Audit of Service Delivery in English and French to Air Canada Passengers

Air Canada employees

Visual active offer (displays, publications and signs)

The displays were in both official languages in all the airports that we visited, as were the self-service check-in terminals and the publications for the travelling public. The Air Canada website was also in both official languages.

Our review revealed that bilingual service signage is inconsistent from one airport to another. Some counters use the “English/Français” pictogram while others use a sheet of paper that says “English/Français.” We noted that Air Canada does not have standards regarding the positioning of its bilingual service pictogram. Another relevant point is that bilingual agents are responsible for placing the pictograms on their work stations. They told us that this was not always done. Air Canada should improve this situation and establish standards to ensure that bilingual service signage is consistent across Canada, and that a monitoring mechanism is established.

Bilingual flight attendants and bilingual agents who work in airports usually wear “English/Français” pins. However, bilingual agents in airports stated that they do not always wear them. Employees in language training can wear “J'apprends le français” pins.

Verbal active offer in person

The active offer allows Canadians to be welcomed in English and French and informed that they can receive services in the official language of their choice as expeditiously as possible.

As we have mentioned previously, Air Canada created a video called “Hello/Bonjour” that presents the institution's obligations as well as the procedures to follow and the key messages that agents should convey in terms of the active offer of bilingual services. We salute Air Canada for this great initiative.

However, our review revealed that very few employees, including the managers we met with, knew about this video. And yet it is a tool that would help Air Canada progress in its efforts towards achieving the desired results.

It is apparent that the active offer of bilingual services is nonexistent in the vast majority of airports, as the results of the observations carried out in 2008–2009 show. The exception was Montréal's Pierre Elliott Trudeau International Airport, where an active offer was made less than half of the time. This major shortcoming requires strong action by Air Canada. The information gathered during the audit shows that agents do not make an active offer mainly because they do not know their obligations in this respect. Some agents told us that they did not have to make an active offer because they were Anglophone. Other agents said they felt uncomfortable making an active offer because they did not want to start a conversation in French, particularly on shifts where there were no bilingual agents working.

How is it possible to explain that, in a number of airports, the managers, lead agents, and customer sales and service agents are unaware of their language obligations regarding services to the public? The vast majority of front-line agents we met with clearly stated that they do not provide active offer as it had not been asked nor required of them. Our interviews also showed that this obligation was poorly understood by the vast majority of employees. Air Canada should establish a set of guidelines and mechanisms to ensure the active offer of bilingual services in person and send a clear message regarding its language obligations.

To be honest, there is no active offer. [translation]

– Customer sales and service agent

But let's look at a positive aspect. During the Vancouver 2010 Olympic and Paralympic Winter Games, all front-line agents working at Vancouver International Airport stated that they made an active offer and were happy to do so. The active offer was part of an awareness campaign, and agents were rewarded with gift certificates to buy coffee when they made an active offer. The agents told us that, unfortunately, the active offer of bilingual services stopped once the Games ended.

An active offer of bilingual services on board aircraft is not always provided. The flight attendants told us that they do offer bilingual services occasionally, but usually they wait to see what language the passenger uses to address them. On board, the offer of services in English and French—for example, “something to drink, quelque chose à boire”—is not systematic. It should be noted that on return flights to Vancouver, Montréal, Québec City, Ottawa, Toronto and Halifax, the offer of services should be made more frequently in French. Air Canada must raise awareness and remind flight attendants working on designated bilingual routes of their obligations regarding the active offer of bilingual services.

‘Hello, bonjour'? No, that's not done at all. [translation]

– Flight attendant

Union representatives we met with also stated that they were not aware that a bilingual greeting was a requirement of Part IV of the Official Languages Act.

The constant lack of an active offer of bilingual services means that Air Canada must make some immediate changes.

Inflight bilingual services

There is no reference to the delivery of bilingual services in the work description in the collective agreement for flight attendants. However, all basic announcements, including welcome and safety messages, are in both English and French in the announcement manual available to all flight attendants. The service directors are responsible for making these announcements, although they may ask flight attendants to make the announcements in English and French. We were told that unilingual English-speaking service directors often make announcements in French. Some flight attendants stated that the quality of the French in such cases was sometimes so bad that it would be better if the managers did not make these announcements at all, but rather asked the bilingual flight attendant on board to do so. By providing welcome messages, Air Canada tells its passengers, “We are happy to serve you in English or French.” In order to enhance bilingual services on board its flights, we encourage Air Canada to inform passengers more clearly that there is a flight attendant on board who speaks English and French, and that they should feel free to address that attendant in the official language of their choice. Air Canada could even introduce the attendant who speaks French, giving his or her name, as is done by another air carrier.

I didn't know that bilingual routes existed. I thought Air Canada provided bilingual services as a courtesy.

– Flight attendant

Impromptu announcements from the cockpit pose a problem. Although there is always a bilingual attendant on board, these messages are not always translated simultaneously or completely.

As we mentioned at the beginning of this report, 33% of the complaints received by the Office of the Commissioner of Official Languages regarding Air Canada involve inflight services. There are many reasons for this. First of all, we noted during our interviews that flight attendants do not always go get the bilingual flight attendant on board to serve a passenger who speaks to them in the other official language. Instead, they often try to make themselves understood in another manner, particularly by using a sort of sign language: for example, pointing to the drinks on the cart. It should be noted that flight attendants justify this practice citing a lack of time, particularly when flights are short and attendants have to serve passengers quickly.

We recognize that Air Canada is making an effort to ensure that there is always at least one bilingual flight attendant on board each flight, and two on larger aircraft. During a review of over 80 lists of crew working on multiple flights, we were able to verify this practice. However, it is our conclusion that Air Canada should step up its reminders to flight attendants to ensure that, when a passenger speaks to them in French, service is given in the same language (for example, by saying “Un moment s'il vous plaît”).

There is always at least one bilingual flight attendant on board. In large aircraft, there are two. That's in the collective agreement.

– Flight attendant

Turning to another issue, our interviews indicated that French-language newspapers were not provided on board flights on designated bilingual routes, particularly in the West. We ask that Air Canada take appropriate measures to remedy this situation.

Lastly, we wanted to know whether managers were informed of legal proceedings and decisions rendered concerning the delivery of services in English and French by Air Canada. None of the managers we met with knew about these decisions. We believe that sharing this information would make managers more aware of the institution's obligations, and would help improve the monitoring of all Air Canada's official languages activities.

Bilingual services on the ground

The audit revealed that there are weaknesses in all airports in terms of bilingual service delivery, although the results were better in Montréal. Significant shortcomings were noted in all airport service areas, where services were rarely of equal quality in both official languages or were not available in French, which explains the high percentage of complaints received by the Office of the Commissioner of Official Languages against Air Canada on this issue (67%). The following paragraphs give an overview of the situations and information gathered during our interviews.

At flight and baggage check-in counters and also in service areas with self-service check-in terminals, Canadians expect to be able to communicate with Air Canada personnel in the official language of their choice after having waited in line. Our on-site observations indicated less than stellar performance in this respect, with the exception of Montréal's Pierre Elliott Trudeau International Airport. There were no bilingual agents in the welcome area, or at the counter for business class, elite and super elite members. The same situation was observed at the counter for passengers with special needs, such as those in wheelchairs. Other observations noted at the check-in counter for economy class showed that not only did the agent not provide an active offer of bilingual services, no effort was made to go and find a bilingual agent. The customer was simply told, “Sorry, I don't speak French,” despite the fact that there was a bilingual agent at another counter. This situation clearly demonstrates that Air Canada's agents are not fully aware of their bilingual service delivery obligations. The negative attitude of some agents regarding official languages was also raised during our interviews.

We reviewed the work description in the collective agreement for customer sales and service agents to identify their bilingual service requirements and mandatory skills. The description is very vague and does not mention that services must be provided in both official languages. We learned that this description is more than 10 years old. It requires a revision in order to better reflect the realities of the agents' jobs. Nonetheless, most of the agents we met with were quite willing to serve passengers in both official languages.

In terms of bilingual service delivery, we suggest that Air Canada examine, among other options, the possibility of establishing a sufficient number of designated bilingual counters and lines in the check-in area, thus ensuring that there are always bilingual agents available to provide services of equal quality in English and French. This should be done in all airports where Air Canada has language obligations, except at Montréal's Pierre Elliott Trudeau International Airport, where all of the customer sales and service agents are bilingual. In addition to ensuring quality services in both official languages without a delay to find a bilingual agent, this approach would allow passengers to stay in one spot with their bags rather than having to take their luggage to another counter. We also suggest that Air Canada appoint a bilingual agent (floating bilingual agent) on each shift who could act as a resource person when there is a request in the other official language. The name of this agent would be communicated to front-line employees. Having an identified resource person would eliminate a number of the steps usually taken to find a bilingual agent. In some airports, agents indicated that they did not know which agents were officially bilingual, unless they had the work schedule indicating who was bilingual at hand.

We wish to point out that the vast majority of managers and lead customer sales and service agents we met with were unilingual, and yet they are required to help passengers in complex situations (for example, when a flight is cancelled) as well as evaluate the quality of the agents' work, including customer service provided in French. In this respect, the work description in the collective agreement for lead agents states that: “The principal functions of a lead agent are to provide leadership, support and direction to a group of employees in the areas of technical expertise, customer service and operational demands while remaining a full working member of that group. Additional responsibilities include employee assignment, on-the-job training and instruction.” In light of the above, we believe that Air Canada should analyze and evaluate this situation and take the necessary measures to remedy the lack of bilingual managers and lead agents, which could have a negative effect on monitoring the quality of services provided in the language of the official language minority community.

When discussing services provided in English and French, airport ground personnel seemed to think that the main aspect of delivering bilingual services was the announcements made at boarding gates, as they often referred to these. The agents told us that the announcements were made using an automated system or MP3 players, but that in airports where there were no automated systems, they were made by the agents themselves. The agents also informed us that they had the option of making the announcements themselves rather than using an automated system. The results of the audit show that often neither scripted nor unscripted announcements were provided in both English and French. After examining the customer sales and service agents' work schedules, we noted that there was very often a lack of bilingual agents at boarding and arrival gates.

It is important to reiterate that failing to provide timely translations of personalized or unscripted messages simultaneously can have a negative impact on Francophone passengers, and can even cause them to miss their flights. Passengers could also miss out on a compensation offer when there is an overbooking, because in most airports, these messages are never translated. The reason given by agents for not providing a translation or using the automated systems was lack of time due to having to proceed with boarding within a short timeframe. With respect to the use of MP3 players in airports not equipped with automated systems, we were told that, although the messages are complete, the sound quality can make hearing them rather difficult, and that using these devices can prove problematic. Since automated systems are the responsibility of airport authorities, we encourage Air Canada to negotiate with them to have access to automated systems that are consistent from one station to the next in order to ensure services of equal quality in both official languages across Canada.

In light of the aforementioned observations, it is worrying to see that the planning for the provision of bilingual services is unsatisfactory with respect to bilingual service signage, and the active offer and delivery of bilingual services in person inflight and at check-in counters, at boarding and arrival gates, and in announcements made in English and in French. Significant shortcomings were also noted when the resource planning unit assigns bilingual personnel to different service areas on a daily basis. Air Canada should fully review its planning for the provision of bilingual services and apply more effective practices to comply with the Official Languages Act. Moreover, Air Canada directors in airports should take concrete measures, take their regional realities into account, and comply with the directives from national senior executives. See Recommendation 10.

Call centres

Air Canada customers who telephone from within Canada and the United States use the 1-888-247-2262 toll-free number. The international network branch handles calls from abroad.

An interactive telephone system directs the call to a qualified agent when the customer has identified his or her preferred language. Although there are bilingual agents outside of Quebec, all agents at the Montréal call centre are bilingual, and this centre offers service 24 hours a day, 7 days a week. Air Canada reports that 60% of agents who work in call centres are bilingual. Air Canada stated that there is quality control on incoming calls in the call centres and that the response time is the same for calls in English and French. The interviews we conducted with representatives of the official language minority communities revealed that sometimes the waiting time can be longer when they choose the “French” option, and that by switching to the “English” option they are served more quickly.

Maple Leaf lounges

During our visit to Maple Leaf lounges, we observed that there were no bilingual agents at the reception counters of many of these lounges. In addition, the personnel working for the catering companies were unilingual Anglophones. However, we noted that Air Canada's publications were bilingual, and that there was at least one French-language magazine on the racks. We would have expected there to be at least one bilingual agent checking the boarding passes of passengers entering the lounges.

Criteria

1. Verify that Air Canada has an official languages accountability framework.
2. Verify that Air Canada's official languages action plan allows for the effective implementation of Part IV of the Official Languages Act with regard to services offered in the air and on the ground, in person, by telephone, in writing and via automated and electronic systems.
3. Verify that Air Canada has an official languages policy (or guidelines) that takes into account all of the components relating to services to the public, that is approved by senior management and that is in compliance with the Official Languages Act and its regulations.
4. Verify that Air Canada is effective in informing all personnel assigned to inflight and ground service delivery, either in person or by telephone, and personnel responsible for automated and electronic systems of the requirements regarding service delivery in both official languages.
5. Verify that Air Canada's training modules, which are given to both its own employees and those of Jazz, include Air Canada's obligations and employees' responsibilities pertaining to official languages.
6. Verify that Air Canada takes official languages issues into account in the performance evaluations of senior executives, managers, and agents with service delivery responsibilities.
7. Verify that the unions take Air Canada's language obligations into account.

Criteria

1. Verify that Air Canada actively offers and provides services in both official languages in airports that receive at least one million passengers per year and in airports where there is at least a 5% demand for services from the official language minority community.
2. Verify that the bilingual capacity of Air Canada's flight attendants and customer sales and service agents is sufficient to ensure the effective delivery of services of equal quality in English and in French.

Criteria

1. Verify that Air Canada consults the official language minority communities in all regions of Canada to identify their service needs and determine whether they are informed of the decisions made.

Criteria

1. Verify that Air Canada has effective oversight mechanisms (including internal auditing and the office of the ombudsman) to ensure that all its services are of equal quality in both official languages, in the air and on the ground.
2. Verify that Air Canada ensures that Jazz offers services of equal quality in both official languages.
3. Verify that monitoring results are used in managing the quality of services with the aim of continuing to improve and secure tangible results.

Air Canada's comments and action plan²

As Canada's principal air carrier, Air Canada is pleased to promote the principles of English and French duality, as outlined in the Official Languages Act. No other North American carrier offers throughout its world-wide network with such consistency services in both official languages, English and French. Air Canada accepts this role, not so much out of compliance and commercial sense but rather as mark of respect for the duality of languages that exist in this country.

Air Canada has a language policy and language guidelines, a Code of Conduct and many other guiding tools for managers and employees regarding the company's language obligations. As per the audit findings, Air Canada realizes that, even with the existing tools, the application of the company's linguistic obligations and the roles and responsibilities need to be clarified. Air Canada proposes the implementation of the following enhanced measures.

Air Canada will develop and implement an accountability framework for official languages by the end of the year, which will include the guiding principles for the effective management of official languages. This will also include:

• The designation of the Accountable Executive and the corporate champion for official languages;
• Clear expectations for all employee groups on their roles and responsibilities;
• Code of Conduct in regard to official languages;
• Documented business processes for official languages.

Commissioner's comments

We are satisfied with the measures and timeframe proposed for establishing an accountability framework. In our opinion, the establishment of a network of official languages coordinators could be part of new official languages management processes. Air Canada should also develop a communications strategy to inform all staff of their obligations under Part IV of the Act.

Air Canada's comments and action plan

Unlike government institutions that are subject to the Official Languages Act, Air Canada receives no direct or indirect funding for language training, testing or communication. Despite this fact, Air Canada has allocated significant resources (financial and human) to maintain its language programs and has never challenged the budget for language training or testing. As more of our commitment to the Official Languages Act, in the force of economic downturns, the Companies' Creditors Arrangement Act, etc., Linguistic Affairs is one of the very few departments that has not seen its budget or programs reduced over the years. Local managers have demonstrated leadership in initiating awareness sessions, in training and in developing new tools to help their employees deliver service in the customer's language of choice. In order to ensure proper follow-ups are conducted and that actions are taken when required, Air Canada will implement the following enhanced measures.

Air Canada has an official languages program that is managed by the General Manager, Linguistic Affairs. In order to bring higher visibility to this resource and to ensure Air Canada has the necessary human and financial resources to implement Part IV of the Official Languages Act, Air Canada will:

• Systemically review findings and actions at the Senior Executive level;
• Conduct regular meetings with key internal stakeholders on the development progress of the business processes in support of the official languages.

Commissioner's comments

We are satisfied with the follow-ups proposed in response to this recommendation.

Air Canada's comments and action plan

As outlined in the Commissioner's report, the 2001–2010 Official Languages Action Plan was specifically designed to address operational issues resulting from the merger with Canadian Airlines in 2001.

Since then, many initiatives and accomplishments have been realized to improve employee awareness of Air Canada's official languages obligations and service delivery to our customers. The following examples identify some of the key action items implemented in the past ten years:

• aerovocab (bilingual pocket-sized booklet that helps employees quickly find proper words frequently used in airline terminology);
• eLang (online management application for language testing);
• video on active offer, presentation to all new frontline employees;
• brochure on official languages obligations;
• e-mail address available to customers specifically for language complaints;
• customer satisfaction surveys;
• quality assurance observations;
• linguistic award;
• on-line training;
• individual coaching by language instructors;
• Air Canada official languages obligations in orientation kit;
• Air Canada official languages obligations presentation to all new frontline employees;
• biodegradable pens promoting service in English and French.

Air Canada recognizes the value of having a new official languages action plan to align its language activities and initiatives.

Air Canada will develop a new three-year action plan that will ensure continued compliance with Part IV of the Official Languages Act and complement our commercial goals. It will include:

• The specific details on how Air Canada will effectively implement Part IV and the other parts of the Official Languages Act;
• Deadlines and performance indicators;
• Accountability mechanism.

Commissioner's comments

We recognize the efforts made over the past 10 years and are satisfied with the proposed measures. However, when developing its official languages action plan, Air Canada should include all components related to Part IV of the Act, as well as all measures proposed for each recommendation presented in this report, to obtain concrete and sustainable results.

Air Canada's comments and action plan

Air Canada used many media vehicles to communicate directives on official languages to employees such as Globe, the customer service magazine, the Daily, a daily newsletter available to all employees, and staff meetings.

Air Canada has a language policy that will be updated by the third quarter to reflect current realities and include components of our language business processes. Once it is updated, it will be communicated to all employees.

Commissioner's comments

We are satisfied with the measures and timeframe proposed for the update of the official languages policy. We acknowledge Air Canada's commitment to communicate, on a systematic and regular basis, its language policy and obligations under the Act, as described in its response to Recommendation 9.

Air Canada's comments and action plan

Air Canada already has a number of existing tools to communicate and inform its employees and managers regarding the obligations under Part IV of the Official Languages Act, such as an eLearning video on active offer, awareness sessions for new hires and other types of reminders. Once the business processes are developed in support of the official languages, Air Canada will streamline all communication vehicles available to improve efficiency.

Air Canada has many media vehicles available to communicate with its employees. It will raise awareness of its linguistic obligations by:

• Using all available media vehicles to effectively communicate employee responsibilities;
• Updating employee indoctrination requirements;
• Reviewing and updating language qualifications requirements for Air Canada, Jazz and other potential required affiliates.

Commissioner's comments

We are satisfied with the proposed measures. It is our view that using an effective communications strategy for the release (and reminders) of the new official languages accountability framework, action plan and policy will give staff a better understanding of their responsibilities in terms of active offer and service delivery in both official languages.

Air Canada's comments and action plan

Air Canada has always assessed the level of performance of its employees in applying Part IV of the Official Languages Act, although under the general umbrella of customer service delivery.

Air Canada will include key performance indicators identifying specific obligations under Part IV of the Official Languages Act in management performance plans. In addition, once the language policy and the Code of Conduct have been updated, all employees, including management, will be reminded of their responsibilities and the performance competencies they are expected to conform to.

Commissioner's comments

We are satisfied with the measures proposed to follow up on this recommendation.

Air Canada's comments and action plan

Air Canada is currently in the process of negotiating new collective agreements with all unions. In collective bargaining employers cannot impose any terms that are not agreed to by its unions. The General Manager, Linguistic Affairs, participated in and provided information during the negotiations with CUPE , CAW and the International Association of Machinists and Aerospace Workers to present the Commissioner's audit findings and explain to the unions Air Canada's obligations under Part IV of the Official Languages Act.

In the context of labour:

• The Labour Relations branch has been briefed on the Commissioner's recommendations pertaining to official languages;
• Any successful negotiated outcomes to the collective agreements will be included in Air Canada's business processes on official languages.

Commissioner's comments

We are satisfied with the measures taken and those to follow. We encourage Air Canada to continue to intervene with unions to ensure compliance with the requirements of Part IV of the Act.

Air Canada's comments and action plan

In the overwhelming majority of instances, signage at the airports requires the approval of the airport authorities. This includes the right to add tent cards or signs on countertops. Air Canada's current airport signage is monitored through the Quality Assurance Division. The following measures, to be developed by year end, will ensure a more consistent approach.

Air Canada will regularly assess passenger demand for official languages and adjust service in airports and in flight accordingly. To be documented in its language business process:

• Develop standards, with airport authorities where required, for service in both official languages, which will include a standard for signage;
• Develop, document and implement auditing protocols for each service area.

Commissioner's comments

We are satisfied with the proposed measures.

Air Canada's comments and action plan

As mentioned previously, because it makes good commercial business sense to do so, Air Canada already has a number of tools to communicate the company's linguistic requirements and understands the need for effective ways to communicate.

As part of its documented business processes in support of official languages, by early next year Air Canada will:

• Develop standards for training, which will include the minimum training requirement in new and recurrent training for employees for them to understand their language obligations under Part IV of the Official Languages Act;
• Communicate its language policy and its obligations under Part IV of the Official Languages Act on a systematic and regular basis.

Commissioner's comments

We are satisfied with the proposed measures and timeframe.

Air Canada's comments and action plan

Air Canada currently has a process in place to ensure there is always at least one bilingual flight attendant on board all flights, and that more bilingual employees are assigned for flights considered mostly French as allowed by the collective agreement.

In order to improve the available service of equal quality in both official languages in airports and on board flights, by the end of year Air Canada will:

• Conduct an analysis to review the minimum number of bilingual employees required in all service areas;
• Review training programs for front line employees;
• Document the business process.

Commissioner's comments

We are satisfied with the proposed measures and timeframe.

Air Canada's comments and action plan

Air Canada does not share the Office of the Commissioner's interpretation of the Supreme Court Decision in DesRochers v. Canada (Industry) in that Air Canada would have an obligation to consult the national, provincial and regional representatives of the official language minority communities in a structured and coordinated manner to identify specific needs regarding how they would like to receive the services. Indeed, unlike the facts at the base of the DesRochers decision, Air Canada offers a service that is more in the nature of a “product.” Unlike government institutions, as a private company, Air Canada does not provide consultative services or development services. More importantly, Air Canada is precluded under the Canada Transportation Act and the Canadian Human Rights Act to provide its services in a differentiated manner and is mandated to provide them consistently.

Be that as it may, Air Canada consults and participates with the language minority communities for special occasions or events such as the Vancouver Olympic Games, la Place de la Francophonie, les Rendez-vous de la Francophonie and le Festival du Voyageur. It also consults with minority communities for recruiting activities. Air Canada is sensitive to community members' needs and is constantly looking at improving its service and meeting the needs of customers.

Air Canada proposes to enhance its communications with the national, provincial and regional representatives of the official language minority communities on an occasional basis, as part of its documented business processes, by the end of the year.

Commissioner's comments

We are partially satisfied with the follow-ups taken in response to this recommendation. Although Air Canada does not agree with our interpretation of the DesRochers decision, we maintain that air transportation services provided by Air Canada must be of “equal quality” for both official language communities that make up the travelling public. To fulfill this obligation, Air Canada must not only listen to the needs of community members, but must also take into account the needs of official language minority communities, particularly when making decisions that impact flights, routes or bilingual services. Consulting minority-language communities to provide services of equal quality to both official language communities, as required by the Official Languages Act, does not contravene the Canada Transportation Act or the Canadian Human Rights Act. We will in time examine the steps taken by Air Canada to consult the communities.

Air Canada's comments and action plan

Air Canada currently monitors the performance of its employees in applying Part IV of the Official Languages Act via various monitoring tools and surveys, for example by Ipsos Reid and other internal quality assurance programs.

In order to improve the monitoring mechanisms, by the end of the year Air Canada will:

• Review and modify the distribution of Ipsos Reid results to ensure appropriate personnel are aware of results;
• Review the current Mystery Shopper program to make it part of our language business process;
• Enhance the quality assurance program to ensure all service areas are covered, including Jazz and any other airline affiliated with Air Canada and the Official Languages Act;
• Ensure the monitoring and auditing process is part of the overall documented language business processes, including the reporting protocol.

Commissioner's comments

We are satisfied with the proposed measures and timeframe.