Secretary of Cabinet
Whitney Block Rm 6420
99 Wellesley St. W
Toronto, ON M7A 1L2
Dear Secretary Davidson:
Thank you for your letter dated July 26, 2019, and for meeting with the Ontario Human Rights Commission (OHRC) on September 17 to discuss the government’s efforts to address systemic anti-Black racism in the OPS. In addition to our meetings with your office, the OHRC has met with the Black OPS employee network (BOPSers), as well as with individual employees with personal experiences of anti-Black racism in the OPS.
As we discussed, the OHRC has serious concerns about systemic racism in the OPS and in particular anti-Black racism. In light of these concerns, we are encouraged by your efforts to foster greater accountability for systemic discrimination and to incentivise leadership diversification. We are also pleased that you will be tracking your progress through quantitative data. Your clear commitments and communications to the entire OPS will be assets as you continue this important and urgent work.
Independent third-party review of the WDHP
The OHRC is pleased that you have committed to retaining an independent third party to conduct a review of the Workplace Discrimination and Harassment Policy (WDHP). As you know, over the past 10 years, the OHRC has repeatedly noted that the WDHP process is not effective for addressing systemic discrimination and has recommended various amendments to the policy and process.
An independent third-party review of the WDHP is an important step towards addressing systemic discrimination in the OPS and building trust with Indigenous, Black and racialized employees. As discussed, the third-party reviewer should have expertise in systemic discrimination, anti-racism and anti-Black racism, and an expert advisory group should be convened to retain this important focus. Once a reviewer has been retained, the OHRC would be pleased to meet with them as part of the process.
This OHRC is also encouraged by your continued commitment to leadership diversification. We are pleased that your commitment includes setting annual goals, tracking success and creating incentives for senior leaders, including Assistant Deputy Ministers and Deputy Ministers, to commit to this strategy.
As you track the OPS’ progress, we encourage you to consider collecting disaggregated data for the different racial categories, including Black people, in accordance with Ontario’s Data Standards for the Identification and Monitoring of Systemic Racism.
We note that this year’s OPS Employee Experience Survey offers the opportunity to be linked against relevant employee information though the Workforce Information Network (WIN). We view this as a positive step to further identify and address discrimination in the workplace.
Putting lived experience at the centre of your efforts
Finally, we would encourage you to put the lived experiences of individuals involved in OPS employee networks, including BOPSers, at the centre of your efforts. These employee networks can provide critical feedback and suggest improvements on these important initiatives. We urge you to consider meaningful and timely engagement with BOPSers and other employee networks, and suggest establishing Terms of Reference to guide these engagements.
Overall, the OHRC is encouraged by the steps you are taking to institute concrete, actionable and measurable initiatives to address systemic discrimination and anti-Black racism. We appreciate your effort to engage the OHRC in this work and would suggest we continue to meet quarterly to continue this open and constructive dialogue.
Renu Mandhane, B.A., J.D., LL.M.
Ontario Human Rights Commission