Rêves repoussés : Guide de suivi et d’évaluation – Mise en place d’un cadre axé sur les résultats dans le système d’éducation publique de l’Ontario

Commission ontarienne des droits de la personne

Novembre 2026

ISBN : 978-1-0491-0122-4 (Imprimé)

978-1-0491-0123-1 (HTML)

978-1-0491-0124-8 (PDF)

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Pour en savoir plus sur le système des droits de la personne de l’Ontario, consultez la page Web dédiée au système des droits de la personne en Ontario.

1. Overview

The Ontario Human Rights Commission’s (OHRC) mandate is set out in the Ontario Human Rights Code (Code). Its mandate includes advancing and promoting respect for human rights in Ontario, recognizing that it is in the public interest to do so, and that it is the Commission’s duty to protect the public interest, and to identify and promote the elimination of systemic discrimination.

The Code prohibits actions and behaviours within provincial jurisdiction that discriminate against people based on seventeen protected grounds in five protected social areas. Systemic discrimination can include harassment that can contribute to a poisoned environment. The Code also protects individuals from reprisal for asserting their rights under it.^[1]

The Code envisions an Ontario in which the dignity and worth of every person is recognized, and each has equal rights and opportunities without discrimination, in a climate of mutual respect and understanding, so that each person feels a part of the community and is able to contribute fully to the development and well-being of the community and the Province.

The OHRC advances its mission by driving structural change based on the principle of substantive equality. The mission is accomplished by exposing and challenging systems of discrimination through education, policy development,^[2] public inquiries,^[3] and strategic litigation.^[4]

Illustration of two Black children sitting on the floor playing together with toys and building blocks. One child wears a light-coloured dress while another wears a short-sleeved shirt and shorts.

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In the Dreams Delayed: Addressing Systemic Anti-Black Racism and Discrimination in Ontario’s Public Education System (Dreams Delayed) report, the OHRC documented deeply entrenched patterns of systemic anti-Black discrimination and harassment in Ontario’s publicly funded education system, patterns that continue to undermine the safety, well-being, sense of belonging,^[5] and success of Black students, educators and education workers (staff).

Building on the insights and lived experiences gathered from extensive province-wide consultations, the OHRC developed 29 Calls to Action aimed at addressing the crisis of anti-Black racism and discrimination in Ontario’s publicly funded education system. These Calls to Action are organized into three main themes: accountability and transparency, monitoring and evaluation, and student well-being, with structured timelines to reflect both immediate and intermediate actions. The immediate actions are intended to be completed within the first 1 to 2 years, while the intermediate actions are set for 3 to 5 years, starting from March 2025, the date the OHRC released the report.

As documented in Dreams Delayed, oversight is still inconsistent across the system. Without proper monitoring and accountability, both overt and subtle forms of anti-Black racism and discrimination continue to impact students and staff negatively.

To address this gap, the OHRC has developed a tool called Dreams Delayed: Guide on Monitoring and Evaluation Towards Achieving Outcomes in Ontario’s Public Education System (Dreams Delayed guide or Guide) to assist education duty-holders in monitoring the implementation of, and tracking outcomes related to the Calls to Action in Dreams Delayed (see Appendix C: Dreams delayed calls to action).

This Guide aligns with the OHRC’s Human Rights Based Approach (HRBA) Framework, and serves as a companion to the HRBA. It provides a principled, practical, and evidence-based approach to addressing systemic discrimination and harassment, thereby helping to achieve substantive equality under the Code, the Education Act, and related legislation.

The OHRC acknowledges that various education duty-holders share responsibilities, which require coordination across different systems. Thus, the OHRC encourages collaboration, relationship-building, and a problem-solving approach among them.

1.1. Purpose of the Guide

The Guide provides clear instructions to education duty-holders on how to meaningfully address systemic human rights issues, especially anti-Black discrimination and harassment within the education system.
It establishes a human rights-based approach for evaluating institutional efforts to address anti-Black racism and discrimination, ensuring that learning and working environments are free from discrimination and harassment.^[6]

Illustration of a Black educator seated in a chair reading from an open book to two young Black children seated nearby. The children are listening while seated on small chairs.

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By centring the diverse experiences of Black communities, especially Black students and education staff, and using various methods of measurement (quantitative and qualitative), the Guide helps to promote accountability and transparency, builds public trust, and supports a transformative approach to achieving substantive equality and non-discrimination.

The Guide is aligned with the OHRC’s mandate. It offers education duty-holders a comprehensive framework for:

Monitoring and measuring the concrete realization of human rights-based outcomes.
Evaluating compliance with the Code’s non-discrimination obligations based on measurable results.
Identifying systemic inequalities that impact individuals who are protected under the Code.
Enhancing accountability and transparency through evidence-based practices aimed at preventing and eliminating discrimination.

This Guide assists education duty-holders in fulfilling their legal obligations in practical ways. It can be used to evaluate existing initiatives aimed at addressing systemic discrimination to measure their effectiveness and outcomes. In addition, education duty-holders can reference the Guide when developing or updating initiatives that reflect the Calls to Action, aiming to establish or strengthen a comprehensive monitoring and evaluation system grounded in human
rights principles.

The Guide is not intended to assess organizational performance in isolation from the affected communities, existing policies, or broader human rights obligations. It is designed to be applied with community input, particularly from Black communities. It also supports education duty-holders in assessing whether policies, systems, and resource decisions result in outcomes which meet obligations under the Code, the Education Act, other relevant legislation or case law.

The Guide serves as a companion to the OHRC’s Human Rights-Based Approach.

1.2. How to use this Guide

By the end of this process, education duty-holders and their organizations will have gained a clearer understanding of whether their actions are leading to meaningful, measurable improvements in addressing discrimination and harassment.

Each organization has distinct needs, constraints, structures, and resources. There is no “one size fits all” way to prevent and address anti-Black discrimination and harassment. While the Guide offers various ideas, each organization within the education system must tailor its approaches to fit its unique context.

The OHRC encourages all duty-holders in the education system to adopt this Guide as a continuous process of learning, accountability, and progress. Duty-holders are encouraged to integrate the monitoring and evaluation processes outlined in this Guide into existing strategic planning, governance, and reporting frameworks. Embedding human rights monitoring within established organizational planning and accountability cycles helps ensure that efforts to address anti-Black discrimination and harassment are not treated as stand alone initiatives, but as core institutional responsibilities.

The focus is on whether those processes are resulting in movement towards an education system free from discrimination and harassment, not on whether prescribed processes have been followed. Further, the focus is about cultivating accountability from education duty-holders directly to rights-holders, particularly Black students and staff, not about reporting solely to the OHRC. Strengthening this relationship is essential to building community trust.

1.3. Potential outcomes and benefits of the Guide

Duty-holders in the education system with direct or indirect roles and responsibilities within the education system will be able to:

Identify whether their initiatives are aligned with the goal of eliminating discrimination and maintaining an environment free from discrimination.
Be supported in meeting their human rights obligations through the collection, analysis, and public reporting of data, including quantitative, qualitative, disaggregated, and intersectional Code-based and non-Code based data, and support more informed and Code-compliant decision-taking.
Report monitoring and evaluation results publicly in clear, accessible and inclusive formats, increasing transparency, strengthening accountability, and building trust
with communities.
Create meaningful community participation and inclusion throughout the monitoring and evaluation cycle to further enhance transparency, improve accountability, and foster trust with affected communities.

Illustration of three people engaged in creative activities. One person seated in a wheelchair plays the trumpet, another holds a paintbrush and a third stands nearby. The image presents participation in the arts.

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2. Roles and responsibilities of duty-holders under the Code

Under the Ontario Human Rights Code, a duty-holder is any public or private actor responsible for respecting, protecting, promoting, and fulfilling the human rights of Ontarians in any of the 17 grounds and five social areas. The obligation to respect requires duty-holders to refrain from discrimination, including direct, indirect, and subtle discrimination and vicarious liability. In the education context, duty-holders include school boards, administrators, the Ministry of Education, unions, Faculties of Education, the Ontario College of Teachers, and educators. If you are in a position of authority or influence in the system, you may be a duty-holder. This means you are expected to take proactive steps to identify, address, and prevent systemic discrimination and harassment before harm occurs, and to take prompt and effective action to investigate and remedy harm when it does occur. ^[7] Under the Code, duty-holders are required to:

Review institutional/organizational policies, practices, and cultures, to identify whether they are producing measurable and meaningful outcomes that support the achievement of substantive equality.
Identify barriers, whether direct or indirect, and remove them in a timely manner.
Take prompt and effective action to investigate, address, and remedy incidents of discrimination and harassment when they occur and prevent their recurrence.
Ensure spaces are non-discriminatory and inclusive, especially for those most affected by systemic discrimination and harassment, such as Black students and education staff.

An organization violates the Code where it directly or indirectly, intentionally, or unintentionally infringes the Code, or where it does not directly infringe the Code but authorizes, condones, adopts, or ratifies behaviour that is contrary to the Code. Organizations must take reasonable steps to prevent violations of the Code, or they may be found to have infringed a right under the Code and be subject to a restitution, monetary compensation, or other orders.^[8]

Sections 35 and 37 of the Code permit the OHRC to seek intervention in an application before the Human Rights Tribunal of Ontario (HRTO) to public interest and may lead to an appropriate remedy.

3. Applying the HRBA Framework

To effectively apply the HRBA in the public education system, education duty-holders should use practical tools that strengthen accountability and continuous improvement. These include collecting and analyzing disaggregated data, developing structural,^[9] process,^[10] and outcome ^[11] indicators, publishing accessible reports, and embedding participation and accountability mechanisms. Together, these tools help establish baselines, monitor progress, and integrate findings into a comprehensive evaluation of human rights compliance. Applying these mechanisms across all stages ensures transparency, community engagement, and measurable progress toward substantive equality.

The focus of the first six stages of the HRBA is about embedding human rights principles into organizational systems, ensuring resource allocations reflect commitments to address systemic discrimination, and designing initiatives that are measurable, and outcomes focused. During these early stages, structural, process and outcomes indicators should be developed to ensure monitoring and accountability are embedded before implementation begins.

Stage seven: monitoring and evaluation draws on the indicators developed in the earlier stages to assess whether duty-holders’ initiatives are producing substantive equality outcomes. This stage integrates qualitative and quantitative findings from earlier stages to provide a holistic assessment of progress, identifying successes, gaps, and next steps.

Education duty-holders are encouraged to align the implementation of this Guide with their existing strategic planning, performance measurements, and accountability processes.

Applying the HRBA Framework

Figure 1: Seven stages of the HRBA

Throughout all stages, education duty-holders are encouraged to use diverse data sources, engage affected communities, and apply HRBA principles such as participation, accountability, transparency, and non-discrimination. This approach enables a comprehensive, evidence-based assessment of progress and areas
for improvement.

If duty-holders have not utilized the OHRC’s HRBA tool prior to developing and implementing their initiatives, the OHRC encourages them to review the Human Rights-Based Approach (HRBA) Framework.

3.1. Stage one: Context analysis

During stage one of the HRBA, education duty-holders should identify human rights issues, systemic barriers and historical factors affecting Black students, and staff. Duty-holders are encouraged to consider the intersectional impacts of other Code grounds (e.g., race, creed, place of origin, disability, gender identity and expression, sexual orientation). Duty-holders must ensure their initiatives are grounded in human rights principles and designed to meet their legal obligation under the Code and other related legislation.

This may include examining:

Historical and ongoing disparities in informal streaming, discipline (suspension, expulsion, exclusion), graduation rates, and special education placements or Individual Education Plans (IEP).
Underrepresentation of Black staff in leadership roles.
Under-enrollment of Black prospective students in teachers’ college programs.
Experiences of anti-Black discrimination and harassment in classrooms (work environment).
The intersectional impacts of other Code grounds for both Black staff and students.

At this stage, education duty-holders are encouraged to begin identifying structural, process, and outcome indicators to guide accountability. Outlining early indicators will assist duty-holders to clarify baselines and help identify what meaningful outcomes may look like.

3.2. Stage two: Undertaking research & analysis

During stage two, education duty-holders are encouraged to collect and analyze qualitative and quantitative data to identify examples of anti-Black discrimination and harassment within their organization or institution. Effective data collection is critical for an accurate and comprehensive evaluation of human rights obligations. Duty-holders are encouraged to collect quantitative and qualitative data, disaggregated by relevant factors such as race, creed, gender, age, disability, and other Code grounds to identify disparities and systemic barriers.

Examples of data may include:

Unions examining grievance data related to racial harassment, discrimination in hiring, promotion and retention, and poisoned work environment.
Faculties of Education reviewing admission, retention, and practicum placement experiences of Black teacher candidates.
School boards reviewing hiring, retention, and promotion data.
Ontario College of Teachers examining complaints data related to anti-Black racism and discrimination.

At this stage, the drafted indicators should be refined based on disaggregated quantitative and qualitative evidence.

Illustration of two Black students participating in science, technology, engineering, and mathematics (STEM) learning. Long description in Appendix E.

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3.3. Stage three: Planning engagement

During stage three, education duty-holders should design and implement an inclusive and meaningful consultation process that centers Black communities, particularly Black students, and staff. Duty-holders should facilitate consultations with Black students, staff, families, and community groups to identify policy gaps and co-design solutions. Communications material development should be inclusive, culturally responsive, and resourced adequately to meet the needs of the communities.

Engagement may include:

The Ministry engaging with Black education advocacy organizations.
School boards engaging with Black education advocacy organizations, Black student associations, and parent/guardian groups.
Unions consulting with internal equity resource groups and/or external Black caucuses or affinity groups. Drafted indicators should be shared and refined through engagement to ensure the outcomes meet the needs of the affected communities.

Illustration of a community consultation session. Long description in Appendix E.

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3.4. Stage four: Developing options & recommendations

During stage four, education duty-holders should develop options and recommendations that address the root causes of anti-Black discrimination and harassment and promote substantive equality. Recommendations should consider systemic reforms and include strategies for data collection to monitor progress. Duty-holders should ensure that recommendations are measurable, and outcomes focused, and actionable. At this stage, indicators should be finalized and be explicitly tied to each recommendation. Duty-holders are encouraged to review the Calls to Action in Dreams Delayed (see Appendix C: Dreams delayed calls to action).

3.5. Stage five: Seeking approvals

During stage five, education duty-holders should document the processes of initiative(s) adoption and implementation, including risk assessments, decision rationales, and mitigation strategies. Identifying risks is essential to ensuring that initiatives achieve their intended outcomes in practice, not just in principle. Potential risks may represent factors that impede duty-holders from meeting their obligations under the Code and may also negatively impact relationships with the affected communities.

Without identifying risks, such as decisions being perceived as symbolic or performative, initiatives developed without meaningful consultation and collaboration, or gaps in data collection, analysis may result in efforts that undermine trust and exacerbate systemic barriers. Risks can be mitigated with clear actionable strategies such as establishing standards for meaningful engagement and co-development, ensuring accessible and inclusive communication, allocating adequate and sustainable resources, and requiring transparent, public reporting to strengthen accountability, credibility and evidence-based decision making.

The legal obligations under the Code should inform and drive the approval process. Duty-holders are encouraged to ensure clear accountability and transparency mechanisms along with the measurable indicators developed in the earlier stages are in place before proceeding to the next stage.

3.6. Stage six: Implementing programs & services

During stage six, education duty-holders should implement approved recommendations into concrete institutional changes. During this stage, duty-holders should also include monitoring compliance, and provide communications and trainings that will ensure the intended outcomes of the recommendations are achieved and meet the needs of those affected.

3.7. Stage seven: Monitoring & evaluation

During stage seven, education duty-holders will integrate quantitative and qualitative findings from all the earlier stages to assess whether their initiatives are leading to substantive equality. Where constraints or barriers are identified that impede progress toward meeting legal obligations, duty-holders will share these findings with affected communities and work with them to co-design corrective actions and next steps.

This stage also emphasizes transparency and continuous improvement. Duty-holders are encouraged to publicly report on evaluation findings. Where the evaluation identifies gaps or limitations, duty-holders are encouraged to revisit and redesign indicators in collaboration with affected communities. Baseline data should be updated as needed to reflect changes in initiatives and to support ongoing monitoring of outcomes over time.

Illustration of two Black students celebrating graduation. One holds a diploma overhead. The other holds a certificate. The image represents positive educational outcomes and achievement for Black students.

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Example of key questions

Below is a non-exhaustive list of examples duty-holders in the education system may consider during stage seven. For profession-specific questions, duty-holders are encouraged to collaborate with affected communities.

Based on policies, resources, and outcomes data, are your Black students and staff experiencing substantively equal treatment and opportunities?
What external socio-economic, political, or cultural factors affect Black students and staff from the realization of their human rights in education?
How are duty-holders ensuring accountability, transparency, and follow-through on commitments to combat anti-Black discrimination and harassment?
What institutional or structural constraints limit progress (e.g., funding inequities, resistance to change, lack of culturally relevant resources) and what strategies can mitigate them effectively?

Examples of key activities

Below is a non-exhaustive list of examples duty-holders in the education system may consider during stage seven. For profession-specific activities, duty-holders are encouraged to collaborate with affected communities.

Synthesize the data from the previous stages (e.g., policies, disaggregated outcome data, climate surveys, employee/member engagement surveys, community consultations) to form a comprehensive assessment.
Identify systemic barriers (e.g., systemic bias in curriculum, funding inequities) and structural challenges with input from rights-holders.
Develop an action plan assigning responsibility, timelines, and monitoring mechanisms.
Engage Black students, staff, families, and community groups in interpreting findings, confirming conclusions, and shaping next steps.
Publicly share findings in accessible formats and involve communities in the next steps.
Review whether Black students and staff are safe reporting discrimination, harassment and whether remedies are timely, reasonable, and effective.
Review and update monitoring mechanisms to improve future assessments.

Examples of data sources

Below is a non-exhaustive list of examples that may apply to education duty-holders across professions in the education system. Duty-holders are expected to identify primary and secondary data sources specific to their needs. Duty-holders and their institutions are encouraged to collect and analyze disaggregated data categorized by Code grounds.

Integrated reports combining qualitative and quantitative data from earlier stages.
Community feedback on draft assessments.
External research or socio-economic data identifying barriers (e.g., poverty, housing insecurity, systemic over-policing) that intersect with education outcomes.
Documentation of action plans and follow-up procedures.

Illustration of a Community Outcomes Review session. Long description in Appendix E.

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Appendices

Appendix A: Sample indicators and metrics

This section outlines examples to help guide education duty-holders craft human rights-based indicators to monitor and report on progress/outcomes in implementing the 29 Calls to Action. These examples are not exhaustive. Duty-holders are encouraged to develop context-specific indicators that reflect their unique roles, responsibilities, and the expressed needs of Black students, staff, families, and community groups.

Rather than providing indicators for every Call to Action from the Dreams Delayed Action Plan, this section highlights a small set of examples under the key themes: Accountability and Transparency, Monitoring and Evaluation, and Student Well-being. Duty-holders should use these as illustrations to build from and create their own tailored indicators.

Indicators should capture measurable and meaningful empirical evidence of policy review, revision and implementation, resource allocation, and improved human rights-based outcomes for Black students and staff, while also showing transparency, accountability and where appropriate, engagement with the community. In addition, education duty-holders are encouraged to consider, potential risks and barriers to implementing these indicators, and to develop mitigation strategies to address them.

Flowchart titled Appendix A: Sample indicators and metrics, showing the components of a human rights-based monitoring framework. Long description in Appendix E.

Figure 2: Sample indicators and metrics

Accountability and Transparency

Action 1 – Education Duty-Holders Must Acknowledge and commit/pledge to action on Anti-Black Racism and Discrimination in Education – Immediate
(1–2 years).

Targeted duty-holder(s): All education duty-holders.

Indicator: A formal public statement acknowledging systemic anti-Black racism and discrimination in education is issued.

Type of Indicator: Structural – existence of published acknowledgements, frameworks, and policies.

Potential data sources: School board and ministry websites, union statements, Faculties of Education statements, independent audits.

Timeline: Public acknowledgement released within 12-18 months of release of Dreams Delayed.

Human rights-based outcome: Duty-holders explicitly recognize systemic anti-Black discrimination and harassment and establish monitoring mechanisms to address this issue.

Potential risk: Statements are issued without meaningful consultation or follow-up action(s).

Proposed mitigation strategy: Duty-holders should ensure the public statement reflects meaningful engagement with Black communities and includes clear next steps and commitments to accountability. Duty-holders should also establish clear standards for meaningful engagement (e.g., early involvement, shared decision-making), and document how community input is leveraged. Duty-holders should ensure outreach to diverse Black communities (e.g., those differentiated by creed, place of origin, disability). Ongoing feedback mechanisms with Black communities (including students, staff, families, and community members) should be established to ensure accountability.

Action 2 – Education Duty Holders Must Develop a Communication Strategy to Acknowledge Anti-Black Racism and Discrimination in Education – Immediate (1–2 years)

Targeted duty-holder(s): All education duty-holders.

Indicator: Multimodal communication materials acknowledging anti-Black discrimination are co-developed with Black communities and publicly available.

Type of Indicator: Structural – communication strategies and accessibility policies that ensure multimodal dissemination across diverse Black communities.

Potential data sources: School board websites, newsletters, Ministry of Education websites, Faculties of Education websites. Quantitative and qualitative surveys, focus groups, consultation records, meeting minutes, community feedback forms, partnership agreements.

Timeline: Materials co-developed and distributed in multiple languages and formats within 2 years.

Human rights-based outcome: Black students, families, and communities report improved awareness of duty-holder commitments and greater access to information in formats that meet their needs. Black communities confirm meaningful engagement in the development of communication strategies and that their input influenced final materials.

Potential risk: Limited collaboration with Black communities, inaccessible communication formats, or consultations that do not meaningfully influence final materials, reduced trust.

Proposed mitigation strategy: Communication materials should be translated into the most commonly spoken languages within each school board and disseminated through multiple channels (online, print, and in-person), in compliance with accessibility standards such as the Accessibility for Ontarians with Disabilities Act (AODA). Duty-holders should establish clear standards for meaningful engagement (e.g., early involvement, shared decision-making), and document how community input shaped the strategy. Duty-holders should ensure outreach to diverse Black communities (e.g., those differentiated by creed, place of origin, disability).

Action 10 – Unions Must Establish an Accountability Framework for addressing the discrimination and harassment experienced by Black educators and addressing anti-Black racism when committed by members – Immediate (1–2 years)

Targeted duty-holder(s): unions (provincial, local level).

Indicator: Accountability frameworks include concrete enforcement mechanisms (e.g., investigation timelines, anti-reprisal safeguards, remedy procedures), to address anti-Black racism, discrimination and harassment experienced by Black union members.

Type of Indicator: Process – operationalization of enforcement mechanisms within accountability frameworks.

Potential data sources: Policy and framework documents, legal analysis, documentation of complaint procedures, union reporting on case management timelines.

Timeline: Frameworks to include enforcement mechanisms within 1–2 years, annual review thereafter.

Human rights-based outcome: Complaints of anti-Black discrimination and harassment are addressed through timely, fair, and proportionate processes, with safeguards against reprisal. Black members experience increased trust in union complaint and discipline processes.

Potential risk: Mechanisms are inconsistently applied. Members may experience reprisal which may discourage reporting.

Proposed mitigation strategy: Establish clear service standards (e.g., investigation timelines). Include anti-reprisal protections and confidential reporting options. Provide training for union leadership and representatives on anti-Black racism and trauma-informed approaches. Monitor and publicly report anonymized aggregate data on complaints and outcomes.

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)

Targeted duty-holder(s): Ministry of Citizenship and Multiculturalism (MCM), Government of Ontario.

Indicator: Anti-Racism Act Regulation 267/18 and data standard are amended to incorporate expanded variables, including Code and non-Code related grounds enabling duty-holders to collect, analyze and report standardized intersectional data effectively.

Type of Indicator: Structural – legal and regulatory amendments enacted and operational.

Potential data sources: Ontario Regulatory Registry, Hansard transcripts, ministry news release, technical data standards documentation.

Timeline: 6-12 months.

Human rights-based outcome: Enabling consistent monitoring of systemic anti-Black discrimination and harassment through a strengthened legislative basis for standardized Code and non-Code related intersectional data collection across public sector institutions.

Potential risk: Duty-holders may fail to collect and analyze necessary intersectional data, leading to ongoing gaps in identifying disproportionalities and addressing systemic barriers.

Proposed mitigation strategy: Implement phased amendments with clear timelines, cross-ministerial coordination, public consultation, and transparent reporting. Provide technical guidance and align implementation with privacy legislation.

Action 16 – Ministry of Education Must Centralize and Standardize Data Collection, Analysis, and Reporting – Immediate (1–2 years)

Targeted duty-holder(s): Ministry of Education.

Indicator: A centralized data infrastructure or reporting portal is established to support the collection, analysis and reporting of education data.

Type of Indicator: Structural – creation of centralized digital infrastructure for standardized data submission and reporting.

Potential data sources: Ministry announcements, budget documents, procurement records, public reporting portals.

Timeline: 18–24 months.

Human rights-based outcome: Strengthened provincial oversight and accountability on anti-Black discrimination and systemic barriers, reduced fragmentation in education data systems, improved comparability across boards.

Potential risk: Funding gaps, technological delays, inconsistent uptake by boards.

Proposed mitigation strategy: Allocate dedicated funding, implement phased roll-out, provide technical support, and establish mandatory reporting directives.

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

Targeted duty-holder(s): Ministry of Education, school boards, unions, Ontario College of Teachers.

Indicator: Complaints policies and procedures are reviewed and updated to include provisions addressing anti-Black racism.

Type of Indicator: Structural – formal review and revision of complaints policies and procedures.

Potential data sources: Board policy manuals, union governance documents, Ontario College of Teachers (OCT) compliance reviews, OCT governance documents, and publicly posted revised policies.

Timeline: Policy revisions completed within 1–2 years.

Human rights-based outcome: Clear and accessible complaint pathways address anti-Black discrimination and harassment and include safeguards against reprisal.

Potential risk: Procedures remain complex or inaccessible and staff lack training.

Proposed mitigation strategy: Consult Black educators when revising procedures; simplify complaint pathways using plain language; ensure multilingual access; and provide mandatory training for administrators.

Student Well-Being

Action 24 – Ministry of Education Must Monitor and Expand the Graduation Coach Program for Black Students – Immediate (1–2 years)

Targeted duty-holder(s): Ministry of Education, school boards.

Indicator: Black students report a stronger sense of belonging and greater confidence in planning their transitions to secondary and post-secondary pathways.

Type of Indicator: Outcome – student reported experiences of sense of belonging and preparedness.

Potential data sources: Student climate surveys, focus groups, Graduation Coach program evaluations, Statistics Canada student outcomes data.

Timeline: Baseline data collected prior to expansion, follow-up assessment within 2 years.

Human rights-based outcome: Black students report increased sense of belonging, academic confidence, and improved preparedness for secondary and post-secondary education, apprenticeships, or other employment pathways.

Potential risk: Low participation in surveys.

Proposed mitigation strategy: Use anonymous, culturally responsive survey tools, integrate qualitative feedback, track trends over time, triangulate findings with graduation and transition data.

Action 26 – School Boards Must Create Inclusive Guidance Counselling for Students’ Transitional Stages – Immediate (1–2 years)

Targeted duty-holder(s): School boards, Ministry of Education.

Indicator: Guidance protocols are updated to include explicit safeguards against anti-Black discrimination and inappropriate streaming practices.

Type of Indicator: Structural – revision of board policies, and counselling protocols.

Potential data sources: Policy manuals, professional development materials.

Timeline: Revisions approved within 1–2 years.

Human rights-based outcome: Guidance counselling promotes access to academic and post-secondary pathways.

Potential risk: Protocol changes remain symbolic without monitoring.

Proposed mitigation strategy: Provide staff training, conduct audits of course selection patterns, and require oversight when disparities persist.

Action 29 – Education Duty-Holders Must Develop Targeted Recruitment of Black Educators and Education Workers – Immediate (1–2 years)

Targeted duty-holder(s): School boards, Ministry of Education.

Indicator: Targeted recruitment and hiring initiatives are established to strengthen the recruitment and progression of Black candidates throughout the hiring process.

Type of indicator: Process – disaggregated monitoring of recruitment and promotion pipelines.

Potential data sources: Workforce demographic reports, climate surveys.

Timeline: Data collection initiated within 12 months, annual reporting thereafter.

Human rights-based outcome: Barriers within hiring and promotion processes are identified and addressed.

Potential risk: Incomplete self-identification data, and privacy concerns.

Proposed mitigation strategy: Implement voluntary confidential self-identification processes and standardized reporting frameworks.

Appendix B: Glossary of Terms

Term	Definition
Data collection	The OHRC interprets the term data collection broadly to include gathering information using both quantitative research methods such as surveys, and qualitative research methods such as focus groups.
Data sources	Forms of evidence used to measure indicators (e.g., school board administrative data, surveys of Black students and families, community consultations, disaggregated data reports, external audits).
Direct discrimination	A person discriminates directly when the action itself is discriminatory and when the person acts on his or her own behalf. For example, a building manager who refuses to rent an apartment because he prefers to rent to someone of his own ethnic background is discriminating directly.
Disaggregated data	Disaggregated data is data that provides subcategories of information, for example by ethnic group, gender, occupation, or educational status. Sometimes this is called demographic data. Unlike aggregated data, which groups information together, disaggregated data can reveal inequalities and relationships between categories.
Education duty-holders	Education duty-holders are duty-holders employed or elected within the education system that have the obligation to respect, protect, promote and fulfill the human rights of rights-holders.
Equality/Substantive equality	Equality under the Canadian Charter of Rights and Freedoms and the Ontario Human Rights Code means substantive equality. Substantive equality is concerned with ensuring that people have the freedom and equal opportunity to fully participate in society. Substantive equality takes into account the full social context of the individual in assessing the effects that laws, policies, programs or conduct may have on them. That social context may include a variety of factors, including the individual’s experiences as a member of a historically marginalized group.
Human rights-based outcome	Intended change that aligns with duty-holders’ legal obligations under the Code.
Harassment	Engaging in a course of vexatious comments or conduct that is known or ought reasonably to be known to be unwelcome.
Indicator	A clear, observable, and measurable sign of change or progress.
Indirect discrimination	Indirect discrimination is discrimination carried out through another person or organization. For example, a building manager tells her superintendent not to rent to people of a certain ethnic group because their food smells too much. The manager can be named in the human rights claim because she used the superintendent indirectly to discriminate against people because of their ethnic origin.
Intersecting Intersectional Intersectionality	A framework or approach that considers how someone’s identification with more than one Code-protected ground or characteristic can result in unique or compounded barriers or discrimination (for example, how a student’s First Nations, Métis or Inuit identity, race, gender, socioeconomic status, being a newcomer, refugee, English-language learner or being in the child welfare system, can combine with a reading disability to create unique and overlapping experiences of disadvantage and discrimination).
Non-Code data	A category of data that is not listed as a Code ground (e.g., education/qualification level, role/position title, years of service, perceptions of well-being and belonging, graduation rates, suspension, expulsion or exclusion rates, academic achievement, Education Quality and Accountability Office (EQAO) results).
Non-discrimination	Non-discrimination refers to the principle of ensuring equal rights and opportunities for all individuals without discrimination based on seventeen Code grounds in five social areas. This principle aims to ensure that all individuals feel included, valued, able to fully participate in and contribute to the well-being and development of their communities and Ontario.
Outcomes data	Outcome data are qualitative and quantitative information that measure the extent to which initiatives have resulted in meaningful changes in the experiences, opportunities, and outcomes of affected communities. Outcomes data can be used to assess whether initiatives are reducing systemic discrimination and advancing substantive equality.
Outcomes indicators	Outcome indicators measure real-world outcomes and lived experiences of affected communities regarding their enjoyment of rights.
Poisoned work environment	A negative, hostile or unpleasant workplace due to comments or conduct that tend to demean a group identified by one or more prohibited grounds under the Code, even if not directed at a specific individual. A poisoned work environment may result from a serious single event, remark or action. While the notion of a poisoned environment has predominantly arisen in an employment context, it can specifically arise in the context of education services.
Potential risk	The harm or setbacks that can occur when duty-holders do not take action or fail to measure progress properly.
Process indicators	Process indicators measure the efforts and actions taken (e.g., programs, enforcement mechanisms, reforms).
Prohibited/protected grounds	The Ontario Human Rights Code prohibits discrimination or harassment based on these personal characteristics. The specific protected grounds include age, ancestry, citizenship, colour, creed, disability, ethnic origin, family status, gender identity and gender expression (recently added to the Code), marital status, place of origin, race, sex (including pregnancy), sexual orientation, receipt of public assistance (in housing) and record of offences (in employment).
Protected social grounds	The Code guarantees equal treatment and opportunities without discrimination in five social areas: employment, housing, services, contracts, and membership in vocational associations.
Proposed mitigation strategy	Specific, practical steps duty-holders can take to reduce or prevent the potential risks
Reprisal	An action or threat that is intended as retaliation for claiming, enforcing or refusing to infringe a right under the Code.
Rights-holders	All people are rights-holders. These include members of groups that are protected under Ontario’s Human Rights Code: people who may face discrimination based on age, ancestry, citizenship, colour, creed, disability, ethnic origin, family status, gender identity, gender expression, marital status, place of origin, race, receipt of public assistance (in housing only), record of offences (in employment only), sex and sexual orientation.
Subtle discrimination	Discrimination is often subtle. Discriminatory remarks are not often made directly, and people do not usually voice stereotypical views as a reason for their behaviour. Subtle forms of discrimination can usually only be detected after looking at all the circumstances to determine if a pattern of behaviour exists. Individual acts themselves may be ambiguous or explained away, but when viewed as part of a larger picture, may lead to an inference that discrimination based on a Code ground was a factor in the treatment a person received. An inexplicable departure from usual practices may establish a claim of discrimination.
Structural indicators	Structural indicators measure the commitment of a government or institution to human rights standards through the adoption of international treaties, constitutional provisions, or legislative and policy frameworks.
Systemic or institutional discrimination	Systemic or institutional discrimination consists of attitudes, patterns of behaviour, policies or practices that are part of the social or administrative structures of an organization, and that create or perpetuate a position of relative disadvantage for individuals protected on the basis of Code grounds. The attitudes, behaviour, policies or practices may appear neutral on the surface but nevertheless have an adverse effect or exclusionary impact. While it often occurs without deliberate intent, systemic discrimination can also overlap with or involve more overt types of discriminatory behaviour.
Vicarious liability	Under section 46.3 of the Code, a corporation, trade union or occupational association, unincorporated association or employers’ organization will be held responsible for discrimination, including acts or omissions, committed by employees or agents in the course of their employment. This is known as vicarious liability. It applies not only to human rights violations in the workplace, but also in housing accommodation, goods, services and facilities, contracting, and membership in unions and vocational associations. Simply put, it is the Commission’s position that vicarious liability automatically attributes responsibility for discrimination to an organization for the acts of its employees or agents, done in the normal course, whether it had any knowledge of, participation in, or control over these actions.

Appendix C: Dreams Delayed Calls to Action

Appendix C: Dreams Delayed Calls to Action - Accountability and Transparency

Appendix C: Dreams Delayed Calls to Action
Accountability and Transparency

Action 1 – Education Duty-Holders Must Acknowledge and Commit/Pledge to Action on Anti-Black Racism and Discrimination in Education – Immediate (1–2 years)

All levels of the education system, including school boards, schools, unions, and Faculties of Education must make a clear, formal, and public acknowledgement of the structural and systemic nature of anti-Black discrimination and its impact on Black students and Black education staff’s right to an education and work environment free from discrimination and harassment. Further, duty-holders must recognize that systemic anti-Black racism is at the root of the tacit acceptance of the ongoing discriminatory practices pervasive throughout Ontario’s publicly funded education system.

Duty-holders must also work with Black communities to establish and implement measurable plans and initiatives (e.g., human rights and anti-discrimination frameworks, human rights indicators and evaluations, targeted supports with impact evaluations) to address and report on anti-Black racism and discrimination.^[12]

Action 2 – Education Duty Holders Must Develop a Communication Strategy to Acknowledge Anti-Black Racism and Discrimination in Education – Immediate (1–2 years)

The OHRC calls on all levels of the education system, including school boards, trustees, schools, unions, and Faculties of Education to clearly communicate their acknowledgement of anti-Black racism and discrimination in education.

In collaboration with students, parents/guardians, and the community, school boards must adopt multi-modal and multilingual approaches to ensure the acknowledgement and associated action plan reach the whole student population and their families.

Action 3 – The Ministry of Education Must Create a Provincial Framework to Address Human Rights and Anti-Black Discrimination – Immediate (1–2 years)

The OHRC calls on the Ministry of Education to create a provincial policy and impact framework to address discrimination and harassment in Ontario’s education system. This should include specific measures to combat anti-Black discrimination and harassment including addressing gaps in responsiveness and accountability through mechanisms to verify performance impact and improvement.

The Framework must include:

A Multi-Year Plan (MYP) for sustainable expansion of resources and programs created to address anti-Black racism and discrimination.
Goals and outcomes pertaining to the hiring, promotion, and retention of Black educators and education workers, and employment systems review process.
An independent and comprehensive evaluation of the framework to determine effectiveness and potential improvements.
A commitment from leadership at all levels of administration, including trustees, to drive systemic change and accountability.
Training and support for leaders to effectively implement accountability measures specific to addressing racial discrimination with particular focus on anti-Black racism.
Accountability measures for data governance.
Accountability and enforcement measures for intervening in instances of racial harassment and discrimination.
Clear guidelines for reporting and addressing human rights violations with transparent lines of authority for roles, responsibilities, and functions.
Transparent and accessible complaints process for students, educators, education workers, parents, and community members.

Action 4 – The Ministry of Education Must Develop a Communication Strategy for the Accountability Framework – Immediate (1–2 years)

The OHRC calls on the Ministry of Education to develop a communication strategy for the provincial framework to address human rights and anti-Black discrimination and harassment referenced in Action 3.

The communication strategy must:

Incorporate multi-modal and multilingual approaches to ensure rights-holders can access the information.
Include a multi-year plan with clearly defined outcomes.
Include a timeframe for compliance reporting.
Be community-informed and trauma-informed.
Be publicly available.

Action 5 – The Ministry of Education Must Review the Policy and Protocol of PPMs – Immediate (1–2 years)

While the Minister of Education has the authority under the Education Act (s. 8(1)(29.1)) to require school boards to develop and implement equity and inclusive education policies, the Ministry must ensure these policies are strengthened to explicitly align with human rights and anti-discrimination principles.

Updated policies should provide clear, mandatory guidance for school boards and ensure alignment with the provincial framework on human rights and anti-discrimination (see Action 3).

The Ministry of Education must:

Embed human rights principles into relevant policy and program memorandums to ensure compliance with the Code.
Conduct a review of PPM 119 and Developing and Implementing Equity and Inclusive Education Policies in Ontario Schools (June 24, 2009) to align it with human rights and anti-discrimination principles and the Anti-Racism Act (2017) and the Anti-Racism Data Standards (2018).
Establish a separate PPM to address anti-Black discrimination with detailed guidelines and actions to combat anti-Black racism at all levels of the education system.
Establish clear mechanisms for oversight and enforcement of the policy, with clearly delineated roles, functions, and responsibilities.
Establish standards for human rights knowledge and anti-racism to be included in teacher qualifications.

Action 6 – The Ministry of Education Must Communicate Policy and Procedure Updates – Immediate (1–2 years)

The OHRC calls on the Ministry of Education to communicate to school boards, unions, and rights-holders about their policy reviews updates and to consult with school boards to establish the most effective manner of communication.

The Ministry of Education must:

Provide rights-holders an overview of process;
Provide a completion timeframe;
Provide a publicly published update and incorporate multi-modal and multilingual approaches to ensure rights-holders have access to information.

Action 7 – The Ministry of Education Must Establish a Threshold for Independent Intervention for Code violations – Immediate (1–2 years)

The OHRC calls on the Ministry of Education to establish a clear threshold for when it will engage an independent reviewer to address serious or ongoing allegations of anti-Black racism within a school board. This threshold should be defined to ensure that any organization consistently violating the Ontario Human Rights Code faces appropriate remedial measures to address and rectify systemic issues. The threshold criteria must be developed in consultation with external experts who have a demonstrated competence in human rights and in addressing anti-Black racism. School boards must be able to demonstrate that they comply with all legal obligations.

The Ministry of Education must:

Develop a clear and measurable threshold to address serious or repeated instances of racism and discrimination within a school board, with the authority to engage an independent reviewer. The threshold should consider the frequency and severity of the racism and discrimination, and its impact on students, families, school, and community. The threshold should be developed in consultation with external experts who have a demonstrated competence in human rights and in addressing anti-Black racism.
Provide preventive support, including policy development and regular audits to school boards to ensure educators, principals, and senior leadership uphold and advance human rights principles.
Ensure any investigator involved in reviewing and addressing human rights issues, including from trustees and student trustees, has extensive knowledge and experience in human rights.

Action 8 – School Boards Must Communicate Roles and Responsibilities Related to Human Rights – Immediate (1–2 years)

The OHRC calls on school boards to establish greater clarity of roles, responsibilities, qualifications, standards, and legal obligations of duty-holders (including but not limited to those with human rights portfolios) under the Ontario Human Rights Code and to clearly communicate these to the community.

Action 9 – Faculties of Education Must Establish an Accountability Framework for Increased Diversity of Teacher Candidates with Particular Attention to Increasing the Number of Black Educators – Immediate (1–2 years)

The OHRC calls on Faculties of Education to create and implement an internal human rights accountability framework to address anti-Black discrimination and harassment in education.

Faculties of Education must:

Increase the diversity in teacher candidates through targeted recruitment.
Secure a commitment to the framework from leadership at all levels within faculties.
Provide training and support for leaders to effectively engage with and implement the accountability measures.
Establish a comprehensive evaluation process with specific timelines to determine compliance and effectiveness of the framework.
Establish assessments to measure the impact of courses on aspiring educators and their practice.

Action 10 – Unions Must Establish an Accountability Framework for Addressing the Discrimination and Harassment Experienced by Black Educators and Addressing Anti-Black Racism when Committed by Members – Immediate (1–2 years)

The OHRC calls on unions to establish and implement an internal human rights accountability framework to address anti-Black discrimination and harassment in education.

Unions must:

Create an accountability framework that includes clear guidelines on and timelines for reporting and addressing human rights violations, including anti-Black discrimination and harassment, with transparent roles, responsibilities, and functions.
Develop and implement accountability procedures for local union branches to investigate complaints of discrimination and harassment, including from Black educators and education workers.
Hold members accountable for human rights violations, including anti-Black racism and harassment, and leadership for addressing complaints of discrimination or harassment from Black educators and education workers.
Identify and implement transparent processes for reporting, investigating and following up on instances of anti-Black discrimination, harassment, and poisoned work environment. Unions have legal obligations under labour law to investigate complaints or potential grievances for merit. Where systemic patterns of anti-Black racism are identified within local unions, national branches have an obligation under the Code to establish processes to investigate and address these issues, including conducting reviews to ensure fair representation of Black members. Where possible, these investigations should be conducted by an independent investigator.
Ensure all processes (e.g., grievance, arbitration) include a human rights lens.
Integrate and implement human rights language, including discrimination and harassment into constitutions, by-laws, and collective agreements.
Develop transparent and accessible complaints mechanisms for educators and education workers, including how they hold employers accountable and establishing a clear process for addressing discrimination between members.
Establish a comprehensive evaluation process with specific timeframes to determine compliance and effectiveness of the framework.
Secure commitment to the framework from leadership at all levels within the union to drive systemic change.
Provide training and support for leaders to effectively implement accountability measures.
Establish a centrally administered complaints system to investigate external complaints against members.

Action 11 – Unions Must Establish a Communication Strategy for an Accountability Framework and Monitoring Framework – Immediate (1–2 years)

The OHRC calls on unions to establish a clear communication strategy to inform members of the accountability framework.

A communication strategy must be:

Developed in partnership with Black members.
Circulated to all local levels.
Made accessible online and regularly updated.

Action 12 – The Ontario College of Teachers Must Enhance Capacity on Anti-Black Racism and Discrimination – Immediate (1–2 years)

The OHRC calls on the Ontario College of Teachers (OCT) to work with education partners to improve public awareness and access to its publicly available information about disciplinary processes, increase its capacity to investigate incidents of anti-Black discrimination, and improve standards of practice regarding racism, discrimination and culturally responsive pedagogy.

OCT must:

Review standards of practice regarding racism, discrimination and culturally responsive pedagogy.
Create a mechanism to track complaints filed at the school board level that may also amount to professional misconduct.
Explore ways to collaborate with other duty-holders to increase public awareness of publicly available information.
Hire staff who have demonstrated knowledge and experience in investigating anti-Black racism, discrimination, and harassment.
Work with Faculties of Education and school boards to increase educator engagement in anti-Black racism Additional Qualifications.

Action 13 – School Boards Must Establish a Human Rights Office in Each School Board – Intermediate (3–5 years)

The OHRC calls on each school board to establish a central office to implement human rights policies and investigate human rights complaints from students and staff under the Code, such as discrimination, harassment, and poisoned environments, including anti-Black racism, and to develop human rights capacity within the board.

The Human Rights office must be established in collaboration with the community and supported by the Ministry of Education and the school board.

The Human Rights Office must:

House Human Rights and Equity Advisors.
Respond promptly to incidents of discrimination.
Be empowered to create accountability measures for board directors and school principals for human rights incidents.
Assist students, parents, and communities facing discrimination and harassment to access information, navigate school systems and effectively advocate for students.

The Ministry of Education must:

Empower and resource school boards to establish human rights offices, which will engage and collaborate with community groups and stakeholders, collect and report data as per the Provincial Framework (Action 3), and investigate complaints.

Action 14 – School Boards Must Develop Culturally Competent Communication Plans for Student and Family Engagement – Intermediate (3–5 years)

The OHRC calls on all school boards to partner with School and Family Advocates (SFA) or System Navigators to develop culturally competent communication plans to inform and engage parents and students at critical points in the educational transitions to improve their understanding of education pathways and opportunities.

School boards must:

Collaborate with students, parents, and communities to establish multi-modal and multilingual approaches to targeted and effective communication, including:
1. Create a communication plan for parents/guardians and families about the transition from Grade 8 to Grade 9, and other significant decisions taking place in grades 1 to 6.
2. Create a communication plan for parents and families about the transition to post-secondary school.
Collaborate with parents/guardians of Black students and Student and Family Advocates to develop culturally relevant education and support services. These services should provide meaningful support to parents/guardians within/from diverse communities.

Appendix C: Dreams Delayed Calls to Action - Monitoring and Evaluation

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:

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.
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.
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.
Create resources for school boards on stakeholder partnerships for the data collection, analysis, action planning and monitoring processes.
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:

Review EQAO to include race-based data collection.
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.
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.
Equip school boards with expert resources to monitor consistency in the collection, quality, and analysis of their data.
Work with the OCT to collect and publicly report data on the racial composition of the education professional body.
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.
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.
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]
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:

Develop and implement an outcomes monitoring framework with indicators measuring progress and achievement on anti-discrimination.
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.
Identify disparities, create approaches to address them and identify remedial measures for lack of compliance.
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.
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:

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.
Develop a robust human rights monitoring framework to track progress on implementing recommendations.
Evaluate and strengthen existing data governance frameworks within the public education system to ensure compliance with privacy laws and ethical guidelines.
With guidance from the Information and Privacy Commission of Ontario, implement protocols for secure data storage, access, and sharing among relevant stakeholders.
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.
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.
Ensure an intersectional analysis is incorporated into existing and new data related recommendations to understand how vulnerable students are affected.
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.
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.
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.
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:

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

The Ministry of Education must:

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.
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:

Develop and implement an EIS for school boards to prevent racial and other Code-based discrimination and harassment by administrators, educators, or education workers.
Ensure the EIS aligns with leading practices for data collection, privacy protection, and fairness in monitoring potential misconduct.
Integrate Code-based data into the EIS to effectively monitor and analyze incidents of discrimination and harassment.
Develop procedures to capture and assess data on behaviors or incidents of anti-Black discrimination and harassment.
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.
Use data to publicly report on the effectiveness of school boards preventing racial discrimination and harassment using EIS.

School boards must:

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

Appendix C: Dreams Delayed Calls to Action - Student Well-Being

Appendix C: Dreams Delayed Calls to Action
Student Well-Being

Action 24 – The Ministry of Education Must Monitor and Expand the Graduation Coach Program for Black Students – Immediate (1–2 years)

The OHRC calls on the Ministry of Education to increase provincial investment in the Graduation Coach Program for Black Students across school boards. In addition, the OHRC encourages expanding the program to all school boards and schools in proportion to the local student population.

The Ministry of Education must:

Allocate ongoing funding and resources to expand the graduation coach program for Black students.
Work with educators, students, and community organizations to establish program standards and guidelines for graduation coach programs across the province including hiring qualified coaches.
Mandate school boards to collect and report on comprehensive data, including disaggregated data on an annual basis on the number of participants, academic achievements, graduation rates, and post-secondary placements for all participants in graduation coach programs.
Monitor implementation of the graduation coach program across Ontario and conduct periodic evaluations of the program for effectiveness and changes.
Include data in the Ministry of Education’s centralized data repositories for analysis and public reporting.

Action 25 – Education Duty-Holders Must Expand the Student and Family Advocates (SFA) / System Navigator Program – Immediate (1–2 years)

The OHRC calls on the Ministry of Education to partner with the Ministry of Citizenship and Multiculturalism (MCM), the Ministry of Children, Community and Social Services (MCCSS), and the Ministry of Francophone Affairs (MFA) to fund the expansion of the Student and Family Advocates (SFA) program provincially with added responsibility to engage parents/guardians and caregivers of Black students to help them navigate the education system to advocate for their children. Data from SFA programs should be shared with the Ministry of Education.

This will foster stronger partnerships between schools and families of Black students, enhance student support, improve educational outcomes, and promote a more inclusive and equitable learning environment for Black students across the education system.

The Ministry of Education must:

Work with the MCM, MCCSS, and MFA through the Black Youth Action Plan and Youth Opportunities Fund to allow system navigators at the elementary and secondary schools levels to provide supports, including mentorship, tutoring, mental health support, and career guidance to Black students.

School boards must:

Develop tailored strategies to support Black families to navigate the education system in culturally sensitive ways, including:
1. Foster partnerships with community organizations and cultural groups to provide additional support and resources to Black families.
2. Conduct regular evaluations and gather feedback from parents and communities to assess the clarity, accessibility, and relevance of communicated information.
Develop processes which enable Black families to work with the SFA program for Black communities through targeted outreach and communication.
Strengthen supports for parent involvement committees to broaden community participation and balance representation based on demographics.

Action 26 – School Boards Must Create Inclusive Guidance Counselling for Students’ Transitional Stages – Immediate (1–2 years)

The OHRC calls on school boards to include parents/guardians and their children in the guidance counselling process when students reach grades 8 and 9. The transition into secondary school and the educational pathway selected in Grade 9 can significantly influence students’ opportunities. While de-streaming is ongoing, students and their parents/guardians would continue to benefit from understanding the different streams (e.g., academic for university, applied for college and trades, essential for the workforce directly after high school). Including parents in targeted guidance counselling will enhance educators’ accountability to students and parents/guardians during these educational transitional stages.

Action 27 – School Boards Must Create Affirmative Education Spaces for Black Students – Immediate (1–2 years)

The OHRC calls on school boards to create affirming educational spaces that respect all Black students’ intersecting identities.

School boards must:

Create inclusive school policies and practices that celebrate and validate Black students’ intersecting identities within the school community, including, but not limited to, dedicated spaces for gathering and support.
Foster a school climate that promotes respect, understanding, and appreciation for diversity among students and staff.

Action 28 – Education Duty-Holders Must Create Black Affirming and Empowering Curriculum – Immediate (1–2 years)

Representation in the curriculum is important to create an increased and sustained inclusive, non-discriminatory learning environment that imparts the richness of Ontario’s communities to all students. A shift in curriculum development to intentionally incorporate Black history and Black experiences is essential to creating a positive learning environment for Black students. The Ministry of Education, school boards, and unions should support educators in learning and teaching culturally responsive curricula.

Faculties of Education, OCT, unions, and school boards should build capacity within the curriculum for student educators and educators to develop the skills and competencies they need to teach about Black intersecting identities and to address discrimination.

The Ministry of Education must:

Ensure representation of Black intersectional identities in curriculum materials, textbooks, and supplementary resources.
Develop and disseminate culturally responsive teaching resources that reflect the diversity of Black experiences, identities, and histories.
Provide access to supplementary materials and tools that educators can use to enhance classroom discussions on intersectionality and diversity.
In collaboration with Black communities, parents, and community organizations, research and integrate diverse Black narratives, histories, and contributions in the K to 12 curricula as core subject disciplines.

School boards must:

In partnership with OCT and unions, implement mandatory professional development programs for educators on culturally responsive teaching practices.
Partner with Black students, parents, community organizations and educators to assess the impact of curriculum transformation on learning experiences and educational outcomes.

Action 29 – Education Duty-Holders Must Develop Targeted Recruitment of Black Educators and Education Workers – Immediate (1–2 years)

The OHRC calls on school boards to actively increase the diversity of leaders within the education system, specifically by including Black persons with lived experiences of discrimination. This approach will enable Ontario’s public education system to more effectively respond to the needs of all students, especially Black students.

School boards must:

Develop targeted recruitment strategies to attract Black educators, educational workers, and staff.
Establish networks and communities of practice where educators, administrators, and school staff can share knowledge, experiences, and resources related to creating safe and welcoming environments for Black students.
Promote diversity throughout the education system, including educators, educational assistants, social workers, guidance counsellors, office staff, vice-principals, principals, and superintendents.
Implement targeted initiatives to recruit and retain Black educators in Northern Ontario, considering the unique challenges of geographic isolation, limited resources, and lack of supportive networks.
Provide additional support and resources to ensure that Black educators in Northern Ontario can thrive and contribute effectively to creating inclusive and positive educational environments.
Incentivize educators in completing Additional Qualification courses in the areas of culturally responsive pedagogy, anti-racist pedagogy, trauma-informed pedagogy and supporting student well-being.
Develop targeted strategies to ensure a pipeline of Black education leaders (including school and system leaders).
Develop and implement strategies that are responsive to concerns about discrimination and harassment from Black leaders.

Faculties of Education must:

Develop targeted recruitment and retention policies/strategies to attract Black educators, educational workers, and staff.

The Ministry of Education must:

Review all hiring and promotion policies to identify and eliminate systemic barriers and biases.
Require each school board to undergo a streamlined comprehensive employment systems review process and provide a report to the Ministry.

Ontario College of Teachers must:

Offer targeted professional development opportunities focused on cultural awareness and culturally relevant or culturally responsive teaching, anti-racism education, trauma-informed practices, and supporting Black student well-being.
Identify baseline training that is mandatory for graduation.

Collaborative Actions:

School boards and Faculties of Education must increase diversity in leadership positions.
School boards, in partnership with Faculties of Education, should develop and implement outreach programs to encourage Black students to pursue careers in education. Resources should be allocated to provide support throughout potential students’ educational journeys (e.g., entrance scholarship and bursary).
The Ministry of Education, in partnership with stakeholders, should develop a standard hiring and promotion policy or guide to ensure equitable access to leadership positions.
In partnership with unions, school boards and the Ministry of Education must establish and enforce policies and practices that create safe, inclusive, and supporting working environments for Black educators and staff. Policies addressing Code-based discrimination and harassment, including a poisoned environment must be updated and publicly reported to all members.
School boards and unions should establish mentorship programs, professional development opportunities, and career advancement pathways to support the career growth and engagement of Black staff members.
OCT should improve offerings of targeted professional development opportunities focused on culturally responsive teaching, anti-racism education, trauma-informed practices, and supporting Black student well-being. School boards should incentivize educators in completing Additional Qualification courses in these areas.

Appendix D: OHRC resources and tools

Appendix E: Long descriptions of alternative text

Cover image:

Dreams Delayed Guide on Monitoring and Evaluation: Towards Achieving Outcomes in Ontario's Public Education System. Illustration imagining the outcomes of implementing the Dreams Delayed Calls to Action, including greater representation among Black educators, increased support for STEAM learning pathways, accessible and inclusive learning environments, and improved educational outcomes from early childhood through graduation and post-secondary education. Illustration with multiple images: an adult sitting on the floor playing with toys with two children; an adult sitting on a chair, reading from an open book with two middle-grade children with backpacks nearby; three people standing together, one in a wheelchair playing the trumpet, one holding a paintbrush, and one watching two youth in graduation caps and gowns; and two adults in lab coats at a table with microscopes.

Image 1:

Illustration of two Black children sitting on the floor playing together with toys and building blocks. One child wears a light-coloured dress while another wears a short-sleeved shirt and shorts.

Image 2:

Illustration of a Black educator seated in a chair reading from an open book to two young Black children seated nearby. The children are listening while seated on small chairs.

Image 3:

Illustration of three people participating in creative activities together. One person seated in a wheelchair plays a trumpet, another holds a paintbrush, and a third stands nearby. The image represents participation in the arts.

Image 4:

Illustration of two Black students conducting a science experiment at a laboratory table. One student looks through a microscope while the other holds a flask containing liquid. Test tubes and other laboratory equipment are arranged on the table, representing participation in science, technology, engineering, and mathematics (STEM) learning.

Image 5:

Illustration of a community consultation session facilitated by an education duty-holder. Members of Black communities are gathered around a table discussing documents and sharing input, while a facilitator speaks at a podium. A presentation screen displays “Community Consultation Session.” The image represents inclusive engagement with Black students, staff, families, and community organizations to identify needs, address policy gaps, and co-design solutions.

Image 6:

Illustration of two Black students celebrating graduation. One holds a diploma overhead. The other holds a certificate. The image represents positive educational outcomes and achievement for Black students.

Image 7:

Illustration of a community outcomes review session involving education duty-holders and Black community members. Participants review data and discuss findings to assess progress toward substantive equality, identify barriers, and inform corrective actions and future improvements. A presentation screen displays “Community Outcomes Review.” Charts and evaluation materials are displayed throughout the meeting space.

Figure 1:

Diagram titled “Applying the HRBA Framework” showing a continuous, iterative Human Rights-Based Approach cycle. Seven stages are arranged in a circular sequence:

Stage one: Context analysis—identify the human rights context of the initiative;
Stage two: Undertaking research & analysis—research and analysis reflecting human rights obligations;
Stage three: Planning engagement—work with impacted communities on engagement;
Stage four: Developing options & recommendations—develop rights-responsive options from research and engagement;
Stage five: Seeking approvals—secure decision-maker approval on human rights obligations;
Stage six: Implementing programs & services—deliver the initiative with human rights upheld; and
Stage seven: Monitoring & evaluation—assess the human rights impacts of the initiative.

A central circular graphic labels the Human Rights-Based Approach as a continuous, iterative cycle.

Figure 2:

Flowchart titled “Appendix A: Sample indicators and metrics” showing the components of a human rights-based monitoring framework. The vertical sequence moves through the following titles:

Action (the commitment or call to action being measured),
Targeted duty-holder(s) (who is responsible for the action),
Indicator (the specific measurable used to assess progress),
Type of indicator (structural, process, or outcome),
Data sources (such as surveys, administrative data, reports, and complaints data),
Timeline (when progress is expected),
Human rights outcome (the intended long-term impact),
Potential risk (factors that could undermine success), and
Proposed mitigation strategy (actions to reduce or manage risks).

Arrows connect each step, illustrating the process for developing and evaluating indicators.

Endnotes

[1] Ontario Human Rights Code, R.S.O. 1990, c. H. 19, s. 8.

[2] Section 30 of the Code gives the OHRC the authority to approve policies to provide guidance on the application of Parts I and II of the Code. Ontario Human Rights Code, R.S.O. 1990, c. H 19, s.30.

[3] Section 31 of the Code details the OHRC’s authority to conduct public interest inquiries, including the entering of premises, requesting documents, and interviewing individuals, to investigate potential human rights concerns. The OHRC may appoint individuals to carry out these inquiries, and evidence gathered during an inquiry can be used in proceedings before the Human Rights Tribunal of Ontario (HRTO). Subsection 31(7) outlines the powers the appointed individuals have when conducting an inquiry. Ontario Human Rights Code, R.S.O. 1990 c. H.19, s.31.

[4] The OHRC’s functions and powers include but are not limited to:

Promote and advance respect for human rights in Ontario;
Protect human rights in Ontario;
Identify and promote the elimination of discriminatory practices and make recommendations to prevent and eliminate them;
Examine and review legislation, regulations, programs, and policies to identify and recommend changes to those that may be inconsistent with the Code;
Support and encourage public, municipal, or private organizations and individuals to engage in initiatives that alleviate human rights related tensions and conflicts;
Undertake public inquiries; and
Initiate and intervene in HRTO applications.

To read the specific functions of the Commission, see section 29 of the Ontario Human Rights Code, R.S.O. 1990, c. H. 19.

[5] A strong sense of belonging in youth is associated with positive health outcomes which in turn support positive social, and development pathways into adulthood. According to Statistics Canada, 96% of youth with a strong sense of belonging also reported being in good physical health, 86% reported positive mental health, 60% reported a high life satisfaction and 77% reported a positive future outlook. By comparison, 87% of youth with a weaker sense of belonging reported being in good physical health, 59% reported positive mental health, 29% reported a high life satisfaction and 44% reported a positive future outlook. Helen Foran, “Community and well-being: Exploring sense of belonging among youth” (29 Oct. 2025)

[6] The Code may not impose a legal duty to report or demonstrate progress; however, this work often emerges contextually, particularly when a duty-holder knows, or ought to know, that systemic discrimination may be present. Where systemic discrimination may be present, duty-holders are expected to take steps to eliminate it. They are then expected to evaluate the impact of their efforts to address and mitigate further discriminatory practices.

[7] Ontario Certified Teachers must adhere to two professional standards as members of the Ontario College of Teachers (OCT). The Ethical Standards for the Teaching Profession, which is grounded in care, respect, trust, and integrity. The Standards of Practice for the Teaching Profession outline the knowledge, skills, and values guiding professional practice.

[8] Ontario Human Rights Commission, “Policy and guidelines on discrimination because of family status: VII Organizational responsibilities” (28 March 2007)

[9] The Office of the High Commissioner for Human Rights. “Human Rights Indicators: A Guide to Measurement and Implementation” (01 Jan. 2012)

[10] Ibid.

[11] Ibid.

[12] Ontario Human Rights Commission, “Human Rights Based Approach Framework” (11 Oct. 2023)

[13] Employee survey should cover a wide range of workplace topics, including but not limited to, staffing practices, respectful environment, professional development, teamwork, tools and workspace, stress and workload, pay and benefits, recognition, job suitability, empowerment etc. See British Columbia Public Service (BCPS) Work Environment Survey for general background on employee engagement surveys), British Columbia Public Service (BCPS) “Work Environment Survey (WES)” (20 Sept. 2024)

[14] For an example of data gathered from an employment equity assessment see the BC Public Service (BCPS) Workforce Profiles Dashboard. The information from the Dashboard helps the BCPS make evidence-based decisions towards equitable treatment in hiring, training and promotion see British Columbia, “Workforce Profiles” (2024)

[15] OHRC, “Policy and Guidelines on Racism and Racial Discrimination” (9 June 2005)

Rêves repoussés : Guide de suivi et d’évaluation – Mise en place d’un cadre axé sur les résultats dans le système d’éducation publique de l’Ontario