.

Human rights organizational change aims to prevent human rights violations and address concerns and issues as they arise, recognizing that human rights issues are many, complex, ongoing and constantly evolving. Such change must include efforts to establish permanent systems and processes to respond to human rights issues as they emerge. The main point of this guide is to showcase the value of such comprehensive and ongoing strategies for addressing human rights issues.

Comprehensive organizational change aims for lasting impact by fostering, developing and cementing change to organizational structures, policies, procedures, practices and culture, in a coordinated way. Human rights organizational change is a comprehensive and enduring process seeking to consciously shape all aspects of how organizations conduct their business in a coordinated and systematic way. These aspects include organizational structures such as departmental divisions, formal policies, procedures, practices, and organizational culture, infrastructure (technological and physical) and governance.

Organizational culture refers to informal norms and values that influence organizational activity and the experience of individuals both inside and outside the organization. An organization may have dominant and competing subcultures. This manual suggests some of the key ”structural” and ”process”-related elements needed to help change cultural norms, values and identifications. It also emphasizes the importance of effective leadership and communication. Addressing ”culture” head on, without having supporting structures in place, can lead to backlash and resistance because of the key role of culture in shaping peoples’ personal lives and identities.

Comprehensive and coordinated organizational change efforts apply equally to both small organizations and large ones. When a comprehensive change strategy is used, small and large police organizations can benefit from any attempt to create an organization that can vigilantly address human rights.

The TPS experience
“The Toronto Police Service Human Rights Project targeted numerous organizational areas and functions, including recruitment, selection and promotion, staff training, public education, and performance management and accountability (See the TPS/TPSB/OHRC Human Rights Project Charter posted on the OHRC website for further details on the range of initiatives undertaken by the TPS in these areas at www.ohrc.on.ca).

The Toronto Police Service Human Rights Project was conceived as a three-year partnership, but it was never seen as a stand-alone project with no follow-up. A permanent Diversity Management Unit had already been established to address equity and diversity issues before the project was developed. The project aimed to jump-start the work of this unit and reinforce it with a broader human rights frame of reference. This unit was a natural place to maintain post-project human rights organizational change structures and processes.

Many project interventions required more than three years to fully put in place. To deal with this and to oversee evaluation of the overall project, a human rights advisory committee involving members from all three partnering organizations was established to meet quarterly for three years after the formal end of the project in May 2010.

Smaller police services with more limited resources may not be able to establish similar permanent units to maintain human rights systems. Having at least one full-time dedicated specialized staff person address human rights issues in the workplace is strongly recommended. However, smaller police services may also build capacity by partnering with larger police services and/or academic and community organizations that can provide advisory services and support. Each police service will need to identify an effective solution that meets its own needs and resources.

7.1.1 Best practices for comprehensive organizational change strategy development

Elements of a comprehensive human rights organizational change strategy may include:

  • organizational strategy, vision, mission and value statements
  • organizational policies, practices and procedures governing employment systems (including complaint and accommodation processes), programs and services, procurement, physical infrastructure and technology
  • organizational governance, leadership and stakeholder relations
  • performance management, monitoring and evaluation
  • professional development and training
  • communication and reporting
  • a clear directive or policy that provides a formal mandate and context for the work of human rights organizational change.

7.1.2 Things to avoid in comprehensive organizational change strategy development

  • Don’t treat human rights organizational change as solely a matter for Human Resources. The entire organization needs to review how its business is conducted.

Do not view human rights organizational change as a time-limited training project. Systemic change requires ongoing assessment of structures and processes.

The London Police Service is committed to maintaining a non-discriminatory workplace, both as a provider of policing services to the public and as an employer. As an organization, we support the principles of equity and fairness embodied in the Human Rights Code. Human rights and policing: creating and sustaining organizational change is an important tool for police services to assist in bringing about organizational change to reflect the rights and obligations embodied in the Ontario Human Rights Code.

– Bradley S. Duncan, M.O.M., Chief of Police, London Police Service

7.2 Committed leaders

Policing in Ontario has a shared leadership structure. Police boards are publicly appointed civilian bodies that oversee police budgets and provide policy-level oversight to police services. Police chiefs head police bureaucracies that include officers and civilian staff. Because police are paramilitary organizations, police chiefs retain more power and influence than presidents and/or chief executive officers do in other bureaucracies. The support of police chiefs is critical to any change effort within police organizations. However, even a police chief can not hope to fully succeed without a supportive police board.

The TPS experience
In the Toronto Police Human Rights Project, both the Police Services Board and the Police Service signed on to a Charter agreement along with the OHRC. The Board Chair, the Police Chief and the Chief Commissioner of the OHRC signed this Charter as “sponsors” and widely publicized their commitment to it. Both the Board Chair and the Police Chief spoke at various events throughout the three-year project, to stress the importance of the project and its human rights goals.

The Charter also called for the sponsors to meet regularly to oversee the human rights organizational change effort. The commitment of these most senior organizational leaders and the direct involvement of other senior board and service staff in the project were instrumental in showing a united purpose and commitment.

A unified, committed and involved leadership is essential for change efforts in general, but particularly so in hierarchical paramilitary organizations like police. For change to happen, leaders must confidently communicate that:

  • change is needed
  • they are committed to it
  • they will commit resources to it
  • they will, themselves, be involved in assessing and guiding the effort.

Leaders can show their commitment by incorporating human rights goals and considerations into core business areas.

Top leadership support is not enough for change. Even in hierarchical organizations, there are different centres of power and potential resistance can prove overwhelming. Top-down orders to change rarely succeed without effectively managing stakeholder interests, and recognizing and planning for resistance (for more specific best practices, see sections on “Identifying and addressing resistance” and “Multi-stakeholder structure and process for change”).

7.2.1 Best practices for leadership

  • Police service boards and police chiefs share commitment, ownership and ultimate accountability for human rights organizational change, and as co-sponsors make a public and official statement of this shared commitment
  • Involve police board members and the police chief directly in overseeing change efforts, possibly through regular “sponsors” meetings
  • Consistently and visibly reinforce shared commitment through personal statements of support by organizational leaders at key events during the change effort
  • Consult with human rights experts and key stakeholders in direction-setting activities.

7.2.2 Things to avoid for leadership

  • Do not show discord among leadership about the vision, goal and value of human rights organizational change. Inconsistent or weak support among the leaders allows resistance to any change
  • Do not have varying levels of operational commitment to this change or else change will happen inconsistently.
  • Don’t say you will do something but fail to follow through as this can jeopardize public/staff “buy-in” (see Communication section).

7.3 Vision and terminology for change

Any change effort requires leaders to clearly state a vision of where they want the organization to go and why. Vision is often stated in terms of values. Only when a vision is firmly established in the organization’s structures and culture will change firmly hold. Human rights represent a lofty vision consisting of persuasive and inspiring values – and also of legal obligations. Focusing on human rights to deal with challenges of diversity and concerns about equity and fairness in policing is a natural “vision” fit.

However, exactly what “human rights” means, and exactly how it relates to other key concepts can be vague and unclear. Lack of clarity in vision and key concepts is often a source of confusion in change efforts. Spend time clarifying and articulating the vision and concepts that will enliven the organizational change effort, initially to the people involved in the effort and then, by extension, to all members of the organization and its stakeholders.

The TPS experience
The Toronto Police Human Rights Project emerged while the Toronto Police Service (TPS) was dealing with several community concerns and formal human rights complaints. These concerns included racial profiling and discrimination and harassment on the basis of race, disability and sexual orientation. Efforts to frame and respond to these concerns used a variety of related concepts, such as ethno-cultural diversity, anti-racism, equity and inclusion. With the involvement of the OHRC, the Board and the TPS began to see such issues through a human rights lens.

During early project meetings, participants, many of whom had little to no background in human rights matters, used many different terms to talk about human rights, often vaguely and with varied understanding. The group developed a shared conceptual framework to clarify concepts and terms and how they related to each other. This framework provided definitions for the key terms of “human rights,” “equity,” “anti-racism,” “diversity,” “inclusion” and “cultural competence,” and provided a chart that related these terms in a meaningful way. Project leaders also developed a glossary of key terms. Project participants received training on both the conceptual framework and the glossary.

7.3.1 Best practices for developing vision and terminology

Use legally grounded human rights values and law to frame the vision

  • Develop and train lead change agents and staff on a shared conceptual framework and glossary of key terms (see Glossary in Appendix as starting point)
  • Consult with human rights experts about definition and scope of various terms and frameworks.

7.3.2 Things to avoid when developing vision and terminology

  • Do not proceed in an ad hoc way without any guiding vision or conceptual framework. Successful organizational change requires clear and consistent language and vision of where the organization wants to go and why
  • Do not use terms and frameworks interchangeably (e.g. diversity, equity, anti-racism, inclusion, human rights) without clearly defining them or building a common understanding of the different nuances of such terms among project partners and leaders. Lack of clarity in vision and key concepts can cause confusion and conflict in change efforts.

7.4 Lead change agents

(a) Role
Formal change efforts need lead change agents to plan and oversee change activity. Lead change agents may perform many of the major tasks involved in change efforts, but their main role is to plan and manage the overall change effort. In any situation, effective lead change agents must have or get the expertise to lead and guide the work. Such expertise includes intimate knowledge of the target organization’s structures and culture, knowledge of organizational change approaches, and a strong understanding of the type of change you are aiming for. Also, lead change agents must be positioned to have sufficient influence and access to resources. Effective lead change agents usually have direct access to top organizational leaders.

(b) Where to find lead change agents
Lead change agents are usually employees, but can be external consultants. In a smaller organization, a lead change agent can be a single staff member with other responsibilities. In larger organizations, a multi-staff working group or a dedicated unit is often possible – and needed.

Officer staff do the core of police work, and play the major role in leading and guiding these organizations. For a change effort to have full acceptance with the entire organization, officer staff must be seen to be a primary component of lead change agents. This can be particularly challenging for police officers in terms of human rights and exposure to specialized human rights knowledge. In larger police forces, successful human rights organizational change requires hiring dedicated personnel and setting up specialized unit(s) with such specialized knowledge to guide and support the change.

The TPS experience
In the Toronto Police Human Rights Project, lead change agents were already established in the Diversity Management Unit, which reported to a Deputy Chief. The unit was headed by a civilian staff person with expertise in policing organizations, organizational change, and human rights and equity work. A dedicated equity advisor was hired to advise the Chief of Police.

When the formal organizational change project began in 2007, a senior staff superintendent was designated to lead the project and a small executive group was developed, consisting of the staff superintendent, the Manager of the Diversity Management Unit, and representatives from the OHRC and the Toronto Police Services Board. This executive group established a group of lead change agents that was essentially co-led by officer staff and civilian staff that was empowered and had significant expertise. The executive group’s task was to guide and supervise the organizational change efforts and report to the project sponsors.

Smaller police services may not be able to dedicate a full unit to act as lead change agents and employ specialized expert staff. Some smaller police services have positioned motivated officer staff to become lead change agents with direct reporting responsibility to top police leadership. These officers must receive adequate and appropriate training to be effective in this role.

(c) Choosing and supporting lead change agents
Staff selected as lead change agents often come from equity-seeking groups, because of their social experiences, identified concerns, and generally stronger awareness of human rights aims. However, individuals with such backgrounds are not the only possible lead change agents. It is also important that lead change agents not be seen as representing “special interest” groups, but be seen as representing the will and interests of the entire organization.

If a person chosen a sole lead change agent is from a minority background, it is even more important for senior leadership to strongly communicate its vision and support for human rights change, and to prominently position lead change agents in the reporting hierarchy. As well, do not assume that because a person comes from a minority group background that they will automatically have human rights knowledge and expertise. In many cases, it will be necessary to provide people with extra training and significant access to expertise in human rights and organizational change. Such expertise can be gained from other police organizations, the OHRC, the academic community and external consultants.

7.4.1 Best practices for selecting lead change agents

  • Prominently position lead change agents in the reporting hierarchy
  • If resources permit, use specialized staff or consultants to support lead change agents
  • Make sure that officer staff are primary parts of assigned lead change agents
  • If resources only permit one or a few staff to be positioned as lead change agents, make sure they are adequately trained and have access to expertise
  • If lead change agents come from equity-seeking groups, make sure that they are strongly positioned and supported by senior leadership.

7.4.2 Things to avoid in selecting change agents

  • Don’t “silo” and/or delegate all responsibility for leadership for human rights organizational change at lower levels of the organization. All leaders must be part of the change efforts so they are taken seriously by everyone
  • Don’t rely exclusively on “parachuted in” change agents. They may have little knowledge of how the organization functions and may lack credibility among staff and the wider public. Leading change requires detailed knowledge of the organization’s structures and culture, and effective relationships with the public and staff
  • Don’t assume that persons from equity-seeking groups automatically have human rights knowledge and expertise. Experiencing discrimination does not mean you understand and can analyze its causes or cures, from a human rights perspective

7.5 Multi-stakeholder structure

Involving stakeholders is particularly important for police organizations seeking human rights organizational change. Human rights issues potentially affect all internal and external stakeholders throughout the course of police work. Human rights concerns can and often do emerge in all areas of police activity, and particularly in service to the public. Involving all stakeholders is instrumental to identifying all relevant concerns, coming up with realistic solutions, putting changes in place, and gaining the “buy-in” needed to address resistance.

One of the main roles for lead change agents is to plan and establish formal structures and processes for change. A vital part of doing this effectively is identifying internal and external stakeholders and sources of expertise, support and resistance among them. It is ideal to involve all stakeholders in formal change structures, but this may not be possible in the case of resistant stakeholders. This primarily includes identifying available human resources, and mobilizing these in working structures like committees and working teams or groups as part of a comprehensive change program. It is also important to plan for educating participants, providing them with relevant information and research, coordinating and facilitating their work, and establishing processes for decision making, reporting and evaluation.

Selecting participants well, and supporting, training and acknowledging their involvement, are some of the best investments an organization can make towards human rights organizational change. Participants in change structures are important for identifying and implementing key change initiatives. They are themselves targets for human rights-related professional development and training, and can play a major role as “ambassadors” and “champions” for the change. This is another reason to try to include members from all key stakeholder groups in the change structures.

(a) Internal stakeholders: police associations
Police associations are an important stakeholder group. Efforts should be made to try to involve them in change efforts. They have many reasons to support human rights organizational change, because human rights improvements benefit police staff as much as members of the general public.

(b) External stakeholders
Many police services already have formal ways to consult with their communities and can use these to allow voices from the community to be included in change efforts. Try to include stakeholders from underrepresented, racialized and marginalized communities (referred to here as “minority community”). All community members have some interest in police activity and human rights, but minority communities identified by Code grounds are often especially interested since they are often the most affected by human rights issues in policing. Communities may be identified by race, colour, culture, family status, disability and sexual orientation. These communities are diverse and may include people who are critical of police activity. Ideally, organizational change structures need to include voices from these communities to articulate key concerns and help search for effective solutions.

Human rights organizational change structures and processes will need to be different for police organizations of different sizes and natures. Smaller organizations use a less formal structure and smaller multipurpose committee, while larger organizations will likely need more elaborate structures with multiple committees, working groups and formal decision-making processes.

Community involvement helps to ensure that human rights efforts and initiatives by police are relevant and in tune with local needs, and made known to the wider public. Community involvement enhances public accountability, and can also improve public relations and perceptions in the process.

Toronto Police Human Rights Project approaches
Because of the size of the Toronto Police Service, a multi-year project requiring highly formalized structures and processes for change was created.

The three partner organizations provided members to take part in seven different committees to administer the project (see Appendix “A” for a sketch of this project structure). The committees included a sponsors committee (the heads of the three organizations), an executive committee to plan and oversee the overall project, a project training committee, four working subcommittees focused on identifying human rights concerns and developing and implementing solutions in key areas of police activity, and an extended executive committee consisting of chairs from the four subcommittees and executive committee members.

The subcommittees focused on employment practices, police officer accountability, staff learning and training, and public education and liaison. Over the three years of the project, more than 100 people, mostly representing police staff and volunteers from many areas of the TPS, were involved in the committees. The TPS also provided a project coordinator working from the Diversity Management Unit. This coordinator served as a link between the committees and organized key meetings and events.

The OHRC’s involvement was seen, among other things, as a way to incorporate communication from minority communities, as the OHRC often hears from community advocates and was deemed to be able to speak about many of these concerns. Also, a major goal of the change work was to create plans to involve the existing community consultative structures of the TPS in a formal way to advise on human rights issues.

Smaller police services will not need to develop the elaborate change structures and processes involved in the Toronto Police Human Rights Project, but can apply some of the features in more simple multipurpose structures. A small executive group composed of lead change agents is essential and can perform many tasks including coordinating, facilitating, training, evaluating and reporting on the entire project. A single multi-stakeholder committee can be set up to perform many of the same tasks performed by the TPS project’s four working groups. Many smaller police services enjoy positive relations with their police associations and minority communities, and can involve them in committee work, as active participants or advisors.

7.5.1 Best practices for governance of organizational change and stakeholder engagement

  • Involve all internal and external stakeholders in change structures, including, if possible, police associations and critical community groups
  • Develop an executive group that is able to coordinate and facilitate project work
  • Develop multi-stakeholder working committees to identify human rights concerns and solutions, and develop and implement action plans. Include relevant corporate and operational management, staff and subject matter experts (e.g. Human Resources if dealing with human resource issues) to ensure local responsiveness of efforts and consistency with business processes and protocols
  • Plan for and conduct evaluation of project work and impact, preferably by neutral third-party experts

7.5.2 Things to avoid in governance of organizational change and stakeholder engagement

  • Do not delegate full decision-making responsibility to advisory committees and others in a way that abdicates executive leadership, responsibility and accountability for human rights organizational change. Leaders must be actively involved to ensure that change efforts are taken seriously by all members of the organization

7.6 Monitor and evaluate

”What gets measured gets done, what gets measured and fed back gets done well, what gets rewarded gets repeated.” (John E. Jones, Leadership Trainer)

All change efforts need to be evaluated. The two basic components are evaluating the change efforts and the impact of these efforts. Evaluating the impact shows the real benefit of change efforts, and can help to identify future needs. Ideally, evaluation should be built into initial planning. Evaluating for impact works best when you identify indicators for success early, set clear benchmarks and identify goals for change. Such evaluation requires research skills that police services may not have. Partnerships with academics or other better resourced police organizations may be cost effective ways to do the evaluation. Having a neutral third party do the evaluation can add credibility to findings. Even where resources are scarce and partnership opportunities are limited, simple internal methods of evaluating impact will be valuable.

The TPS experience
The Diversity Institute of the Ryerson School of Business was contracted to evaluate the Toronto Police Service Human Rights Project. The Institute began formal evaluation once the project ended. The evaluation will include review of the human rights change structure and process, and will look at the impact of the overall work in the human rights profile of the TPS.

(a) Post-project monitoring and maintenance
Large organizations may need to start human rights organizational change with a time-limited project to raise the attention needed to foster and integrate significant systemic change. However, post-project measures must be developed to monitor and manage human rights issues and to help establish longer term structures and processes. A successful human rights organizational change effort will plan for post-project needs in some formal way.

7.6.1 Best practices for monitoring and evaluation

  • Clearly articulate SMART (Specific, Measurable, Actionable, Realistic and Time-lined) human rights organizational change goals and desired outcomes at the start of the project (in other words, define what success looks like)
  • Develop and agree upon appropriate performance measures (including outcome measures)
  • Regularly evaluate and assess impact of human rights organizational change efforts, and revise and update strategies and action plans in light of incoming information
  • Partner with academics or other better resourced police organizations to conduct evaluations if you lack internal expertise
  • If human rights organizational change begins as a time-limited project, make sure there is post project evaluation and follow-up to establish and guide more enduring human rights processes and systems.

7.6.2 Things to avoid in monitoring and evaluating

  • Do not treat performance measures and data collection as ends in themselves by failing to analyze, report and/or act on the information obtained. “Intelligence” – data collection, analysis and reporting – must be tied to a specific goal.

7.7 Communication and reporting

Reporting should spell out the vision and values guiding the change effort, and detail the change efforts being made and specific changes that are being developed or implemented. As public bodies, police organizations should report publicly. But do not overstate the success of change efforts – allow the facts to speak for themselves.

Critical groups will not be convinced by reports alone, but will appreciate transparency. Make reporting formats and mechanisms accessible with broad outreach to the public. Different communities have different needs - consider formal reports, newsletters, media articles, flyers and inserts in community publications. Ideally, make these available in different languages (depending on demographics and need) and publish them both on websites and in accessible hard formats.

Reporting can show the wider public that the police are acting in good faith to make meaningful and substantive human rights organizational change in an accountable, transparent way.

“The Charter agreement between the three partner organizations included a requirement that the Project report on its work and progress. The Project team released three annual reports that identified project highlights and detailed the work of the subcommittees. These reports were tabled at the public meeting of the Toronto Police Services Board, and were then released on the websites of the Board and the TPS. In addition to these formal annual reports, a newspaper insert about the TPS commitment to “Fair and Equitable” policing and referring to the Human Rights Project was distributed through community newspapers to over 450,000 households.”

7.7.1 Best practices in communication

  • Plan for and execute transparent, accessible and regular reporting on project progress, to the organization and the public.

7.7.2 Things to avoid in communication

  • Do not fail to communicate successes and acknowledge gaps and failures. Sharing good practices inspires the same, while acknowledging challenges shows good faith and a will to continually improve
  • Do not make promises that you do not keep. Show, through your actions, that the organization is committed to human rights organizational change. Words are quickly perceived as “empty” without corresponding actions to support them.

7.8 Identify and address resistance

Change of any type can create opposition. Almost all organizational change efforts will be met with some resistance. In any substantial change effort, try to anticipate where resistance might come from and plan how to respond. Not doing so can delay or even stop change efforts.

(a) Acknowledge resistance
Acknowledging resistance is a major step in addressing it. People resist change for reasons that are understandable, even if they may be misguided. Acknowledging perceptions and attempting to address these through patience and persistent messaging is a useful first step that will help you manage many difficult situations. In some cases, resistance will be deeply rooted and not easy to overcome – the only way to proceed may be to firmly but respectfully affirm change goals and initiatives.

(b) Sources of resistance
Resistance to human rights organizational change can come from many sources. Most people do not object to the idea of “human rights”, but many may resist the effect of human rights on specific issues. These may be seen to be a threat or an affront in some way.

Here are some examples of negative reactions to human rights-related efforts in policing:

  1. A police service tries to become a more diverse and representative workforce. Some white male officers see such efforts as “favouritism” that unfairly hurts their employment opportunities.
  2. A police service works to accommodate religious attire in uniforms. This provokes a reaction among some people who think this is an affront to police unity and policing customs that undermines morale.
  3. A police workplace takes steps to accommodate employees with care-giving responsibilities. Many staff view the accommodation as “favouritism” and unfair “preferential treatment.”
  4. A police service takes steps to acknowledge systemic racial discrimination or racial profiling. Staff deny systemic racism and racial profiling, and feel these steps are insulting to police officers.

The TPS experience
In the Toronto Police Human Rights Project, anticipating and planning for resistance was a regular item of discussion on the various committees. Discussion related to examples described above were just some of the types of resistance that were experienced. Employment equity efforts aimed at a representative police service, in particular, raised concerns. Efforts to respond to this resistance

  • Clearly and consistently explaining the purpose and need for equity measures
  • Showing that these measures were fully consistent with hiring and promotion on the basis of merit
  • Affirming through objective data the extent to which new hires and promotions reflected the population.

Some concerns persist, but the project partners believe responding has helped reduce resistance.

7.8.1 Best practices in addressing resistance

  • Anticipate, acknowledge and respond to resistance and the perceptions underlying it, through consistent and firm communication by senior leadership and through risk management planning at the start of the project.

7.8.2 Things to avoid in addressing resistance

Do not focus on convincing everyone of the merit of human rights organizational change efforts – which may be impossible. By supporting existing and potential “champions” and allies rather than a small minority of immovable detractors you are more likely to succeed.

7.9 Strategic areas of focus for change

Once an organization has established its human rights policy vision and a governance structure to oversee the design of a comprehensive human rights organizational change strategy, it will need to decide which change efforts to focus on.

While this kind of change involves all facets of an organization, not all areas can be addressed right away. Each organization will have key areas that may draw greater human rights concerns or be particularly important to preventing human rights concerns from arising. You will need to identify and focus on these areas first. The strategic choice of focus areas can make the difference between success and failure.

It is often useful to start with concerns relating to employment and service-based activity. Employment and services are two of the five social areas where discrimination based on Human Rights Code grounds is prohibited. For public service organizations like police and school boards, service-based human rights complaints outnumber employment-related ones.

Note that there are strong interactions between an organization’s employment and service activities. For example, strongly affirming human rights values and legal requirements in employment will significantly help organizations to show the same commitment in the services it delivers.

In addition to focusing on employment and service functions, some specific human rights issues may be so significant that they need specific attention. For example, some police services have been seen to have strained relations with some communities identified by race, such as the Aboriginal and Black communities. Perceptions of racial profiling have been the source of a large number of human rights complaints from members of these and other communities in the last few years. Another historical concern in policing has been the lack of opportunities for women to serve as police officers. Each police service may have its own unique set of human rights issues that will need to be tackled.

Training, internal complaint systems and human rights accommodation processes are areas of organizational activity that are particularly relevant to addressing and preventing human rights violations. Training initiatives are usually a major part of efforts to prevent and respond to human rights concerns. Redesigning training systems and programs to serve human rights purposes will usually be a major part of a human rights organizational change plan. This is because staff must have appropriate human rights competencies, skills and knowledge to embed human rights in the work they do.

Organizations that best address human rights concerns also have effective internal complaint mechanisms for dealing with human rights matters. Focusing attention on establishing or improving internal complaint systems to assess human rights concerns will help an organization to better respond to human rights issues as they arise, and to learn from these to prevent future problems.

Both legislation and case law stress the legal requirement to accommodate based on disability, religion and family status. Not accommodating based on disability is the largest single reason that human rights complaints (now called applications) are filed in Ontario. Focusing attention on developing and improving human rights accommodation processes can help to establish a welcoming workplace that is more receptive to the contribution of many marginalized groups in society.

Developing human rights training, internal complaint systems and accommodation processes should be part of a larger human rights organizational change strategy that reviews all organizational policies, systems and structures from a human rights perspective (as discussed in section 7.1).To sustain human rights organizational change and prevent human rights violations, organizations must build human rights into their regular structures and ways of doing business.

The Ontario Provincial Police supports the work of the Ontario Human Rights Commission and its development of Human rights and policing: Creating and sustaining organizational change as a positive step for police agencies to meet their obligations under the Ontario Human Rights Code and to better serve Ontario’s diverse communities.

– Chris D. Lewis, Commissioner, Ontario Provincial Police

The TPS experience
The Toronto Police Service Human Rights Project chose to focus on four separate areas that were entrusted to subcommittees to identify concerns, suggest actions, and plan or implement change. The Recruitment, Selection, Promotion and Retention Subcommittee focused on finding and removing barriers to employment of minority groups and women, and on reviewing any other employment practice that may affect the human rights experience of members. The TPS wanted to develop a staff profile that better reflected the population it served. Before the project, it had already conducted major employment systems reviews to support this. The TPS believes a more representative police service is an essential affirmation of human rights values, and a key way to develop capacity to better serve a very diverse city with many different human rights issues.

The Public Education and Liaison Subcommittee focused on improving community relations with alienated segments of the community, and on making sure that police consultation and communication with the community served human rights aims.

The Accountability Subcommittee focused on reviewing service systems to make sure that police officers were accountable for their human rights obligations in their work. This included looking at complaints processes, performance management systems, and procedures guiding police service activity.

The Learning Subcommittee worked on improving training and other learning activities to support human rights understanding and compliance.

The project’s four areas of focus may be helpful for other police services. However, these are only a general guide. Each police service will need to do its own assessment and make its own strategic choices.

7.9.1 Best practices in selecting strategic areas of focus

  • Identify areas of focus after assessing the experience and circumstances of the service
  • Consider focus areas that relate to employment and service functions
  • Consider focus areas related to training, accommodation and internal complaint processes.

7.9.2 Things to avoid in selecting strategic areas of focus

Do not select strategic areas of focus without a larger organizational change strategy. A larger organizational change strategy informs and directs priority-setting and ensures that change momentum remains strong.

Organizational responsibility: