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ASL – Minimum requirements for Video Relay Service (VRS) (2 of 2)

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Minimum requirements for video relay service and its administrator

Requirements for the video relay service administrator

  1. Operate and monitor a national video relay service (VRS) system that meets the requirements set out below or otherwise set out by the Commission.
  2. Operate VRS in accordance with the administrator’s bylaws, mandate, and any other corporate documents approved by the Commission.
  3. File updates with the Commission for information if any modifications are made to the processes that the administrator will follow for
    1. resolving complaints between registered VRS users and itself or any VRS provider(s), with a mechanism to escalate complaints to the Commission;
    2. recording and maintaining VRS data on usage and demand (including monthly reports generated by the VRS technology platform) so that any trend analysis may be completed regarding call traffic patterns sorted by day and by hour, call volume of completed and abandoned calls, call duration, wait times for completed and abandoned calls, technical areas, and other related issues; and
    3. recording and maintaining data with respect to the provision of VRS, including, at a minimum, quality-of-service measures; financial accountability measures; and the number and nature of (i) complaints and inquiries (including those related to video interpreter service and technical errors or technology compatibility); (ii) video interpreters (including the number of video interpreters hired, the average wage rate and availability, and certification requirements); and (iii) planned and unplanned outages.
  4. File updates with the Commission for information if any modifications are made to the privacy and confidentiality standards for the provision of VRS that meet the criteria set out in paragraph 135 of Telecom Regulatory Policy 2014-187 (the 2014 VRS Policy).
  5. File any information requested by the Commission about the administrator’s operations.
  6. Develop and file with the Commission for information, within one year of this regulatory policy's publication date, an updated outreach and education plan to encourage the adoption of VRS by users with and without disabilities, including hearing individuals (e.g., general public), businesses, and institutions (e.g., financial institutions). In the plan, the administrator must describe, at a minimum, targeted education efforts to inform registered VRS users about the features of VRS, how to effectively place VRS calls with businesses and institutions, and how to access emergency services (9‑1‑1 and 9‑8‑8) using VRS and when VRS is not available.
  7. Demonstrate that it has made all reasonable efforts to ensure that American Sign Language (ASL) and Langue des signes québécoise (LSQ) services are equally comprehensive regardless of whether ASL and LSQ users are served by the same or separate VRS providers. The administrator is not to limit one service to ensure its equality with the other service.
  8. Ensure that staff and any advisory panels that may be struck to advise the board of directors include the perspectives of ASL and LSQ communities.
  9. Engage on an ongoing basis with current or potential VRS users whose primary language is ASL or LSQ and who are Indigenous to better understand their specific needs. The administrator must also provide an update in its annual report on the status of engagement and the steps it has implemented or plans to implement to better serve Indigenous people who are Deaf and whose primary language is ASL or LSQ.
  10. Ensure that the total of all VRS-related costs does not exceed $41 million annually for a fully subscribed, full-time service.
  11. If all minimum requirements are met, notify the Commission of the administrator’s annual funding requirements by way of a letter to the Secretary General in English, French, ASL, and LSQ. The letter must
    1. be filed by August 31 each year;
    2. specify the amount of funds needed from the National Contribution Fund for the next calendar year, which should never exceed the cap set out in the updated policy;
    3. provide a reference and link to the administrator’s annual report;
    4. attest by way of an affidavit from the administrator’s chief executive officer that the minimum requirements set out in the updated policy have all been met (all minimum requirements must be listed in the affidavit); and
    5. be made available on both the administrator’s website and the Commission’s website in both official languages and in ASL and LSQ.
  12. If one or more of the minimum requirements are not met, file a Part 1 application pursuant to the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure with the Commission by August 31 each year to request its annual funding.
  13. On a date set by the Commission before each VRS review, file with the Commission for approval modified or updated
    1. quality-of-service standards;
    2. guidelines to resolve complaints, including service standards; and
    3. reporting requirements.
  14. When a VRS platform provider offers all or some of the VRS, include in any request for proposals, and in any resulting contract, a requirement that a VRS platform provider must
    1. provide a service (or a portion of a service) that complies with (or allows the administrator to comply with) the requirements in this appendix or otherwise established by the Commission;
    2. provide to the administrator, or to the Commission directly, any information regarding its operations for monitoring or review purposes, including any data collected or reports generated;
    3. handle and monitor user complaints in accordance with the mechanism established by the administrator;
    4. record the following information in relation to the services provided:
      1. video interpreters (including the number of video interpreters hired, the average wage rate and availability, and certification requirements);
      2. demand data (including, at a minimum, detailed call traffic patterns sorted by day and by hour, call volume, call duration, abandoned calls, and average wait time); and
      3. complaints and inquiries data relating to video interpreter service and underlying technology;
    5. indicate the price the VRS platform provider will charge registered VRS users for long distance calls and any ancillary services;
    6. indicate in bids whether long distance calling cards are compatible with the service, and if so, identify which calling cards are compatible;
    7. limit its contract term with the VRS platform provider to a maximum of five years, with the option of an extension, to allow for possible changes resulting from the Commission’s review of VRS; and
    8. cooperate with the administrator and any other VRS platform providers to ensure seamless transitions at the beginning and the end of the contract term.
  15. Consider, when operating and modifying VRS,
    1. interoperability with other jurisdictions’ VRS systems to the extent possible to facilitate point-to-point calls internationally;
    2. interoperability between VRS and message relay service, as described in the International Telecommunications Union Total Conversation standard;
    3. promotion of consumer choice in end-user devices that are current, off the shelf, and popular;
    4. separation of the technical and video interpreter elements of VRS; and
    5. minimization of system outages.

Minimum requirements for VRS developed by the VRS administrator

  1. Provide video relayed calls in both ASL and LSQ.
  2. Use telephone numbers that conform to the North American Numbering Plan and provide universal access to and/or from the public switched telephone network.
  3. Use a single common VRS technology platform nationally that can support multiple video interpreter providers.
  4. Use non-proprietary VRS technology based on current and evolving industry-accepted technical protocols.
  5. Use a specialized platform for VRS unless the key features mentioned in paragraph 103 of the 2014 VRS Policy become available on non-specialized platforms.
  6. Provide service 24 hours per day, 7 days per week.
  7. Make access to information about planned outages and system status prominent on its website.
  8. Include the ability for registered VRS users to make point-to-point calls (i.e., calls between registered VRS users without the use of a video interpreter).
  9. Support caller identification (caller ID) blocking.
  10. Include Hearing Carry Over and Voice Carry Over functionalities.
  11. Provide notifications of incoming calls to registered VRS users.
  12. Create a database of registered VRS users accessible to the administrator that includes registered users’ address information and has a mechanism for registered users to update their information online and through customer service.
  13. Provide access to 9‑1‑1 service 24 hours per day, 7 days per week using the same approach that the Commission mandated for nomadic voice over Internet Protocol 9‑1‑1 services, as set out in Telecom Decisions 2005-21 and 2007-44. Specifically,
    1. the video interpreter must act as the intermediary between the registered VRS user and the 9‑1‑1 call operator at the public safety answering point (PSAP);
    2. 9‑1‑1 service must be provided using the incumbent local exchange carrier’s tariffed emergency call routing operator service so that the video interpreter has priority access to PSAPs across the country;
    3. when they register for VRS, VRS users must be informed how to reach 9‑1‑1 in instances when VRS is unavailable;
    4. registered VRS users must be informed in advance of any planned VRS outage that will affect access to 9‑1‑1 services;
    5. whenever registered users are notified of a planned or unplanned VRS outage, they must be provided with information about alternative ways to reach 9‑1‑1;
    6. an onscreen notification must appear when a registered VRS user tries to place a 9‑1‑1 call in instances when VRS access to 9‑1‑1 is unavailable (such as during a planned or unplanned outage), including the duration of the outage if known and alternative ways to reach 9‑1‑1; and
    7. each registered VRS user’s address information must be entered into a database and automatically provided to the video interpreter during a 9‑1‑1 call made via VRS. Moreover,
      1. the user-provided address information is to be used as a last resort in situations where the registered VRS user is unable to provide or confirm their location; and
      2. registered VRS users must have the capacity to update their address information for 9‑1‑1 purposes online and through customer service.
  14. Provide access to 9‑8‑8 service 24 hours per day, 7 days per week, consistent with Telecom Regulatory Policy 2022-234. Specifically,
    1. the video interpreter must act as the intermediary between the registered VRS user and the 9‑8‑8 counsellor;
    2. when they register for VRS, VRS users must be informed on how to reach 9‑8‑8 in instances when VRS is unavailable;
    3. registered VRS users must be informed in advance of any planned outage that will affect access to 9‑8‑8 service;
    4. whenever the administrator provides notifications of a planned or unplanned VRS outage, it must include alternative ways to reach 9‑8‑8;
    5. registered VRS users must be provided with an onscreen notification when they try to place a 9‑8‑8 call in instances when VRS access to 9‑8‑8 is unavailable (such as during a planned or unplanned outage), including the duration of the outage if known and alternative ways to reach 9‑8‑8;
  15. Use a screening process to ensure that video interpreters are qualified sign language interpreters, meaning that they can interpret effectively, accurately, and impartially, both receptively and expressively, using any necessary specialized vocabulary.
  16. Provide VRS to registered VRS users upon their self-certification that they use ASL or LSQ as their primary language of communication due to a disability and their consent to a user agreement. This agreement must outline, at a minimum, privacy and confidentiality policies, a fair usage policy, information on 9‑1‑1 and 9‑8‑8 access, and a billing agreement for ancillary and long distance service. The agreement must also be
    1. in plain language (i.e., clear, simple, and concise language);
    2. available in ASL and LSQ; and,
    3. signed before services are rendered.
  17. Provide to the registered VRS user a user technology interface and written materials that are in plain language and offered in the official language of the registered VRS user’s choice. The contents of the written informational materials are to be offered in English and French and are expected to be provided in ASL and LSQ.
  18. Provide VRS at no additional cost to the registered VRS user.
  19. Ensure that ancillary services, such as call display, video mail, etc., when offered, are billed to registered VRS users who subscribe to these services at rates similar to those charged for corresponding voice services.
  20. Offer registered VRS users long distance services at rates similar to those charged for other long distance services. Long distance calls initiated by registered VRS users are to be billable to the user, based on call duration.

Previous video

The minimum requirements imposed by the Commission on the Canadian Administrator of VRS (CAV), Inc. are described in this video.

Full policy on Video Relay Services.

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