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8. Specific actions to consider

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Over the last few years, new strategies to support human rights organizational change in policing organizations have been developed. This section describes some of the key actions that were taken during the Toronto Police Service Human Rights Project, but many have also been used in various shapes and forms by other police organizations.

8.1 Core actions

1. Human rights and accommodation policy
Few police service boards have clear and comprehensive human rights and accommodation policies. It is important to create such policies to signal commitments and obligations (for example, see Toronto Police Services Board Policy online at

2. Review policies and procedures and consider human rights implications
Most policies and procedures have human rights implications, or can be improved to provide better human rights protections. A formal review of all policies and procedures by individuals sensitive to human rights case law and policy will help find barriers or gaps. The OHRC has developed a guide for developing human rights policies and procedures with some sample language (see Guidelines on Developing Human Rights Policies and Procedures and Human Rights at Work, online at

3. Inclusive design reviews
Inclusive design reviews are research projects to identify barriers to participation for persons who identify with various Code grounds. An inclusive design review can be conducted relating to specific Code grounds like race, family status, religion, disability or gender, or can focus on an area of concern like employment practice or service delivery. Such reviews are a standard tool used in human rights organizational change, and can be more or less detailed depending on the expertise and resources available.

As part of its human rights work, the TPS has done several formal inclusive design reviews, including a major review of employment practices for both officer staff and civilian staff. It is also planning an inclusive design review of employment practices based on religion.

4. Publicize the commitment to human rights
Publicizing a police service’s commitment to human rights both to service members and the general public will help to clarify the goals, raise standards of conduct, and ease any community concerns. A concerted effort to use communication tools for this purpose does not take a large commitment of resources but can have a major impact.

For example, the TPS developed a four-page community newspaper insert to advertise its commitment to fair and equitable policing, and distributed it to over 400,000 homes across Toronto.

5. Integrate human rights element into complaint procedures
Identifying and dealing with human rights complaints in a timely and respectful way is critical to the health and resilience of individuals, and for the organization. A healthy organization is one that learns from its mistakes. Human rights complaints may be addressed in many ways, including by creating human rights complaint systems that deal exclusively with human rights-based conflicts, and/or by monitoring human rights-based grievances and complaints within existing complaint systems and procedures.

The TPS has built a human rights element into their existing complaint procedures by cataloguing and monitoring all human rights concerns from existing grievances and internal complaint processes.

8.2 Actions aimed at improving employment practices

1. Complete a staff census
Police services need to know the makeup of their staff based on Code grounds such as race, family status, ethnic origin, disability, gender and sexual orientation if they want to be reflective of their community. The Ottawa Police Service conducted an extensive census of its staff using survey methods that can be used by other services. This type of data can help identify gaps in staff representation and target recruitment efforts. See the OHRC’s publication – Count me in!: Collecting human rights-based data, available at for more information and best practices on how to collect human rights-based data.

2. Work to recruit members of under-represented groups
Representative police services need targeted recruitment efforts to attract under-represented group members. Steps to do this include researching and responding to barriers to police employment for targeted groups, targeted advertising and recruitment, and mentoring targeted group members through the hiring process. The TPS is one of the most successful services in hiring members of under-represented groups. It uses these tools extensively.

3. Include human rights considerations in exit surveys
Exit surveys help employers understand why employees are leaving their jobs. They are used by many employers, including police services, to identify employment concerns. Asking specific human rights-related questions can help identify human rights concerns affecting employees. The Toronto Police Service Human Rights Project included the creation of an exit survey.

4. Create affinity groups
Affinity groups are peer support groups, supported by the employer, that include people from similar backgrounds. They are used widely to allow employees from minority groups to support each other in their employment experience and help the service to better meet their needs.

The TPS lets individuals formally develop “Internal Support Networks” to act as affinity groups for its staff including Black, Women’s, Filipino and LGBT Networks.

8.3 Actions related to police service delivery

1. Build human rights considerations into PSA complaints process
Complaint processes under the Police Services Act (PSA) are a feature of police experience. While the PSA identifies grounds for complaints and sanctions that overlap with the Human Rights Code, the human rights implications are rarely clear or acted on as specific human rights actions. Also, some services have internal complaint and grievance processes that supplement complaint processes under the PSA. These complaint processes can be used to identify human rights concerns and help to guide institutional responses. The Toronto Police Service Human Rights Project changed complaints procedures and practices to achieve this aim. This included redesigning several forms, processes, databases and investigator training to add a human rights lens.

2. Include human rights considerations in performance management
Performance evaluation and management are major tools for influencing staff behaviour. These can be adapted to serve human rights purposes by explicitly looking at human rights-related behaviour and activity. To address conduct related to diversity and human rights, the Toronto Police Service Human Rights Project changed officer evaluation and performance forms, and developed training to use the newly revised (human rights inclusive) performance evaluation forms.

3. Collect data related to human rights in service delivery
Collecting data to identify patterns of service delivery is important for all organizations including police. Such data is collected routinely to look at who is being served and identify gaps and failings in service. As long as proper safeguards are in placed, the OHRC encourages organizations to collecting data based on Human Rights Code grounds to serve human rights purposes such as detecting patterns of discrimination. For more information, see the publication Count me in!: Collecting human rights-based data, available online at

The Toronto Police Services Human Rights Police Project considered the value of this type of data collection to assess patterns of racial profiling, but did not implement it, noting that the TPS had already acknowledged racial profiling and steps to address it were already underway. Collecting data to identify and develop responses to racial profiling may be appropriate in other police services. This is common practice in many police services in the United States, and also in the United Kingdom.

4. Develop human rights focus for community consultation activity
Police services routinely consult with the communities they serve to better meet their needs, and to share issues of potential concern. In many larger services, consultation is a regular practice, and consultative committees are common.

Community consultation can be directed to support human rights goals, especially those relating to allegations of discrimination in police service. The Toronto Police Service Human Rights Project reviewed its community consultation structures and procedures to develop an explicit human rights role for them. Changes included adding a role into the description of the consultative committee mandate, making human rights training mandatory for committee members, and developing a new consultative committee to address the specific concerns of persons with disabilities. Such targeted community consultations can be very effective in beginning to mend relations with communities seen to have historically poor relations with the police.

5. Develop language guide for internal and external communication
Police communication is a sensitive issue for members of many minority groups. Language chosen to describe a suspect or community grouping can be unintentionally insensitive, or worse, perpetuate stereotypes of minority groups. Developing a language guide to help staff use appropriate and sensitive language in their communication work can be a valuable tool to support a police service’s human rights goals. The TPS, with input from the OHRC has developed this type of best practice language guide for its members.

6. Develop outreach tools for hard-to-reach communities
Many communities do not get police information easily due to barriers such as language, homelessness and disability. Identifying these hard-to-reach communities and responding with appropriate measures will support a commitment to human rights. Many police services have developed brochures and guides in the language groups found in their communities. The Toronto Police Human Rights Project identified homeless persons as a particularly vulnerable community that needed enhanced outreach and communication efforts. Efforts to better reach out to this community were initiated during the project.

7. Attend or organize diversity and human rights-related events
Acknowledging and/or celebrating the diversity of a community is an important signal that a police service is connected to all members of its community. Attending or organizing events to acknowledge important dates for minority community members or for human rights in general are one way to affirm this. Many police services attend and/or organize community events for this purpose. This is an easy way to publicize commitment to human rights.

The TPS regularly hosts celebrations in the lobby of their headquarters, to recognize various diversity and human rights-related days of significance (for instance, celebrating the international day for the elimination of racial discrimination).

8.4 Actions related to training

1. Develop generic human rights training programs
Training is an essential part of a police service’s efforts to prevent and address human rights concerns. Training should focus on general human rights and on specific human rights issues that arise in police work.

Human rights issues are complex and can take many different forms, so some basic understanding of generic human rights is essential to prepare staff to identify and respond to these concerns. Training should focus on human rights history, values, legal obligations and principles in a way that connects to the organizational context and work experience of the people being trained. This training should be provided to all current staff, and to all new staff as part of their orientation.

Human rights training on a larger scale should be clearly connected to a larger organizational change strategy, to show the organization’s commitment to the subject matter. Training should provide staff with the concrete skills and tools required to effectively achieve human rights organizational change strategic goals. It will help to first assess staff and organizational gaps in knowledge and skill, in relation to change objectives, and provide targeted training in those areas.

The Ontario Police College provides some initial training for new recruits. Any human rights organizational change effort needs to go beyond this and extend training to all staff, including civilian staff. Periodic refresher training should also be considered as a standard requirement. As part of the Toronto Police Service Human Rights Project, a full-day in-class training session was prepared for all staff. The OHRC, in partnership with the Ontario Police College, has provided similar training to smaller services over the last few years.

The OHRC provides an e-learning introduction to human rights called “Human Rights 101.” This learning module, available at, is available to the public and can be used as a component of human rights training.

2. Develop training related to specific human rights issues
In addition to generic human rights training, training on specific human rights issues will be needed from time to time. For example, police services have developed training packages on racial profiling, treatment of transgendered individuals, sexual harassment, etc. The TPS has developed e-learning training on racial profiling for police officers. This training is available for other services to use through the Canadian Police Knowledge Network. Through this network and other associations and networks, smaller police services have access to a wide range of training programs on specific human rights issues.


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