British Broadcasting Corporation Disability Equality Scheme

British Broadcasting Corporation

Disability Equality Scheme

updated 2008

Foreword by the Chairman of the BBC

Disability Equality Scheme

Everyone in the UK, whatever their background, should get something of real value from the BBC. After all, everyone pays for it. One of the main roles of the BBC Trust is to listen hard to and understand the views of the public, in order to ensure that the BBC does as well as it can among every section of UK society.

Around one in five of people living in the UK is disabled. This is not a homogenous group, but a range of people with a wide range of needs and views. The BBC Trust needs to understand these views in order to do its job.

The Disability Equality Scheme is one way in which the BBC contributes to meeting the diverse needs and expectations of all audiences, and to enhancing the lives of people from a wide range of different communities and backgrounds. The BBC published its first Disability Equality Scheme in December 2006. This scheme outlines the framework for how the BBC will develop, implement, monitor and review its work towards achieving equality for disabled people (and their carers) in relation to its relevant public functions. The scheme is updated each year, and we will be carrying out a major review every three years.

In the schemes, you will see our detailed progress report against actions we committed to in last year’s scheme. For example, following consultation we have modified our complaints procedures to increase their accessibility in a number of ways. In the coming year, we will work harder to encourage disabled people to join our Audience Councils.

As Chairman of the BBC, I am determined to make a difference here.

We will also hold the BBC Executive, which is responsible for the day-to-day running of the corporation, to account to ensure that it finds the best way to provide distinctive services of the highest quality to all the people and all the communities across the UK.

Sir Michael Lyons

Foreword by the Director-General of the BBC

Disability Equality Scheme

I am delighted to join Sir Michael in introducing the BBC’s Disability Equality Scheme.

My Directors and I are committed to disability equality, and we look to the Disability Equality Scheme to help us achieve it across those of our public functions which are subject to the Disability Equality Duty. This year’s scheme includes a review reflecting our progress one year on – and I am happy to report that it contains details of real progress, as well as important indications of how we can continue to deliver on demanding targets.

In addition, and perhaps most importantly, the BBC has exceeded its employment target on employing disabled staff, while our Mentoring and Development Programme, which aims to create a diverse pool of future leaders, has ring-fenced a proportion of places for disabled staff.

Our equality schemes express a key goal for us: we want the BBC to be valued by all our audiences – so that we can continue to make amazing content which offers something of value to everyone and in which they can see themselves reflected. We have now achieved 100% subtitling of programmes on our main channels (BBC One, BBC Two, BBC Three, BBC Four, CBeebies, CBBC and BBC News). This was a BBC set target, which exceeded the targets set for public service broadcasters by Ofcom. Looking ahead, one of the BBC’s objectives for 2008/2009 is Building Digital Britain. As part of our responsibilities to lead digital switchover we are charged with delivering a help scheme for older and disabled people which ensures that digital switchover is an inclusive process that leaves no one behind.

While much of our day-to-day work is outside the scope of our duty to promote disability equality, we nevertheless also wanted to take this opportunity to give some idea of the wealth of what we are doing across our programming, and with our people. I am very proud of what we have achieved by working in partnership with other broadcasters through the Broadcasting and Creative Industries Disability Network, in which we continue to take a leading role – working together to promote disability equality on screen and within the industry.

Our equality schemes are living documents. My Directors and I will continue to regularly review our progress across everything we are doing on disability equality – including our legal duties – through our Diversity Board, which I chair. I hope you will find it offers tangible evidence of our deep and ongoing commitment to equality.

Mark Thompson

Contents

Summary of the Disability Equality Scheme 5

1 Introduction 10

2 The Disability Equality Duty 12

3 The BBC’s Disability Equality Scheme 13

4 Key elements of the BBC’s Disability Equality Scheme 14 4.1 Involvement 14 4.2 Action plan 19 4.3 Performance monitoring 20 4.4 Assessment 29 4.5 Review 31

5 Implementing the Disability Equality Scheme 32

6 Monitoring and evaluation 33

7 Feedback and update 45

8 The BBC’s broader approach to promoting disability equality 46

9 Action Plan 55

Annex 95

Summary of the Disability Equality Scheme

Overview of TV Licensing

“TV Licensing” (TVL) is a trading name used by companies contracted by the BBC to administer the collection of TV licence fees and enforcement of the licensing system.

Outcomes from the BBC’s involvement of disabled people in the development of the Disability Equality Scheme heavily informed TVL’s commitments to promoting disability equality in its activities.

As a result, a comprehensive Action Plan has been established to ensure that disabled people experience and receive appropriate and accessible TVL information, advice and targeted support services. TV Licensing objectives

1 To communicate with disabled people, wherever practicable, in a way that is accessible and appropriate to facilitate a clear understanding of television licensing obligations.

2 To ensure that all BBC TVL staff and contractors fully understand their duty to promote disability equality and are active in implementing actions identified.

3 To continually review and, wherever possible, improve or develop service supports (including technology) to provide maximum access to support and advice services for all disabled people.

4 To develop and maintain a strategic and systematic approach to integrating disability equality into all TVL activities.

5 To maximise the potential for data and information management systems to enhance and promote disability equality.

6 To develop and maintain strategic leadership and commitment to the broad implementation of the Disability Equality Scheme and the TVL Action Plan.

7 To ensure that all payment methods and processes are accessible and appropriate for a range of needs.

8 To ensure a strategic approach to integrating disability equality into all TVL procurement activities.

Supporting each of these objectives is a list of specific actions. Examples of some of these are: Conducting equality impact assessments on relevant communications and policies which are being developed or reviewed.

Continuing to make communications representative and available in a range of styles, formats and languages. Partnership working with organisations which represent and are run by disabled people to inform TVL activities. Continuing to impose contractual obligations on contractors to comply with legal obligations including the Disability Equality Duty and this Scheme and monitoring their compliance. Overview of the BBC Trust

The BBC Trust is charged with upholding the interests of all licence fee payers and placing them at the heart of its decision-making. It is committed to making sure that disabled people in all their diversity are listened to and heard.

The Trust has been in operation since 1 January 2007. Preparing for the original publication of the Disability Equality Scheme involved a combination of monitoring the impact of activities carried out by its predecessors, the BBC Governors, and assessing the new public functions with respect to their relevance in promoting equality for disabled people. Following the BBC’s involvement of disabled people in developing the Disability Equality Scheme, it was possible for the Trust to identify a list of high-level objectives which set out the strategic direction of the Trust’s Action Plan. Given that this is an update of the Scheme just over a year into publication, we have been able to review the progress of the actions set for 2007 and early 2008. BBC Trust objectives

1 To ensure that the Trust actively engages with and seeks the views of disabled people and that engagement activities encourage participation and are accessible. 2 To monitor and assess the BBC’s compliance with its equality duties and on an annual basis publish its observations of such. The Trust will also monitor and assess its own compliance with the equality duties and on an annual basis publish its observations. 3 To provide disabled people with equal and fair access to the BBC’s complaints process. 4 To ensure that disabled people have equality of access to consultations and are involved in Trust decision-making regarding issues which are of a public nature. 5 To ensure that where appropriate and reasonable the Trust’s public reports and communications (including online) are accessible (in language, format and content) for disabled people. 6 To ensure that Audience Councils are fully inclusive and as far as possible reflect the diversity of society they represent. The Trust will actively encourage membership from disabled people wherever practicable and possible. The Trust will also work with Audience Councils to ensure that they engage effectively with diverse communities to enhance members’ understanding of audience concerns. 7 To ensure that diversity and equality matters are integrated into the Trust’s governance tools.

Supporting each of these objectives is a list of specific actions. Examples of some of these are: The Trust’s commentary of the Annual Report and Accounts will include the Trust’s statement on how it sees that the BBC is meeting the needs of different groups of people. The appropriate Trust Unit team will be responsible for conducting an equality impact assessment prior to the Trust commencing any new activity, project, policy, strategy or review that relates to a public function. The outcomes of this will inform further action. When handling appeals, the Trust will ensure that the Complaints Manager will identify and provide the necessary advice and support for those people who are unable to submit their appeal in writing or who may lack literacy skills or the confidence to submit their appeal through the usual channels. The BBC Agreement

In addition to the Royal Charter, the BBC has entered into a Framework Agreement with the Secretary of State for Culture, Media and Sport. This Agreement deals with a number of the BBC’s public functions, including: 1 Digital switchover, including the Digital Switchover Help Scheme, and 2 Some others – in particular, access to UK public services Overview of digital switchover, including the Digital Switchover Help Scheme (i)

In September 2005, the Government announced that digital switchover (changing the television broadcasting network to digital) would take place between 2008 and 2012. The television broadcasting network will change to digital-only, and the public will have to convert or upgrade their TV and recording equipment to receive digital television. Digital UK is the independent, non-profit organisation set up at the request of the Government to manage all communications with the public regarding digital switchover. Digital UK provides impartial information on what people need to do to prepare for the move to digital television. Digital UK is owned by the UK’s public service broadcasters and the transmission companies SDN and National Grid Wireless.

The BBC and Digital UK are fully committed to involving disabled people in making sure that the communication needs of disabled people are listened to and properly considered in the planning, implementation and review of digital switchover rollout. The BBC and Digital UK have worked together to develop this Disability Equality Scheme, informed by the BBC’s involvement of disabled people, and have put into place systematic processes for assessing the communications and information needs of diverse communities and for monitoring progress in meeting those needs over the next three years.

To help ensure that everyone can switch more easily to digital TV, the BBC will manage a help scheme for people who need it, most focused on providing practical assistance and support for people aged 75 years and over, people who receive Disability Living Allowance,

Attendance Allowance and other qualifying benefits, and people who are registered as blind or partially sighted. Involvement of disabled people is a key principle in the development of the help scheme. The BBC has set up a subsidiary, Digital Switchover Help Scheme Ltd (DSHS Ltd), to deliver this function. Digital switchover objectives

1 To assist the “most vulnerable beneficiaries” (older and disabled people) to make the switchover to digital TV.

2 To ensure that the transition to digital-only broadcasting is a fully inclusive process.

3 To ensure that all digital switchover and help scheme related information and modes of communication are appropriate for target audience and are fully accessible.

4 To involve disabled people in the planning and rollout of digital switchover and in the planning and rollout of the help scheme.

5 To gather and use information effectively in order to monitor and assess the impact of current and planned digital switchover policies and practices with regard to disability equality.

6 To ensure effective internal monitoring and Disability Equality Scheme outcomes evaluation.

Supporting each of these objectives is a list of specific actions. Examples of some of these are: BBC Digital UK board members monitor and influence Digital UK activities and ensure that the differing needs of and issues for disabled people are considered and responded to wherever relevant and practicable. Ongoing engagement of Digital UK Regional Managers with a diverse range of organisations, including disability organisations, community and voluntary groups, and local authority social services departments. The BBC will work with Digital UK to identify all key digital switchover policies, functions and project elements and prioritise for disability equality impact assessments. A Digital Switchover Help Scheme, which the BBC is responsible for delivering, is being developed to help those most in need. The BBC will set up internal mechanisms for monitoring progress and reporting to the Diversity Board, BBC Executive Board and BBC Trust. Overview of other BBC public functions (ii)

Under the terms of the Agreement, the BBC must meet a series of access commitments relating to the provision of all UK public services and ensure that important public, security and defence announcements, as well as public documents such as the Annual Report, are accessible to all disabled people. Various key departments across the BBC contribute to

meeting these commitments. As public functions of the BBC, these are now clearly documented within this Scheme in respect of their relevance to the Disability Equality Duty. Systematic processes for assessing and monitoring current or future access as effective and appropriate for disabled people are now in place for the next three years. Other BBC public functions (under the BBC Agreement) – objectives

1 To anticipate and wherever practicable meet the diverse needs of disabled people who access or seek to access UK public services.

2 To anticipate and meet communication needs of those with sensory impairments in order to ensure their access to UK services and to related information and consultation activities (as required by Ofcom’s code).

3 To ensure that specific financial information is fully accessible, through meeting the various communication needs of all disabled people.

4 To ensure that all disabled people have equal access to specific public information announcements.

Supporting each of these objectives is a list of specific actions. Examples of some of these are: The BBC will involve disabled people in monitoring the effectiveness of access services. The BBC will ensure that copies of the Annual Report and Accounts are accessible to all disabled people.

1 Introduction

1.1 The BBC

The British Broadcasting Corporation (BBC) is established as a corporation by Royal Charter. The first Royal Charter was granted on 20 December 1926 and the BBC has subsequently been continued by further Royal Charters, the most recent of which was granted on 19 September 2006. This continues the Corporation for a period of 10 years from 1 January 2007.

The Royal Charter essentially defines the powers of the BBC and its constitutional arrangements, and states that the BBC is to be independent in all matters concerning the content of its output, the times and manner in which this is supplied, and in the management of its affairs.

The most recent Charter was granted after a lengthy and detailed process of public consultation spanning several years. The process included publication of a Green Paper and a subsequent White Paper by the Department for Culture, Media and Sport.

In addition to the Royal Charter, the BBC has entered into a Framework Agreement with the Secretary of State for Culture, Media and Sport. This Agreement deals with a number of important matters, including the following: A statement of the services which the BBC is to provide at the commencement date of the Charter The process which is to be followed for subsequent additions or changes to the BBC’s public services, including the use of the Public Value Test under which the public value of the BBC’s services is to be compared with any potential market impact which a new or varied service may have The obligations on the BBC in relation to the achievement of digital switchover, including managing delivery of the Digital Switchover Help Scheme The regulatory obligations which apply to the BBC UK public services The arrangements relating to the provision of the World Service Fair trading and competitive impact provisions The BBC’s commercial services Complaints The BBC’s relationship with Ofcom A number of other miscellaneous and general matters

The BBC is mainly funded by the television licence fee, the collection of which by the BBC is authorised by section 365 of the Communications Act 2003. After collection the BBC is obliged to pay the sums received to the Government. Under the terms of the

BBC Agreement, sums equal to the amounts collected by the BBC are paid to the BBC, after deduction of the Government’s administration costs. The World Service is funded separately by the provision of grant-in-aid from the Foreign & Commonwealth Office. There are also separate divisions and companies which operate at arm’s length from the BBC. These carry out a number of commercial activities (for example, the sale of magazines, books, DVDs and CDs). The profits arising from these activities are returned to the BBC and used in support of licence fee-funded services. 1.2 The new BBC Charter and Agreement

The BBC is, we believe, unique among the public authorities to which the Disability Equality Duty applies, because it is in the position of having to introduce this Disability Equality Scheme at the same time as introducing an entirely new constitutional and governance arrangement under the terms of its new Charter and Agreement. In particular, the replacement of the BBC Governors by the new BBC Trust has resulted in the introduction of a large number of new functions, many of which are public functions that have not been exercised previously. There are also additional functions for the BBC as a whole, for example relating to digital switchover, including through delivering the Digital Switchover Help Scheme (see page 18).

For this reason the Action Plan contained within this Disability Equality Scheme sets out a series of actions that the BBC believes are appropriate in respect of its public functions, which will be addressed during the three years of its operation. These actions will be updated and amended annually as necessary, having regard to ongoing feedback from involvement with disabled people. 1.3 Application of the Disability Equality Scheme to Northern Ireland, the Channel Islands and the Isle of Man

The equality duties do not legally apply where the BBC is exercising public functions outside Great Britain. However, it has been determined that, so far as is practicable, the BBC will voluntarily apply standards which are substantially similar to the equality duties when exercising its public functions across the United Kingdom, in the Channel Islands and in the Isle of Man.

2 The Disability Equality Duty

2.1 The Disability Discrimination Act 1995 (as amended) (DDA)

The DDA was amended in 2005 so as to require public authorities to fulfil a Disability Equality Duty. This duty encompasses requirements: To promote equality of opportunity between disabled persons and other persons To eliminate discrimination that is unlawful under the Act To eliminate harassment of disabled persons that is related to their disabilities To promote positive attitudes towards disabled persons To encourage participation by disabled persons in public life To take steps to take account of disabled persons’ disabilities, even where that involves treating disabled persons more favourably than other persons

The Disability Equality Duty applies to most public authorities in respect of all of their functions. However, in the case of the BBC, it applies only “in respect of its public functions”. This means that not all functions of the BBC are subject to the requirement to fulfil the Disability Equality Duty.

The BBC believes that the correct approach to defining its public functions is to look at the nature of the function involved rather than the nature of the body carrying out the function or the nature of its funding. For this reason, regulatory functions are likely to be public functions, whereas the BBC’s output-related activities (for example newsgathering and programme-making) are not. The application of general principles of this type to specific situations involves detailed analysis which it would not be appropriate to set out in this document. However, the result of the analysis that has been carried out – that is, a definition of those functions of the BBC which are considered to be public functions – is set out in the Annex to this Scheme. Section 3 of this Scheme sets out what the BBC intends to do in order to fulfil the Disability Equality Duty in respect of each of these functions. In addition, section 8 sets out the BBC’s broader approach to promoting disability equality. Various specific actions and targeted initiatives are detailed, as well as examples of more long-standing and routine good practice across the BBC. Although these are not requirements under the Disability Equality Duty, which relates only to public functions, they do nevertheless demonstrate the BBC’s positive and inclusive approach towards disabled people as employees, audiences and TV licence fee payers, as well as its clear intention to fully meet additional specific duties relating to equal opportunities which are placed on it by the BBC Charter and Agreement (ref. Charter Article 44 (1) (a) and (b) and (2) (b), and Agreement Clause 83).

3 The BBC’s Disability Equality Scheme

The BBC’s Disability Equality Scheme forms a part of the BBC’s overall commitment to equality and diversity. The Scheme outlines a framework for how the BBC will develop, implement, monitor and review its work towards achieving equality for disabled people (and their carers) in relation to its relevant public functions. The Scheme is a tool to help promote disability equality at the centre of the BBC’s work and specifically across relevant areas such as TV licensing, digital switchover and the BBC Trust’s operations.

The Disability Equality Scheme aims to build on a strong foundation of existing good practice and expertise. The BBC has always sought to address any identified gaps and barriers to delivering fair, accessible and appropriate services. It has also sought to protect the rights of disabled people both at work and in the wider community and to engage with them in order to understand their concerns and meet their needs wherever possible. This Scheme, therefore, aims not only to ensure full compliance with the general duty with regard to the BBC’s public functions, but also to provide some information relating to the BBC’s previous and current efforts to ensure equality of opportunity and access for disabled people (albeit that this does not technically form part of the Scheme).

4 Key elements of the BBC’s Disability Equality Scheme

The Equality and Human Rights Commission has set out five key elements or principles on which the Disability Equality Scheme should be based. Under each element there is a list of ways by which the BBC will work to deliver its commitment to disability equality. The five key elements are: 4.1 Involvement 4.2 Action plan 4.3 Performance monitoring 4.4 Assessment 4.5 Review 4.1 Involvement – a statement of how disabled people have been involved in developing the Scheme

All Disability Equality Schemes are required to be updated in the light of experience and ongoing involvement with disabled stakeholders, and this will particularly be the case in relation to the BBC’s Scheme. The BBC is committed to continually reviewing and developing its Scheme so as to maximise its relevance to the delivery of real benefits for disabled people in relation to the performance of the BBC’s public functions.

The first draft of this Scheme was developed during the autumn of 2006, against a constitutional background which was being clarified and finalised at the same time. An expected outcome of this process was that there would be a substantially different analysis as to the nature of the BBC’s public functions (as set out in the new constitutional arrangements of the BBC’s new Charter and Agreement). For this reason any meaningful involvement of disabled stakeholders during the Scheme’s very early development was necessarily limited during that period. 4.1.1 Previous and recent involvement of disabled people The BBC had, however, previously involved and consulted disabled people in a number of ways with regard to the performance of the public functions which are now covered by the Scheme. These initiatives are listed below: BBC Trust Charter review consultation TV Licensing Digital switchover, Digital Switchover Help Scheme and Digital UK Consulting disabled BBC staff (See also section 4.3 for details of the BBC’s involvement and information-gathering activities.)

The outcomes of this previous involvement and consultation, and very recent involvement and consultation about the Help Scheme, have informed the Scheme and in particular the Action Plan. 4.1.2 Disabled people’s involvement with the development of the Disability Equality Scheme This newly reviewed Scheme (February 2007) is informed by the outcomes of planned involvement activity with disabled people, which was carried out as part of the Scheme’s development. The activity was conducted through questionnaires and focus group meetings during the course of November 2006 and was launched following the final settlement of the BBC’s new constitutional arrangements by means of the grant of the new BBC Charter. The outcomes of this planned involvement activity have now been considered by relevant sections of the BBC. Details of the involvement activity and the headline findings are reported below and reflected within the Action Plan as appropriate.

The Scheme was subsequently updated in February 2008 to include more recent work relating to digital switchover, including involvement activity.

Involvement process The BBC retained the services of specialist consultants Churchill, Minty & Friend to help with the design and implementation of an involvement strategy.

The first phase of this, which was implemented during October and November 2006, involved a questionnaire which was made available by post, in accessible formats (on request) and via the BBC Ouch! website. The survey canvassed the views of disabled people about each of the areas identified as public functions. In addition, four focus groups were held in London, Manchester, Edinburgh and Cardiff (a specific focus group was held in Cardiff for people with learning difficulties or disabilities).

To promote participation and enable some disabled people who were unable to attend the focus groups to have their views heard, an advertisement was placed in Disability Now magazine, which reaches a number of disabled people nationally. Respondents were offered the chance to win a pair of tickets to visit the BBC studios. The questionnaire was also promoted via an electronic contact list held by Churchill, Minty & Friend. Provision was made to offer support via telephone for those who wanted assistance to complete the questionnaire, along with an invitation to attend a focus group for those who found questionnaires inaccessible.

A number of known disabled individuals and organisations were contacted and invited to attend the focus groups. This sample had a diverse make-up, with people representative of a range of impairments, access needs and specific knowledge within a given disability arena. Significantly, these stakeholders represented a number of national and local disability organisations. Efforts were made where possible within a disability equality context to explore the diversity of the disabled community to reflect the different access needs experienced by certain impairments groups.

The focus groups were designed to explore concerns, barriers and the experiences of disabled people with respect to the BBC public functions included in the Scheme. The BBC made the necessary arrangements to ensure that the focus groups were accessible, for example by providing induction loops, speech-to-text and BSL interpretation, as well as funding transport costs. All disabled participants were given a small token payment for their assistance with this project, in line with DRC good practice guidance.

Involvement findings and further action The various BBC teams which manage the public functions involved have considered the outcomes of this work carefully and agreed priority actions which are now included within this updated Disability Equality Scheme.

The findings reflect disability within the context of perceptions and experiences of engagement with the BBC in relation to three specific areas of focus: TV licensing (a public function) Digital switchover, including the BBC’s responsibility to deliver the Digital Switchover Help Scheme (a public function) – see also section 4.3.3 and Action Plan 3 (i) Involvement (disabled people’s perception of the BBC and involvement with the Trust in particular)

Some overarching themes emerged in relation to all three areas, including: Communications – for example, issues were raised about the benefits of digital broadcasting to enable audio description, while BSL interpretation and subtitling and the provision of written information formats were identified as presenting access issues across all three areas. Representation and involvement – of deaf or disabled people. Publicity – about BBC activities by the relevant public functions, with specific regard to disabled people and how the needs of this section of the BBC audience are met. Information resources – are they appropriate and accessible enough to encourage disabled people to make informed decisions when engaging with services or changing digital equipment?

TV Licensing – summary of key issues Access Most people found it accessible to purchase their TV licence. Barriers identified included some PayPoint outlets and whether people have access to bank accounts, etc. NB: The latter issue was identified in qualitative feedback from the focus groups rather than in quantitative feedback from the survey. It was helped by the regulations change on 1 April 2007, when cash payment schemes became available to all, not just to those on income-related state benefits.

Equity and fairness Some confusion existed in relation to the blind concession. There was debate about whether charging was fair for people who are visually impaired and/or deaf. NB: Concessions are defined through legislation, but the debate may highlight a communications issue.

Contact with customer services The TVL team does not have the means to support communication with people who use British Sign Language (BSL). There is a perceived lack of awareness of diverse additional needs. Some examples of positive experiences were highlighted. Improvements suggested including training and developing preventative programmes to educate some groups who may fail to pay their licence fee, such as people with learning difficulties.

Digital switchover – summary of key issues Awareness Most people were aware that changes were taking place. There were some concerns about lack of awareness in other sections of the disabled community, for example elderly parent carers and elderly disabled people. Targeted information provision could address information and knowledge gaps (for example, clarification over the radio changes, teletext, and greater promotion of suitable, affordable equipment which meets specific needs, such as digital boxes that enable subtitling and audio description). Concerns included identifying difficulties in setting up equipment and ensuring that services are compatible with environmental controls. Cost was another area of concern.

Information This needs to be provided in suitable formats and must address the (often more specific) questions of this target audience. Involvement – summary of key issues Approachability and access Quantitative data suggests that disabled people in the sample felt that the BBC was approachable. However, barriers included determining how disabled people could approach the BBC. For example:

Telecommunications – difficulties not just in gaining access to a textphone number, but also the customer services team not being able to respond to an incoming textphone call. Complaints – general dissatisfaction with BBC responses to complaints made and perception that the organisation does not recognise, acknowledge and represent lifestyles and issues of disabled people. Engagement events and initiatives – involvement with consultation events and panels was limited and perceived as tokenistic. Perception that there was never any feedback from consultation undertaken.

General perceptions – a summary Overall, disabled people who engaged in the study felt that: The BBC was a very good organisation, but it failed to recognise disability equality sufficiently. There were a number of good things identified about what the BBC is currently doing but little was communicated. Improved communication, regular involvement and published feedback were needed. Sustainable involvement should be a process of long-term engagement. Sustainable involvement should also be a shared learning experience between key disabled representatives and the BBC. All interaction and engagement points should be reviewed in terms of encouraging accessible communication, including the promotion of opportunities. The BBC should aim to disseminate information to this section of the BBC audience. Many of those who participated in the study expressed an interest in engaging in such an involvement process.

Digital Switchover Help Scheme The BBC is responsible for delivering the Digital Switchover Help Scheme which will provide practical help in switching to digital television for disabled and older people who qualify for the scheme under rules set by Government. In order to deliver against this responsibility the BBC has set up a subsidiary, Digital Switchover Help Scheme Ltd (DSHS Ltd), to deliver this function.

The BBC (through its subsidiary DSHS Ltd) has worked to involve disabled people in its activities through various projects and initiatives.

For further information on the Help Scheme, see section 4.3.3.

4.2 Action plan

The BBC Action Plan in respect of its public functions consists of three main sections. These are television licensing functions, certain functions of the BBC Trust and certain functions of the BBC under the BBC Agreement. 4.2.1 Action planning and review The Action Plan is based on the outcomes of involvement and consultation with disabled people and staff and on the outcomes of disability equality impact assessments. The key areas that emerged, which were found to be of most importance or concern to disabled people, varied depending on the public function under discussion (see 4.1 above for more detail). The Action Plan sets out the steps which the BBC intends to take during the first year of the Scheme to address these key areas and work towards ensuring disability equality in relation to its public functions (see section 9, Action Plan).

The Disability Equality Scheme runs for three years from 4 December 2006 to 3 December 2009, and all objectives contained within it should be met by the end of the third year. The Scheme and its Action Plan in particular are subject to regular updates and formal annual reviews.

The BBC will continue to consult with and involve disabled people in order to monitor its operation and assess the impact of actions implemented. Feedback will inform the annual review process and help the BBC to update or set new actions to meet its disability equality objectives over the Scheme’s three-year period. (Details of the way in which disabled people will be involved are set out in section 4.4.) The BBC will review and, if necessary, update and amend the manner of involvement based on an evaluation of how successful these processes have been.

During the third year of operation of the Scheme, the BBC will conduct a more detailed review of the steps taken over the entire period to decide what actions are appropriate in respect of the BBC’s public functions thereafter. These actions will then be incorporated into a new Scheme. 4.2.2 Ownership and implementation The BBC Trust is responsible for overview and scrutiny of the Disability Equality Scheme (DES). The three-part Action Plan embedded within the Scheme is the responsibility of the Director-General and other members of the BBC Executive Board within the BBC divisions, and of the BBC Trust Unit. The pan-BBC Diversity Centre is responsible for liaising with relevant divisions, disseminating best practice and providing guidance, and monitoring progress of the Disability Equality Scheme Action Plan at corporate level.

Each relevant divisional director is responsible for implementing the DES and the specific local actions which have been identified as a result of consultation and equality impact assessments at divisional level. These will be monitored within each division and progress will be reported at the Diversity Board and Executive Board. Implementation of the DES is scrutinised by the BBC Trust.

4.2.3 Structure and content The Action Plan is divided into the three public function areas of the BBC’s activity: Television licensing functions Certain functions of the BBC Trust Certain functions of the BBC under the BBC Agreement, for example digital switchover including the BBC’s responsibility for delivery of the Digital Switchover Help Scheme

Within each section, key objectives have been set which aim to achieve the positive outcomes that disabled people and their carers have identified as most important to achieving disability equality. Specific actions support one or more of the Scheme’s key objectives, which are all underpinned by core BBC values relating to diversity. Actions have been informed directly by disabled people or arise out of recommendations made following a range of engagement and consultation initiatives plus various initial reviews of current activities.

Background information on each of the relevant function areas and examples of how the BBC carries out, or intends to carry out, each of the public functions covered by the Scheme has been provided as part of the introduction to each section of the Action Plan. 4.3 Performance monitoring – arrangements for gathering information about the performance of the BBC on disability equality

This section provides examples of how the BBC gathers information on its own performance through examining its current activities and function processes and by investigating the specific needs and barriers to access which may be identified through the outcomes of involvement with disabled people and other relevant research.

Information and evidence gathered will now be used to: Inform Disability Equality Scheme review processes and any additional work areas which fall outside its scope. Benchmark against other broadcast industry providers and allow for broad comparison against a range of other public bodies where appropriate. Systematically identify barriers and gaps which may impact negatively on disabled people. Understand and wherever possible respond appropriately to diverse and constantly changing needs. Examine and assess outcomes. Inform future planning processes target setting, where appropriate.

Previous and current information gathering 4.3.1 TV Licensing “TV Licensing” (TVL) is a trading name used by companies contracted by the BBC to administer the collection of TV licence fees and enforcement of the television licensing system1.

Regular and targeted involvement The BBC and TV Licensing (TVL) have been working with a number of key stakeholders to both gather and share information. In particular there is a regular dialogue with the Royal National Institute for the Blind (RNIB), Royal National Institute for Deaf People (RNID), Mencap, Age Concern, Help the Aged and Citizens Advice. (Age Concern, Help the Aged and Citizens Advice all liaise with organisations which represent disabled people.)

Information is gathered and planned changes in TVL processes are discussed so that the views and needs of disabled people help to shape developments. These processes have resulted in, for example:

Actions The Over 75s licence is now produced on different coloured paper to make it easier to read, and information about the licence is provided in a larger print, following liaison with RNIB and Help the Aged. During the transition to new PayPoint-delivered TVL services, plans to require the use of a PIN number with the savings card were discarded as it was clear that it would be more difficult for some customers to use. 4.3.2 The BBC Trust The BBC Trust is supported by the BBC Trust Unit which in January 2007 took over from the Governance Unit, which had supported the BBC Governors previously.

Specific consultation on the new governance framework embedded in the Charter and Agreement The Government carried out extensive public consultation connected with the transition to the Trust. The BBC’s Governance Unit also offered disabled licence fee payers the opportunity to meet with Governors and tell them first hand what they thought of the BBC’s programmes and services, which informed the development of Trust protocols on audience engagement and the BBC Audience Councils.

1 The majority of the administration of TV Licensing is contracted to Capita Business Services Ltd (which undertakes the majority of the TV licensing system), with the administration of cash-related payment schemes contracted to Revenue Management Services Ltd (RMS). PayPoint Collections Limited is contracted to provide over-the-counter services. The marketing and public relations activities are contracted to the AMV Consortium. The consortium is made up of the following four companies: Abbott Mead Vickers BBDO Ltd, Fishburn Hedges Boys Williams Limited, PHD Media Limited and Proximity London Ltd. The BBC is a public authority in respect of its television licensing functions and retains overall responsibility.

Equalities monitoring The Trust uses a number of tools to monitor its performance in meeting its disability equality duties. In May 2007 the Trust rolled out both diversity monitoring forms and equality impact assessments across the Trust Unit. These are regularly reviewed by the Trust Unit’s Equalities Working Group, which also ensures that the insight gained from these two tools is captured and that any resulting actions are followed up. The Trust also contributes to the BBC’s quarterly compliance report, which tracks the progress of the commitments made in this Action Plan.

The Trust also carries out regular audience research, for example the annual Purpose Remit survey, conducts public consultations and draws on the feedback and insight from its Audience Councils across the nations and regions. Further information on all of these is given below.

The Audience Engagement Protocol The Royal Charter requires the BBC Trust to publish a protocol which sets out how it will “actively seek the views of, and engage with, licence fee payers” and that, before doing so, it must consult the public. Between 14 May and 3 August 2007 the BBC Trust conducted its Audience Engagement consultation, which through a variety of mediums (online consultation, leaflets, quantitative and qualitative research and working lunches with interest groups) sought feedback on different types of engagement methods. Having considered all of the information which was gathered during those three months, the Trust then published the protocol ‘Our Promise to You: How the Trust will Engage with Audiences’. The following is an overview of some of the quantitative findings.

A low proportion of those who took part in the quantitative research expressed a desire for active engagement with the BBC Trust, or indeed any other organisation. Only 15% said they regularly shared their opinions, views and feedback with organisations generally. (This figure dropped to 6% for people who were over 65 and disabled.) Eight per cent of all respondents said they had given feedback to the BBC. (There was no such significant difference between disabled and non-disabled people for this figure.) Where participation did take place it tended to centre on local and personally relevant issues such as schools, hospitals or utilities.

When asked about taking part in specific BBC Trust activities or decisions, only 6–14% said that they would want to be personally involved. However, most respondents felt that the Trust should provide as many opportunities as possible to encourage people to get involved with the work of the Trust, with 73% saying that it was important for people to have a say in the running of the BBC.

When asked about the methods they generally used to share their opinions, views and feedback with organisations, the top three responses (across all groups) were: 1 Took part in research

2 Wrote a letter to the organisation

3 Made a phone call to the organisation

This was not a consensus across all groups and in fact the results showed that disabled people over 65 were much less likely to say that they had taken part in research (it dropped to third in their list, behind writing a letter and making a phone call to organisations).

With regard to the Trust consulting, there was a clear view that consultation documents should be written in plain English, should not be overly technical, and should not require a great deal of prior knowledge by the respondent. Respondents also felt that it was important that consultations were well publicised, including specifically targeting key groups in order to reach a wide range of people. In terms of the ways of consulting, there was support for using a range of methods. Respondents appreciated the need for a mix of formal consultation alongside structured research and work with interest groups. In terms of different tools, care needed to be taken not to exclude anyone – the consultation submissions were particularly vocal about not relying on online methods alone.

Purpose Remits survey The Trust’s annual Purpose Remits survey provides a comprehensive and consistent tool for understanding the perceptions of licence fee payers on the high-level delivery of the purpose priorities. In its second year, the Trust ensured that the survey captured the views and attitudes of a more diverse audience. As a result it has been able to interrogate the data to draw out any differences based on equality strands including disability. The 2008 survey revealed that: Disabled people under 65 years of age were more likely than the general population to say they would change the BBC significantly given the opportunity (30% versus 15%). Also, while only one in seven of the population were low approvers of the BBC, giving it a rating of four or less out of ten (14%), this increased to one in four people with disability aged 15–64 (24%).

To note: the BBC is now working in collaboration with Channel 4 to understand the needs and attitudes of our disabled audiences in more detail.

Audience Councils The Audience Councils exist to bring the diverse perspectives of licence fee payers to bear on the work of the Trust. Audience Councils’ links with diverse communities and their programme of outreach and other activities allow them to provide a broadly based assessment of audience needs, interests and concerns, thereby bringing audience voices to the heart of the Trust’s work. Over the course of last year and early 2008, the Councils have organised a number of outreach events and activities. These have involved a rich and diverse mix of members of the public and organisations representing different communities and groups. The format of these events varies across and within each nation, with some specifically targeting audience groups and some focusing on key discussion topics. Any potential barriers to participation are considered when developing an event, so that, where possible, accessibility or other special needs can be addressed.

These information-gathering mechanisms and sources of information have resulted in the following actions:

Develop a set of principles which will aid the way in which the Trust commissions its research and collected classification data so that it improves its understanding of diverse audiences. Working with staff, improve the implementation of diversity monitoring forms, so that there is greater consistency and regularity of use across the Trust Unit. Continue to monitor the diversity of Audience Council members to inform action planning and review where necessary. Ensure that the Trust website meets both the statutory and the BBC’s accessibility requirements. 4.3.3 Digital switchover and Digital UK In September 2005, the Government announced that digital switchover would take place between 2008 and 2012. Digital switchover is the process of changing the television broadcasting network to digital. It involves converting the current analogue television network, as well as encouraging the public to convert or upgrade their TV and recording equipment so that they can receive digital television.

A Ministerial Group on Digital Switchover has been set up to manage digital switchover. The Ministerial Group meets around four times a year and is co-chaired by the Department for Business, Enterprise & Regulatory Reform (BERR) and the Department for Culture, Media and Sport (DCMS). The Ministerial Group also includes representatives from Digital UK, Ofcom, BERR, DCMS, public service broadcasters (BBC, ITV, Channel 4, Five, S4C and Teletext), non-terrestrial platform operators, consumer bodies, retailers and manufacturers.

Digital UK is the independent, non-profit organisation set up at the request of the Government to manage all communications with the public regarding digital switchover and the Digital Switchover Help Scheme (although the BBC subsidiary DSHS Ltd also has some responsibility in this area). Digital UK provides impartial information on what people need to do to prepare for the move to digital television. Digital UK is owned by the UK’s public service broadcasters and the transmission companies SDN and National Grid Wireless.

Digital switchover is a public function for the BBC and the BBC is a key stakeholder in many elements of the digital switchover programme being managed by the Ministerial Group. Digital switchover communications are part of the public function of the BBC and, as mentioned above, this work is being managed and implemented by Digital UK.

As well as managing the communications for digital switchover, Digital UK is also working with digital TV platform operators, equipment manufacturers, installers, retailers, rental companies and consumer groups to coordinate the technical rollout of digital television across the UK.

Digital UK is consulting with a number of groups of disabled consumers and audiences in different areas of the UK as part of its communication planning for the regional rollout of digital switchover. It is gathering regional information from consumers and audiences through its Regional Managers and via its Consumer Experts Group (CEG), which includes representation from the RNIB, Help the Aged, Age Concern, RNID, VLV, CAB, SENSE,

NCC, OCP, ACRE, TAG, Wireless for the Bedridden, and the Ofcom Advisory Committee on Older and Disabled People. The CEG meets regularly to discuss the planning, implementation and management of digital switchover.

Digital Switchover Help Scheme To help ensure that everyone can switch more easily to digital TV, the Government has announced that the BBC will manage a Help Scheme for people who need it most.

The Help Scheme is focused on providing practical assistance and support for people who: are 75 and over receive Disability Living Allowance, Attendance Allowance, Constant Attendance Allowance or Mobility Supplement are registered as blind or partially sighted

The scheme will help people to select, install and use digital television equipment and will include: assistance with choosing the service equipment designed for ease of use providing equipment to convert one TV set help with installation follow-up support The scheme will cost £40 to participate in, but will be free to those receiving Income Support, Job Seeker’s Allowance or Pension Credit.

The BBC’s subsidiary DSHS Ltd expects 7 million households to be eligible for the Help Scheme in the UK. These households will be able to opt in region by region between 2008 and 2012.

A pilot Help Scheme was delivered in Copeland/Whitehaven, where digital switchover was trialled in 2007. A full evaluation will inform how both digital switchover and the Help Scheme are introduced across the country. See the report: www.digitaluk.co.uk/__data/assets/pdf_file/0004/9670/DUK_Copeland_ReportWEB010508.pdf.

The BBC, through its subsidiary DSHS Ltd, has selected eaga plc as its preferred supplier for delivering help scheme services. For more information on the Help Scheme please visit: www.digitaltelevision.gov.uk/helpscheme/hs_home.html.

How disabled people have been involved Through its subsidiary DSHS Ltd, the BBC has consulted with disabled people and disability organisations to inform the Help Scheme.

During the summer of 2007 the BBC led a consultation and involvement process to shape the development of the Help Scheme. The BBC involved disabled and older people and voluntary sector organisations specifically in the development of this service. Interviews with

over 30 organisations informed a series of focus groups with nearly 150 people who have positively informed:

The service itself, including detail around the planned contact centre, home visits including delivery of equipment and installation, payment, security, instruction manuals and help sheets, aftercare, the complaints process, recruitment of contact centre staff and training for engineers and contact centre staff The Code of Service Standards – a set of service standards anyone eligible can expect to receive Meeting individual requirements according to impairments, including visually impaired and partially sighted people, people with mobility impairments, learning disabled people, people with mental health problems and people with multiple disabilities Appropriate communication formats How the successful organisation contracted to deliver the service will be appointed and then measured on performance

DSHS Ltd conducted over 30 interviews over a three-week period with organisations representing Help Scheme target audiences, including people over 75, people with a range of impairments, carers and members of the Consumer Expert Group (CEG). The aim of the consultation was to obtain as much information as possible to ensure that the Help Scheme is fully accessible to, and inclusive of, disabled people. Each interview took place at an accessibility-audited location and lasted around one and a half hours.

Care was taken to ensure that the organisations identified for interviews and the participants in focus groups were a diverse group representing a range of lived experience in terms of impairments, gender including trans people, ethnicity, language, geographical location, and literacy skills. Carers were also represented in the focus group discussions.

The findings from the consultation led to the development of the Help Scheme’s Code of Service Standards. The Code of Service Standards is the commitment the Help Scheme makes to all people eligible for the service and is designed to help people know: What they can expect from the Help Scheme What is available through the Help Scheme and what the process will be like That any individual requirements will be met Where to go if more information is required

Without a Code of Service Standards, the Help Scheme could have created and reinforced barriers for disabled and older people. The purpose of the Code is to design out any potential disability discrimination.

The Code of Service Standards forms part of the contract with eaga plc, the service provider, and is a specific requirement of the Help Scheme Agreement (the legal document outlining the BBC’s obligations for delivering the scheme).

The impact of the Code for all disabled and older groups will be monitored on an ongoing basis through customer satisfaction and annual consultations. Any complaints or feedback will be addressed.

The consultation identified the need for all staff developing the Help Scheme to have awareness of the needs and views of disabled people and, where appropriate, training to ensure that the needs of disabled people can be easily and consistently identified.

The consultation also identified various ways in which the Help Scheme itself could be more accessible and inclusive of disabled people, including the following; Marketing and identification materials will be made available in various alternative formats with additional available features (such as audio description, BSL interpretation, subtitles and other languages). Customers will be able to pay any fees due in instalments. Call centre staff and equipment installers will be made aware of and sensitive to the requirements of disabled people and where possible will work to recruit disabled staff. A help sheet will be available to people eligible for the Help Scheme to allay any fears.

DSHS Ltd also commissioned quantitative research to explore and establish the needs and requirements of those in the eligible groups and to provide feedback on relevant issues to inform the development of the Help Scheme and to develop ways to maximise its take-up, including among those most disadvantaged. From the responses it was clear that eligible people broadly understood the assistance that will be provided by the Help Scheme including installation, user instructions, equipment and materials, with additional features such as BSL interpretation and large print documentation.

To ensure that the Help Scheme does everything possible to assist people to make the switch to digital, and recognising that a minority of people eligible for the Help Scheme will experience greater difficulty, DSHS Ltd has initiated a programme of work called Maximising Reach. This work is designed to help reach people who are particularly isolated and to break through those multiple barriers. This work will address disability, ethnicity, gender, disability and age, and aims to remove any barriers to accessing the Help Scheme.

The DCMS and BERR have consulted with a number of groups of disabled consumers and audiences on digital switchover and the Digital Switchover Help Scheme (see www.digitaltelevision.gov.uk/helpscheme/hs_home.html). In 2005/2006, BERR and DCMS ran a trial in Bolton which forms the basis of the Help Scheme. (The full report from the Bolton Trial is available at www.digitaltelevision.gov.uk/press/2006/dcms080_06-bolton.html.)

Ofcom and Digital UK are also tracking and recording the perceptions and opinions of disabled people (those who describe themselves as disabled based on the Disability Discrimination Act – Amended 2005 definition and those in receipt of Disability Living Allowance or Attendance Allowance) regarding the digital switchover process, as part of its regular tracking survey. In the most recent report of the Ofcom/Digital UK Tracker (Quarter 1 2008), 429 of the 2,819 total respondents identified themselves as disabled.

Digital UK and the Ofcom Advisory Committee on Older and Disabled (ACOD) commissioned qualitative research in early 2007. This included focus groups and in-depth interviews with: Those with cognitive impairment (early stage dementia, learning difficulty) Blind and partially sighted Those with hearing impairments Those with mobility or dexterity impairment Carers of the above Informal family and friends Local voluntary supporter networks Social services

Results were published on completion and used to further inform this Scheme as appropriate.

Information on needs and barriers is also collected via a Usability Action Plan which has been established by the BERR. Manufacturers and consumers meet regularly to discuss digital switchover and specifically digital TV receiver equipment.

In addition, ‘mystery shopping’ surveys at commercial outlets include a quota of older and disabled store assessors who gauge the accessibility and appropriateness of service and advice given.

ACOD and a variety of other organisations contributed to a report entitled ‘Digital Switchover – An Audit of Viewers’ Priorities’, which was produced by Ofcom in July 2006. This research into the needs and potential barriers to accessing digital services helps to inform future planning around specific needs.

These information-gathering mechanisms and sources of information have resulted in the following.

Actions Ministerial Group established to manage the digital switchover programme. Digital UK in place to coordinate the digital switchover programme and to act as a single point of focus for digital switchover communications. Digital UK contact centre live agents are provided as an alternative to automated information through a main menu option and can action requests for generic information leaflets in alternative formats (Braille, large print and audio formats). A text service is provided for those with hearing impairments. A Digital Switchover Help Scheme, which the BBC is responsible for delivering, is being developed to help those most in need. The industry is currently exploring easy-to-use remote controls to make digital TV services more accessible.

4.3.4 Consulting disabled BBC staff The BBC convened a group of disabled staff during 2006 to discuss the feasibility of launching a Disability Forum and to consult them about what the organisation needs to do now to become more disability aware and inclusive. Prior to this there has been a small internal mailing list for BBC disabled staff, but no formal representative mechanism to consult them about BBC plans which affect them. The Forum has been consulted on the reviewed Disability Equality Scheme and, although employment falls outside the scope of the Scheme, their views and formal response to it will help to inform broader BBC strategy review in this area. The Forum’s remit goes beyond that of this Scheme, but nonetheless its work is important in relation to disability and the BBC’s public functions. Information gathered has resulted in the following.

Actions Invitation issued to all disabled BBC staff and interested colleagues to participate. Agreement reached to press ahead with plans for the Forum. The core group of the new Disability Forum met with the Director-General, Mark Thompson, to brief him about the issues and their views on what the BBC should be doing. Progress on disability, including this scheme, is now formally monitored by the BBC’s Diversity Board, which consists of the Director-General and the divisional directors. 4.4 Assessment – arrangements for assessing the impact of the activities of the BBC on disability equality and improving these when necessary

The methodology which the BBC will use to assess the impact of its public functions (or the policies and practices relating to the performance of those functions) with regard to disability equality is likely to vary according to the nature of the public function concerned. Assessment timetables relating to each function will also vary because many of the public functions to which this Scheme applies were introduced by the BBC’s new Charter and Agreement, which only came fully into force on 1 January 2007. Nevertheless, preliminary assessments of activities which were scheduled or likely to take place in pursuance of these functions were made by the relevant parts of the BBC during the initial development of this Scheme, and the Action Plan for 2007 reflects this preliminary assessment.

With regard to existing public functions such as TV licensing, involvement and consultation with disabled stakeholders had been taking place for a considerable period. This has been recognised as a valuable method for assessing the impact of TV licensing activities or planned activities (see section 4.3 and the introduction to the TVL Action Plan for more detail). 4.4.1 Equality impact assessments To ensure a systematic and consistent approach to assessing existing or potential differential impact and to identifying specific needs requirements, the BBC will formalise equality impact

assessment processes across all relevant public functions. The BBC will do this in line with recommended good practice and in order to meet the specific disability equality duties as they apply to the BBC’s public functions, equality impact assessments (EIAs) will help the BBC to: Identify any adverse impacts in carrying out the relevant public functions (or implementing policies and practices related to those functions). Identify unmet needs which may become apparent when carrying out the relevant public functions (or implementing policies and practices related to those functions). Ensure that action is taken to address identified areas above. Inform future (disability) equality action planning and review of the Disability Equality Scheme. 4.4.2 Retrospective EIAs The BBC identified and prioritised a series of (disability) equality impact assessments where relevant, and these were conducted during 2007 (see individual Action Plans). The outcomes of these assessments and related consultation were used to inform policy and planning processes, with specific actions being included in the relevant Action Plans during the three-year period. 4.4.3 Predictive EIAs Any new policy or practice relating to a BBC public function (or any new function which is identified as public by the BBC) will be considered for an impact assessment as a matter of course, and the outcomes of the assessments conducted will be used to inform future review of the Scheme. 4.4.4 Consultation and involvement Where a full equality impact assessment is identified as relevant and proportionate to the duty to promote disability equality, the following consultation mechanisms will be considered: Consultation with and involvement of disabled colleagues from within the BBC and other broadcasting industry groups. Consultation and involvement with a range of organisations of and for disabled people in different locations across the UK. Questionnaires, surveys and other forms of information-gathering published in appropriate media including print, broadcast and online, particularly those which are addressed to disabled stakeholder group audiences. Focus groups held in suitably diverse locations which meet appropriate accessibility requirements.

The above activities may also be carried out at appropriate intervals as part of other wider consultation activities, and relevant information or evidence will be used to assess impact, inform action and influence the three-yearly review of this Scheme.

4.5 Review – details of how the BBC uses information gathered, in particular in reviewing the effectiveness of its Action Plans and preparing subsequent Schemes

All of the information-gathering, analysis and usage processes detailed above will be used as part of an ongoing review process.

Disability Equality Scheme outcomes will be evaluated on a regular basis in consultation with disabled people. The Scheme will be reviewed annually with a major review after three years.

In addition to reviewing disability equality performance with regard to the public functions covered by the Scheme, the BBC will always seek to move beyond mere compliance and consider the effectiveness of its policies and procedures through engaging disabled people on a variety of other matters.

5 Implementing the Disability Equality Scheme

The implementation of the Disability Equality Scheme will be driven by the BBC Trust Unit insofar as it relates to the Trust, and otherwise by the BBC Executive Board and carried out at relevant divisional level.

The Scheme runs for three years from 4 December 2006 to 3 December 2009, but is subject to regular updates as well as formal annual reviews. The objectives contained within the Scheme should all be met by the end of this three-year period, though further objectives will be developed over time to ensure that the BBC continues to implement disability equality relevant to its public functions and achieves the specific priority outcomes identified by disabled people (see also section 4.2 for more detail).

6 Monitoring and evaluation

Progress on the Disability Equality Scheme Action Plan will be monitored and evaluated by the Trust Unit and management teams responsible for each relevant public function. Each management team reports to the Executive Board, which is accountable to the BBC Trust. In 2006 the BBC also set up a Diversity Board, led by the Director-General, Mark Thompson.

This body agrees and drives forward the BBC’s wider diversity agenda. The structure chart below shows formal reporting lines (arrow lines also indicate advice and information flow).

Each Disability Equality Scheme Action Plan section has an in-built monitoring system (see section 9) which will be used to measure progress and its effectiveness in achieving intended outcomes.

Throughout the three-year period, the BBC will continue to consult with and involve disabled people to monitor implementation and assess the impact of actions, in order to maintain a continual cycle of improvement.

This is the third draft of the BBC’s first Disability Equality Scheme, which has been updated, amended and reshaped following: Dialogue with the Disability Rights Commission Analysis of feedback from the November 2006 core involvement activity Further development of the Digital Switchover Help Scheme arrangements (February 2008)

The BBC Trust The Trust Unit

BBC Executive Board

TV BBC Any other Digital switchover Licensing Diversity relevant public including Board Digital function Switchover areas Help Scheme

Digital BBC UK

Diversity (external) Centre

6.1 Disability Equality Scheme Performance Summary 2007/2008 Introduction Section 4 of the Disability Equality Scheme (DES) sets out in detail the steps the BBC has taken to meet the Disability Equality Duty, including: A statement of how disabled people have been involved in developing the Scheme An Action Plan Arrangements for gathering information about the performance of the BBC on disability equality Arrangements for assessing the impact of the activities of the BBC on disability equality and improving these when necessary Details of how the BBC uses information gathered on the effect of BBC policies and practices on disabled people, in particular in reviewing the effectiveness of its Action Plans and preparing subsequent Schemes

This Performance Summary reflects an annual review of the DES and highlights both the BBC’s performance across its public functions following year 1 and key activities identified for year 2. All of the objectives for each of the public function areas are outlined below together with corresponding progress and priorities for next year. Public function: TV Licensing (For further detail on the range of public functions which relate to TV Licensing, see Annex.)

Objective 1: To communicate with disabled people, wherever practicable, in a way that is accessible and appropriate to facilitate a clear understanding of television licensing obligations Key achievements during 2007/2008 TV Licensing (TVL) conducted an equality impact assessment (EIA) on a representative sample of TVL communications. Although no negative impacts were identified for either project, the EIA did highlight that different groups have different needs, experiences, issues and priorities in relation to TVL’s marketing materials. These are being catered for through a raft of activity which is already in place. For example, TVL’s written marketing communications are available in large print, Braille and audio tape formats, while the call centres offer a textphone service and are capable of interacting with the BT Typetalk service. TVL introduced subtitling in TVL television trails. All trails which are played out next to programmes that have BSL translation are now similarly translated. TVL also introduced a checklist to ensure diversity and equality issues are taken into account during the process of casting actors for trails. The checklist includes questions on the rationale for casting specific roles and highlights the importance of avoiding stereotyping when casting for this purpose.

TVL involved disabled people in an audit of website usability to assess accessibility and provide a positive customer experience for all. Many recommendations were made for improving the accessibility of the website, including clarifying some of the wording and layout, for example by maintaining the accessibility options at the top of web pages (such as those referring to PayPoint outlets) and the use of pictures and easy read, currently being explored with Mencap. TVL will continue to work to implement these recommendations during 2008. TVL implemented a new system to provide more information on PayPoint accessibility via the TVL website for those individuals who choose to pay for their TV licence at a PayPoint outlet. A contact programme has been created for stakeholders including RNIB, RNID, RADAR, Mencap, Scope and ENABLE Scotland.

Area for improvement Will continue and develop our engagement with key stakeholders to help us monitor how effectively we are communicating with disabled people with a range of impairments.

Objective 2: To ensure that all BBC TVL staff and contractors fully understand their duty to promote disability equality and are active in implementing actions identified Key achievement during 2007/2008 The vast majority of staff dealing with customer queries and complaints continue to receive equality training. Further work with one supplier has been identified for action in 2008/2009. The rollout of equality training to visiting officers has taken place during 2007/2008 and is almost complete.

Area for improvement TVL will put systems into place to record and analyse information on complaints which are related to disability and ensure that all complaints monitoring is carried out according to diversity. This information will then be used to inform future action or review as necessary.

Objective 3: To continually review and, wherever possible, improve or develop service supports (including technology) to provide maximum access to support and advice services for all disabled people For detail on progress against this objective and the related actions, see section 9, Action Plan Part 1.

Objective 4: To develop and maintain a strategic and systematic approach to integrating disability equality into all TVL activities Key achievements during 2007/2008 TVL established a BBC TVL Equalities Working Group to monitor compliance with this Scheme and take forward the commitments in the TVL Action Plan. The group met eight

times in 2007/2008, discussed progress against each of the actions within the Scheme and received regular updates on equality legislation. EIAs were conducted on the new Licensable Places policy in October 2007 and the TVL rebrand project in April 2008. An EIA has been conducted on the new Refunds policy (retrospectively). Members of the BBC TVL Management Team are regularly reminded in Equalities Working Group meetings of the need for EIAs to be conducted on new policies and projects.

Area for improvement TVL will continue conducting EIAs on relevant policies and projects, including on the new TVL automated voice-recognition system which is due to be installed towards the end of 2008.

Objective 5: To maximise the potential for data and information management systems to enhance and promote disability equality For detail on progress against this objective and the related actions, see section 9, Action Plan Part 1.

Objective 6: To develop and maintain strategic leadership and commitment to the broad implementation of the DES and the TVL Action Plan Key achievement during 2007/2008 The TVL Management Team Policy Adviser has given presentations on the Equalities Working Group’s progress to a number of TVL team meetings to assist the senior management team to review the work of the Group. This will continue in year 2 (2008/2009).

Objective 7: To ensure that all payment methods and processes are accessible and appropriate for a range of needs and lifestyles For detail on progress against this objective and the related actions, see section 9, Action Plan Part 1.

Objective 8: To ensure a strategic approach to integrating disability equality into all TVL procurement activities Key achievement during 2007/2008 Re-procurement of TVL’s cash schemes and the telecoms re-procurement exercise reflected the Disability Equality Duty throughout the process.

For more detail on progress against each of the objectives relating to TVL and the corresponding actions, see section 9, Action Plan Part 1. Public function: the BBC Trust in relation to certain functions under the BBC Charter and Agreement (For further detail on the range of public functions which relate to BBC Trust, see Annex.)

Objective 1: To ensure that all of the Trust’s communications activities (internal or external), including involvement activities, are fully accessible and meet the specific needs of all groups Key achievements during 2007/2008 The Trust’s Audience Engagement Protocol ‘Our Promise to You: How the Trust will engage with audiences’ was published. This set out the ways in which the Trust intends to engage with the public in all its diversity. This was informed by (a) consumer research, (b) a public consultation, (c) feedback from Audience Councils and (d) a series of working lunches with interest groups, one of which was attended by organisations which represent disabled people. Since May 2007 the Trust has conducted and published two predictive equality impact assessments (EIAs). These are available on the BBC Trust website. Five are currently in progress and are due for publication before autumn 2008. The outcomes of both the retrospective and predictive EIAs conducted by the Trust showed no evidence of any negative impact on disabled people to the extent where it was illegal, it could not be justified or that further consultation was warranted before proceeding any further. As a result of conducting the impact assessments a number of actions have been identified. These are being monitored by the Trust’s Diversity Adviser as well as being routinely discussed during the Equalities Working Group meetings. The Trust’s 2008 annual purpose remit survey for the first time ensured that it captured the views and attitudes of a more diverse audience. As a result it has been able to interrogate the data to draw out any differences in the results of the following equality and diversity strands: gender, age, disability, ethnicity, nationality, sexual orientation, faith, social class, and rural and urban locations. A diversity monitoring form was developed and rolled out across the Trust so that, where possible, equality data of participants of consultations, public meetings and research projects could be captured, with the aim of informing future activities. A venue accessibility checklist was created to aid the Trust when choosing locations for meetings.

Area for improvement Although a diversity monitoring form was customised and rolled out across the Trust there has been some inconsistency in its use and reservations about its implementation. As a result the Equalities Working Group will work to ensure that there is a consensus across the department as to when the form is applied. There have also been recommendations as to how diversity data could be obtained for closed meetings which are targeted at certain organisations.

Objective 2: To monitor and assess the BBC’s strategic approach to disability equality in order to review and continually improve outcomes for disabled people Key achievement during 2007/2008 An Equalities Working Group was established within the Trust Unit to monitor compliance with the Scheme.

Objective 3: To ensure that all disabled people have equal and fair access to the Trust’s complaints processes Key achievement during 2007/2008 There have been changes to BBC’s complaints framework as a result of the consultation which took place between October 2007 and January 2008. For example, the language has been amended in the procedures document so that it is clear and consistent (for example, using the same wording throughout the document and ensuring timelines are referred to in a consistent manner). The changes also aim to ensure that the complaints process is accessible by offering alternative methods for contacting the BBC instead of only by written correspondence at appeal stage. The document itself has also been made more accessible by removing footnotes and inserting them into the body of the text where appropriate. Easy read versions and other formats are also available on request.

Objective 4: To monitor and assess equality of access, information and service provision with regard to the television licensing and digital switchover functions (see also the TVL and DSO Action Plans for detail) Key achievements during 2007/2008 The Trust has executed its oversight responsibilities through biannual receipt of compliance reporting from the Executive and noting the Executive’s progress summaries at its June 2008 meeting. An Equalities Duties Protocol has been developed to set out how the Trust will perform this responsibility in the future.

Objective 5: To ensure that all disabled people are consulted on and involved in policy decisions or changes which may impact on them, in relation to the BBC’s public functions Key achievement during 2007/2008 The Trust has developed and will be shortly publishing its own consultation policy. This will encourage the Trust to be proactive in reaching out to those who do not ordinarily take part in written consultations, for example, by way of using research, public meetings and the Audience Councils network. Area for improvement Because of the scale and limited resources of some Trust research projects, there has not been the opportunity to always monitor and secure statistically significant samples of disabled people. Therefore, the Trust Unit is currently developing a set of principles

which will aid the way in which the Trust commissions its research and collects classification data so that it improves its understanding of diverse audiences.

Objective 6: To ensure that specific public reports and information are fully accessible and appropriate (in style, format and content) for all disabled people Key achievement during 2007/2008 The Trust continues to offer information in alternative formats on request, including large print, Braille and audio tape.

Area for improvement The Trust has identified the need to ensure that Trust documents on its website are appropriately accessible.

For more detail on progress against each of the objectives relating to the Trust and the corresponding actions, see section 9, Action Plan Part 2. Public function: the BBC’s obligations in relation to digital switchover (DSO) (For further detail on the range of public functions which relate to digital switchover, see Annex.)

Objective 1: To assist the “most vulnerable beneficiaries” (older and disabled people) to make the switchover to digital TV Key achievements during 2007/2008 Digital Switchover Help Scheme Ltd (DSHS Ltd), a subsidiary of the BBC, developed the Digital Switchover Help Scheme’s Code of Service Standards. This outlines the level and standard of service that people eligible for the Help Scheme can expect. The Code forms part of the contract with the service provider, eaga plc, against which it will be closely monitored by the BBC, through DSHS Ltd. DSHS Ltd conducted a qualitative in-depth, face-to-face consultation process to inform the development of the Help Scheme and its Code of Service Standards. This engagement activity involved: • In-depth interviews with over 30 organisations, including disability organisations • A deliberate focus on conducting interviews with people with a range of impairments inform development of the Help Scheme • 14 focus group discussions • Customer and satisfaction surveys with users of the pilot Help Scheme implemented in Copeland DSHS Ltd conducted research (Maximising Reach) and developed a unique model (Social Support Network) to identify and meet the requirements of the most excluded people among the target audience for the Help Scheme. These are people who experience multiple and significant barriers relating to lack of networks, cognitive, sensory or physical disabilities, income, and language. This developing work and research will continue during the life of the Disability Equality Scheme.

DSHS Ltd recruited two diversity specialists to the procurement team to ensure that disability equality was integrated into the procurement process. Both were disabled staff members and one now leads for DSHS Ltd on continuing to integrate equality and diversity into the work to manage delivery of the Help Scheme. DSHS Ltd selected eaga plc in February 2008 as the preferred supplier for delivering the Help Scheme. eaga has significant experience of providing services to disabled and older people through its contract with the Warm Front domestic fuel scheme. The schedule of Help Scheme requirements used for the procurement process, which forms part of the contract terms and conditions with eaga, outlines explicitly the diversity-related requirements for successful delivery of the Help Scheme. DSHS Ltd developed help sheets to reassure and assist people eligible for assistance from the Help Scheme.

Area for improvement A more effective equality and diversity governance framework is needed in relation to the Help Scheme and to ensure consistency in approach and implementation.

Objective 2: To ensure that the transition to digital-only broadcasting is a fully inclusive process Key achievements during 2007/2008 Evidence from Digital UK’s Switchover Tracker, which measures satisfaction rates by different groups, indicates a positive impact for disabled people. The Quarter 1 2008 tracker results indicate that, in 11 out of 15 key areas tested for people’s views or awareness levels, the responses from disabled people were either in line with or higher than the national response. Digital UK commissioned Ricability to test registered digital TV products to recommend those which are the easiest to install. Digital UK has established a contract with Digital Outreach Ltd (a consortium comprising Age Concern, Help the Aged, CSV and Collective Enterprises Ltd) designed to enable DSO messages to reach potentially isolated and excluded people, including disabled people, and at ground level by working with voluntary groups to understand better how to reach communities and address issues locally.

Objective 3: To ensure that all DSO and Help Scheme related information and modes of communication are appropriate for target audiences and are fully accessible Key achievement during 2007/2008 The Help Scheme branding has undergone significant user testing in order to identify and mitigate potential barriers for people within the target group audiences, including disabled people.

Objective 4: To involve disabled people in the planning and rollout of DSO and in the planning and rollout of the Help Scheme Key achievements during 2007/2008 DSHS Ltd conducted a qualitative in-depth, face-to-face consultation process to inform the development of the Help Scheme and its Code of Service Standards. This engagement activity involved: • In-depth interviews with over 30 organisations • A deliberate focus on conducting interviews with people with a range of impairments inform development of the Help Scheme • 14 focus group discussions • Customer and satisfaction surveys with users of the pilot Help Scheme implemented in Copeland DSHS Ltd established relationships with a wide range of community and voluntary sector organisations together with eaga plc (the contractor responsible for delivery of the Help Scheme), ensuring that the BBC, through DSHS Ltd, continues to involve disabled people in the Help Scheme.

Area for improvement DSHS Ltd needs to ensure a focus on engaging with a wider diversity of disabled people, for example younger people eligible for the Help Scheme, and those most excluded disabled people eligible for the Help Scheme.

Objective 5: To gather and use information effectively in order to monitor and assess the impact of current and planned DSO policies and practices with regard to disability equality Key achievements during 2007/2008 Since May 2007, a total of seven EIAs have been conducted and published in relation to the Help Scheme, five of which were retrospective and two predictive. These have been focused on the procurement process for the Help Scheme and the development of its Code of Service Standards. These EIAs are used to inform policy and planning procedures by identifying any specific requirements or barriers for disabled people eligible for the Help Scheme. Digital UK has conducted two EIAs on its generic communications strategy and its Digital Switchover Help Scheme, outreach and housing work.

Area for improvement A more effective and robust EIA framework is needed to inform operations linked to the Help Scheme.

Objective 6: To ensure effective internal monitoring and DES outcomes evaluation For detail on progress against this objective and the related actions see section 9, Action Plan Part 3 (i).

For more detail on progress against each of the objectives relating to DSO and the corresponding actions, see section 9, Action Plan Part 3 (i). Other BBC public functions (under the BBC Agreement)

Public function: Making the UK public services widely available Key achievements during 2007/2008 In May 2008 the BBC reached its target of 100% of programmes on BBC One, BBC Two, BBC Three, BBC Four, CBeebies, CBBC and BBC News. This amounts to more than 50,000 hours of subtitled content each year. During 2007/2008, the BBC achieved the following audio-described content (against a target of 8.8%): BBC One: 13.6% BBC Two: 12.4% BBC Three: 21.4% BBC Four: 18.1% CBBC: 11.9% CBeebies: 10.6% During 2007/2008, the BBC achieved the following signed content (against a target of 4.4%): BBC One: 4.7% BBC Two: 5.1% BBC Three: 5.0% BBC Four: 5.0% CBBC: 4.9% CBeebies: 4.6% Online, BBC iPlayer aims to provide television-style access services (subtitles, audio description and British Sign Language) for many of its programmes. Subtitling for some pre-recorded programmes in downloadable format on iPlayer is now available. A facility has been introduced for deaf people to find easily much of the BBC’s BSL content – both See Hear and interpreted programmes from Sign Zone are available via the Sign Zone category of iPlayer.

Areas for improvement The BBC will put in place an improved assurance process to ensure that each new website or service is as accessible as possible. The BBC will explore facilitating the provision of transcripts of radio content via an automated mechanism. Currently, any available transcripts or information about a programme will be on the relevant website. The BBC will explore provision of audio description on iPlayer for those programmes where this is provided at the point of broadcast.

Public function: Code relating to provision for the deaf and visually impaired and power to modify targets For more detail on this public function and the related actions, see section 9, Action Plan, Part 3 (ii).

Public function: Reports and accounts about the commercial services Key achievements during 2007/2008 English, audio and Braille versions of the Annual Report and Accounts 2006/2007 were produced. For the first time the Annual Report 2007/2008 will have its own dedicated website, designed together with access specialists.

Public function: The BBC may be requested to broadcast or distribute announcements in relation to defence and emergency arrangements For more detail on this public function and the related actions see section 9, Action Plan, Part 3 (ii).

For more detail on progress against each of these public functions and the related actions see section 9, Action Plan Part 3 (ii).

7 Feedback and update

The BBC promotes its broad commitment to respecting, valuing and celebrating diversity via the BBC Diversity website, bbc.co.uk/info/policies/diversity.shtml, where the Disability Equality Scheme is published. It is also published on the BBC Trust website, bbc.co.uk/bbctrust/framework/diversity/index.html.

Updates will be added at regular intervals.

In addition the Trust will report annually on the performance of the BBC Executive Board with regard to disability equality – see also Action Plan 2 (objective 2, action 2).

Alternative formats will be available on request from the Diversity Centre and will be provided within a set maximum time limit.

For a copy of the Disability Equality Scheme in another format, or for further information, contact:

BBC Diversity Centre Room 2564, White City Media Village 201 Wood Lane London W12 7TS Email: [email protected]

8 The BBC’s broader approach to promoting disability equality

NB: This section does not form part of the Disability Equality Scheme, which the BBC is required to publish under the Disability Discrimination Act (Public Authorities) (Statutory Duties) Regulations 2005, but should be read in conjunction with the Scheme as it provides additional information about the BBC’s diversity commitments.

The Disability Equality Scheme is limited to how the BBC applies the Disability Equality Duty to its public functions. However, while not within its legal obligations, the BBC also considers what other actions can be taken across the wider BBC in the interests of diversity.

The BBC aims to promote disability equality generally through seeking to understand and meet the specific and diverse requirements of disabled people and by ensuring that they are fully involved in working together towards achieving fair and equal outcomes for themselves and their carers. This approach is based on the BBC’s commitment to a broader diversity agenda and is underpinned by its core values: Audiences, Respect and Working Together. It is also driven, in part, by the specific duties relating to equal opportunities which are placed on the BBC by the BBC Charter and Agreement (ref. Charter Article 44 (1) (a) and (b) and (2) (b), and Agreement Clause 83).

The following section sets out a number of additional steps which the BBC takes or has taken to promote the interests of disabled people. These are not required to be taken for the implementation of the Disability Equality Scheme, which relates only to the BBC’s public functions, but are undertaken under other legal obligations, or completely voluntarily in accordance with good practice, to meet the needs of disabled people generally including, of course, disabled licence fee payers.

In October 2006, the BBC Executive Board hosted a consultation event with other BBC Directors to understand the views and perceptions of the wider disabled community about the BBC’s services. A number of national and local organisations working within the disability arena participated in the seminar, including the British Council of Disabled People, People First, TAG, MIND and Mencap. A BBC Governor attended the event. Information gathered at the event resulted in the following.

Actions arising included: A review of the guidelines for visually impaired audiences A commitment to work with disabled people inside and outside the BBC to raise awareness of the issues A review of the processes in place to support disabled people working across the broadcasting industry

Update As at April 2008 examples of work throughout 2007/2008 include: The publication of newly developed production guidelines for deaf and hearing impaired audiences. A review of how effectively these guidelines are being implemented is planned for 2008/2009. A joint BBC and Channel 4 research project to better understand the consumption of UK public services and new technology by disabled people. The research will also explore the perceptions of BBC and Channel 4 content and portrayal.

The BBC is a member of the Broadcasting and Creative Industries Disability Network. As such, the BBC aims: 1 To increase the presence of disabled people on air and on screen 2 To increase the number of disabled people in all areas of the workforce 3 To increase access to services, on and off air 4 To ensure access to its buildings 8.1 The BBC aims to increase the presence of disabled people on air and on screen What has been done already Television The BBC introduced on-screen disability portrayal targets, most of which have been met.

At least one regular disabled character in a returning drama series on BBC One (Paul Henshall in Holby City). Three factual and leisure shows on BBC One and BBC Two to feature at least one disabled contributor per series (Beyond Boundaries, BBC Two – 11 disabled contributors; Ade Adepitan, previously from Xchange, BBC One and CBBC, now contributes to Sportsround, BBC One, and Grandstand, BBC One, and covered the new wheelchair tennis doubles event at Wimbledon). Three key entertainment series on BBC One and BBC Two to feature a minimum of one disabled contestant in 50 (Weakest Link and Jet Set on BBC One, Mastermind on BBC Two). BBC Three to broadcast one drama or entertainment series with a regular disabled character – this has been more than met by I’m with Stupid which began on BBC Three on 10 September 2006 and features a number of disabled characters in addition to the lead role played by Paul Henshall. BBC Four to broadcast a minimum of two profiles of people of achievement per year, with an ambition to develop new on-screen talent in its factual output (for example, profiles of Ray Charles and Muhammad Ali).

In addition to the above, there are many other examples of the BBC’s increasing commitment to the inclusion and portrayal of disabled people in television output: Ready Steady Cook on BBC One Something Special on CBeebies Soundproof, A Thing Called Love, Top Gear and Junior Mastermind on BBC Two House of Tiny Tearaways on BBC Three BBC News correspondent Frank Gardner, who was left disabled as a result of being shot, has been featured in various reports. Desperados, a children’s drama about a disabled basketball team on CBBC Series two of Beyond Boundaries on BBC Two and series three currently in production New Street Law on BBC One Extensive coverage of the Paralympics in 2004 The Street on BBC One Stephen Fry – HIV and Me on BBC Two Children Fighting Cancer on BBC One The Politics Show had a feature on the problems faced by disabled ramblers. The One Show on BBC One featured paralympian and gold medallist Tanni Grey- Thompson who talked about what home means to her. BBC Sport continues to report on disability sport events including the Paralympics World Cup from Manchester and wheelchair tennis action from the 2008 Wimbledon Championships. There will also be extensive action broadcast from the Beijing Paralympics later in the year. Coming Down the Mountain, a feature-length drama on BBC One, looked at the unusual relationship between two teenage brothers, one played by Tommy Jessop, an actor with Down’s syndrome.

Radio In Touch and You and Yours on Radio 4, presented by Peter White, regularly feature items of interest and relevance to disabled people, likewise Woman’s Hour and Sound Advice, presented by Gyles Brandreth. The Archers on Radio 4 has blind actor Ryan Kelly playing the regular character Jazzer. Sound Barriers, a Radio 4 drama, featured deaf actor Steve Day. The Lights, a Radio 4 drama, featured wheelchair-user actor Luke Hamill playing a wheelchair-user character. My MS and Me, another Radio 4 drama, written by Jim Sweeney who has MS Peeling, on Radio 3, written by visually impaired writer Kaite O’Reilly Watch the Spider, on Radio 3, written and performed by Andy McLay, a paraplegic, about his experiences Rean’s Girls, a Radio 4 Afternoon Play, written by Kaite O’Reilly who is visually impaired Daybreak, a Radio 4 Afternoon Play, written by disabled writer Tom Ray and a commission for an Afternoon Play written by Sue Townsend who is now blind Walkie Talkies for Mandy Colleran (wheelchair-using actress performed at the Free Thinking Festival on Radio 3

Other developments In 2008, BBC commissioned a new show that would attempt to launch a disabled woman as a mainstream fashion model (Britain’s Missing Top Model). The BBC commissioned the first ever comprehensive, in-depth research into Learning Disabled Audiences (LDA) in 2006. This covered what they watched, how well they thought their needs were catered for and what specific programmes they would like to see on television in the future. Findings will inform the 2008 BBC and Channel 4 joint research into the consumption of UK public services and new technology by disabled people. A key finding of the LDA research was the importance of television soaps to learning disabled people, providing them with a window to the world, helping them to understand everything from relationships to what goes on in a pub. This led to the overwhelming desire to see themselves represented in these programmes above all others, particularly significant in the light of the current EastEnders storyline about Billy and Honey’s baby having Down’s syndrome. The BBC, in conjunction with Channel 4 and the Actors Centre, ran the Talent Fund for Disabled Actors, a training and development scheme for 25 disabled actors, selected through nationwide open auditions. The aim was to increase the pool of disabled acting talent available to casting directors. BBC Children’s has worked closely with the National Deaf Children’s Society to produce a guide for programme-makers on how to ensure that their programmes are inclusive of and accessible to deaf children. BBC Children’s has worked closely with the Makaton charity to continue its successful series Something Special, aimed at children with learning difficulties. The BBC post of Editorial Executive – Diversity was created during 2006. The postholder liaises with the corporate Diversity Centre and works closely with service controllers, commissioners and in-house and independent production companies to improve on- screen portrayal and diversity. This includes providing advice to programme-makers during the course of the development and production of programmes. New Disability Portrayal targets are currently being set. The Production Handbook – a guide for programme-makers on the Disability Discrimination Act – was relaunched in 2007. The BBC periodically audits a range of its productions to assess provision for studio audiences and contributors under the DDA (part iii). Follow-up meetings with production teams are held to ensure that the recommendations arising from the audit are carried out so that programmes are compliant with the DDA obligations which apply to the provision of services. A Portrayal Monitoring survey of BBC TV peak-time output was commissioned in 2006. The findings were presented to the Vision Editorial Group, to inform policy on inclusion and portrayal going forward.

The Big Screens are a partnership between local authorities, London Olympics and the BBC. The BBC will, where it can, extend subtitling to Big Screen broadcasts for major BBC broadcast events such as a Royal Wedding or a major sporting event or news items (i.e. those that clearly fulfil BBC public purposes). These will be screened in full-screen mode. The Big Screens do not have the technical capability to provide subtitling for a large amount of community-generated film content; however, when the screen is in ambient mode it combines video, text and sound in an attempt to give a fuller experience to as wide a number of people as possible. Requirements under DDA legislation for events around the Big Screen are the responsibility of the local authorities and their partners. Where there is a BBC event then the BBC will take responsibility for ensuring that all reasonable steps are taken to comply with legislation.

What we are doing going forward Working to increase the number of disabled people working in production for the BBC, either in house or through independent commissions. Actively encouraging the inclusion of disabled people in mainstream programming as well as targeted programming that works in the mainstream, such as Grange Hill that now has a deaf character and one of the new faces on EastEnders, hard-of-hearing 10-year-old Ben. Continuing to search for a learning disabled presenter for Children’s on-air presentation. In radio, continuing to investigate ways to ensure that programmes featuring items of interest to the disabled audience are flagged up to that audience. Considering the introduction of a regular disability newsletter in BBC Radio Factual.

Update BBC Children’s has decided to search for a disabled presenter for Children’s on-air presentation instead of a learning disabled one. BBC Radio Factual introduced a regular disability newsletter authored by Peter White, including audio, which wraps up all BBC radio output. 8.2 The BBC aims to increase the number of disabled people in all areas of the workforce, including production The BBC continues to: Review recruitment practices so that job opportunities are accessible to disabled people (for example advertising, selection and assessment procedures). Make reasonable adjustments for employees who are or become disabled during employment. Provide a reasonable level of support to its disabled staff by monitoring provision of the contract with Capita (now responsible for recruitment and reasonable adjustments).

In addition the BBC is committed to the following: Continuing to monitor the numbers of disabled employees. The BBC’s 4% disability target was exceeded in 2007 (4.5% as at 31 May 2008) and disability employment targets are being reviewed. A disability target for senior managers will be introduced in 2008. Consulting with and involving disabled staff in creating an inclusive and disability-aware workforce. Monitoring progress regularly at the Diversity Board: Mark Thompson chairs this board, and members are all the divisional directors. Ensuring that at least 20% of places on the BBC’s Mentoring and Development Programme are ring-fenced for disabled staff over the next three years, in order to support the development of diverse future leaders for the BBC. Setting up a separate professional development scheme for disabled employees at lower grades. Continuing to run Extend (the BBC’s work placement scheme for disabled people) and maintain its recent, successful focus on placements in production areas. Fifty people were taken on for 2007–2010. The pan-BBC Access Services unit, which has now been in operation for six years. This provides a variety of services to disabled staff ranging from access assessments for new starters or newly disabled existing members of staff, arranging reasonable adjustments, and offering trained facilitators who can undertake some production roles, through to general support and advice. In addition the Access Unit is now also advising production teams working with disabled contributors on technical and production-related issues, for example Britain’s Missing Top Models. Continuing to implement a dedicated Assistive Technology Strategy. 8.3 The BBC aims to increase access to services, on and off air Service provision commitments and current achievements The BBC is committed to subtitling 100% of programming on BBC One, BBC Two, BBC News, BBC Three, BBC Four, CBBC and CBeebies by the end of 2008. The target for 2006/2007 was for at least 95% of programmes on BBC One and BBC Two and 80% on the remaining channels to be subtitled. The BBC is committed to signing 5% of non-excluded programming on all of the above channels by 2008/2009. The target for 2006/2007 was for at least 4% of each channel output to be signed. The BBC is committed to audio-describing 10% of non-excluded programming on BBC One, BBC Two, BBC Three, BBC Four, CBBC and CBeebies by 2008/2009. The target for 2006/2007 was for at least 8% of these channels to be audio-described.

Update As at April 2008, the BBC had met or exceeded all of the 2006/2007 targets above. The BBC is on target for 2007/2008 targets. In May 2008 the BBC reached its self-imposed target of 100% subtitling on programmes on its main channels. The BBC is committed to the following targets for non-excluded programmes on BBC One, BBC Two, BBC Three, BBC Four, BBC News, CBBC and CBeebies in 2008/2009: Subtitling: 100% Signing: 5% Audio description: 10% The BBC Information Directory is available free. In addition to the standard version there is also a simple English version and a large print version. Website accessibility The BBC continues in its commitment to making its content accessible to as wide an audience as possible. This was reflected in the establishment of an accessibility team in 2008, focusing on the delivery of all new and future service being accessible.

The BBC launched My Web, My Way (bbc.co.uk/accessibility) in 2005. The website aims to equip anyone using a computer with the tools and understanding to enable them to make the most of the internet, whatever their ability or disability, and regardless of the operating system (Windows, Mac or Linux) they use. The site provides advice and help to all those people who would benefit from making changes to their browser, operating system or computer by giving advice on a wide range of specialist hardware such as alternative keyboards and mouse units, plus software such as voice recognition, screen reading and word prediction. CBeebies has worked closely with young children with motor disorders such as cerebral palsy to design a dozen fun and inclusive games for children 6 years old and under. The CBeebies team has proved that designing and adapting games to be controlled by switches rather than pointing devices is ‘child’s play’. BBC jam, the BBC’s broadband learning service for 5 to 16 year olds, was launched in 2006. The BBC Trust suspended the online education service on 20 March 2007 following complaints from the commercial sector about the parameters of its activities. The Trust has requested BBC management to prepare fresh proposals for how the BBC should deliver the Charter obligations to promote formal education and learning, meeting the online needs of school-age children. Once complete, the Trust will subject BBC management’s proposals to a full Public Value Test, including a market impact assessment by Ofcom. The BBC Trust in conjunction with BBC People (Training and Development) is launching a new training course for staff to ensure that all documents for the web are developed in accessible PDF.

BBC iPlayer accessibility BBC iPlayer was approved by the Trust in April 2007. In December 2007 the BBC committed to making its broadcast and online products and services as accessible as possible. BBC iPlayer (an online television catch-up service that is compatible with screen readers) is no exception. It successfully brings together best practice in accessible website design and television access services.

The interface was built with the consultation of the BBC New Media Access Team and various accessibility consultants. Ongoing consultation fed into every stage of the BBC iPlayer design and enabled the development team to build a platform from which accessible interfaces with additional accessibility features such as the display settings options could be built.

BBC iPlayer also features television-style access services (subtitles, audio description and British Sign Language). Each solution has been designed to maintain the high standards of the BBC’s linear television services and will match the BBC’s TV access services commitments by 2008. With accessibility as one of its key objectives, the development of BBC iPlayer has set the standards for accessibility for all future BBC digital services.

BBC iPlayer update 2008 BBC iPlayer aims to provide television-style access services (subtitles, audio description and British Sign Language) for many of its programmes. • The first prototypes of subtitling on bbc.co.uk were developed in 2005/2006 for the Click Online and iMP (Interactive Media Player) trials. Since then, the BBC has worked to get the technologies used in these trials into the complex production processes used to deliver programmes through iPlayer. The result of this work is that, in March 2008, the BBC introduced subtitling for some of its pre-recorded programmes on iPlayer in download format. The BBC is also working on providing subtitles for iPlayer’s streamed programmes, and is looking at the possibility of providing them for other platforms such as iPhone and Wii. • In March 2008, the BBC introduced a facility for deaf people to easily find much of the BBC’s BSL content – both See Hear and interpreted programmes from Sign Zone – via the Sign Zone category of iPlayer. iPlayer has enabled the BBC to provide what our BSL users have regularly asked for – access to a directory of recent BBC BSL TV content which is available for them to watch at any time they choose. • In addition, the BBC is also looking into the possibility of iPlayer providing audio description for programmes that already have it on linear TV. 8.4 To ensure access to its buildings BBC Workplace – project background In 2001 the BBC initiated a long-term process aimed at establishing improved access for disabled staff, visitors and artists across the entire BBC estate. The BBC initially carried out a programme of site audits and produced a substantial list of potential improvements for consideration and action.

Items identified ranged from minor works to more significant building improvements. BBC Workplace subsequently initiated a project to roll out a programme of works which has so far led to a financial commitment in excess of £3million of improvements and upgrades across the estate. Detailed improvements The works so far carried out typically cover: External building approach and car parking provision New and improved ramping Reception works Toilet works (both new and upgrades) New doors, some door automation and improved vision panelling Better signage Provision of deaf alerters and hearing induction loops Lift car improvement works A new lift for BBC Belfast Lighting and colour contrast improvements for visually impaired people Renewal of and improvements to handrails Access improvements to studios and audience areas Better dressing-room provision Projects to assist some disabled staff in their workspace New buildings and refurbishments In addition to the above, the BBC has also included access improvements in all of its major site developments, most notably at White City and Broadcasting House in London and at Pacific Quay in Glasgow. When the BBC develops new sites or carries out refurbishments to existing buildings, access requirements or the potential for improvement is considered at an early stage in the planning process. A full DDA audit is conducted prior to any proposed site moves. The audit report then informs any decisions which the BBC makes regarding suitable access arrangements. Ongoing commitment All of the above outlines the BBC’s commitment to making necessary and appropriate improvements. However, the process is not yet complete and there are still a number of access challenges to be overcome, particularly in some of the BBC’s larger and older buildings. Nevertheless, the BBC’s strategic vision is clear and remains fully committed to the process of improving accessibility across the BBC estate wherever this is possible. Update In early 2008 the Director-General Mark Thompson pledged that the BBC would put into place robust processes and structures to ensure that full and consistent consideration is given to access needs at the initial planning stage of all major BBC projects. Diversity (including accessibility of premises and technological accessibility) is now part of the approvals process for all large projects going to the BBC’s Finance Committee.

9 Action Plan

Action Plan 1: TV licensing function What is TV Licensing? “TV Licensing” (TVL) is a trading name used by companies contracted by the BBC to administer the collection of TV licence fees and enforcement of the licensing system. The majority of the administration of TVL is contracted to Capita Business Services Ltd, with the administration of cash-related payment schemes contracted to Revenue Management Services Ltd (RMS). PayPoint Collections Limited is contracted to provide over-the-counter services. The marketing and public relations activities are contracted to the AMV Consortium. The Consortium is made up of the following four companies: Abbott Mead Vickers BBDO Ltd, Fishburn Hedges Boys Williams Limited, PHD Media Limited and Proximity London Ltd. The BBC is a public authority in respect of its TV licensing functions and retains overall responsibility. What help is already available to consumers who need it? TVL currently offers a number of ways to enable people with disabilities to access its services and information. These include the following: Textphone service Braille letters and publications Large print letters and publications Audio tapes of TVL information Special email forms (some forms can be sent in electronic format enabling manipulation to make them accessible) Typetalk for deaf or speech-impaired people Account security numbers to enable carers and support workers to discuss customers’ accounts Liaising with housebound customers to find an appropriate way for them to make payments, even if Direct Debit or other payment methods are not available to them

TVL also has a small number of customers with specific needs which are taken into account when conducting transactions or communicating with them.

Concessionary TV licences are available for people who are registered blind (who receive a 50% discount). For those who live in applicable accommodation such as residential care, where one qualifying factor is that the individual is disabled, a £7.50 licence has been available from 1 April 2007.

To offer peace of mind to all customers, but particularly those who are or may feel vulnerable, a password system is available to enable people to confirm the authenticity of TVL visiting officers.

The BBC has ensured that there are provisions in the BBC’s contracts with suppliers to ensure that they must comply with legal requirements and related policies, including the Disability Discrimination Act and this Disability Equality Scheme. This is monitored by the BBC TV Licensing Management Team (TVLMT). How are the public consulted and informed about TVL? The BBC and TVL engage in regular consultation with a number of key stakeholders to both gather and share information in relation to meeting the needs of disabled people. There is regular dialogue with the Royal National Institute for the Blind (RNIB), Royal National Institute for Deaf People (RNID), Mencap, Age Concern, Help the Aged and Citizens Advice.

These relationships also relate to consulting on and seeking input on proposed changes in TVL processes (see section 4.3.1 for information on involvement and the mechanisms used to gather information related to disability and TVL).

TVL’s community relations campaign, which gained international recognition as winner of the 2004 International Public Relations Association Golden World award for community relations, is designed to target hard-to-reach community groups, such as those on low incomes and vulnerable people. By working with national and local stakeholders, the campaign targets groups including disabled people and their carers, who may struggle to pay for their TV licence for financial reasons or who are unaware of the legal requirement to buy a TV licence. The objective of the campaign is to raise awareness of the need to have a TV licence and the many easy ways to pay. Action Plan aims That disabled people and their carers experience and receive appropriate and accessible TVL information, advice and targeted support services

This Action Plan section shows how current TVL activities which are relevant to the Disability Equality Duty will be maintained and progress monitored. It also details a series of planned actions which have been identified as necessary following an audit of current activity and through consultation and involvement with disabled people. A formal programme of equality impact assessments and continual involvement with disabled people will inform ongoing review (see above and also sections 4.3 and 4.4).

NB: Objectives are not in priority order. Objective 1 To communicate with disabled people, wherever practicable, in a way that is accessible and appropriate to facilitate a clear understanding of television licensing obligations

1 An equality impact assessment (EIA) will be conducted on a representative sample of TVL communications (mailings, information leaflets and publications), to examine how accessible and appropriate they are in style, content, format and dissemination, and the EIA outcome will inform any further action necessary. Due date: By end 2007

Progress: Completed in August 2007 and identified a number of groups had different needs that current marketing communications were meeting appropriately. The TVL marketing team agreed a process of continuous assessment. The EIA will be formally reviewed every three years. Lead: Marketing Evidence/outcomes: TVL communications assessed and recommendations made to improve and amend where necessary.

2 TVL will continue to make our communications available in Braille, large print, audio and electronic formats. Due date: Ongoing Progress: Actioned. Communications in these formats continue to be made available. Lead: Marketing, Customer Relations Evidence/outcomes: Standard communications will be accessible to a range of disabled people.

3 TVL will explore options for use of SMS or videophone in addition to existing textphone service. Due date: By end 2007 Progress: Completed. Implementation has been delayed because of a procurement exercise to re-tender the contract for a telecoms provider for the TVL call centres. Although TVL has not received any complaints in this area, either directly or via the RNID, this action has nevertheless been taken forward, with bidders for the telecoms contract being asked to provide indicative costs for an SMS or videophone solution. A feasibility statement has been produced from the responses. A final decision is due to be taken in quarter 1 of year 2. Lead: Operations Evidence/outcomes: Options for introducing additional alternative modes of communications assessed.

4 TVL will review all television trails and publications to examine how best to represent disabled people. Due date: By end 2007 Progress: Completed. New trails are airing from April 2008. Although these trails do not portray characters, a checklist has been developed to ensure that diversity and equality issues are taken into account during the process of casting actors in the future. The checklist includes questions on the rationale for casting specific roles and highlights the importance of avoiding stereotyping when casting for this purpose. Lead: Marketing Evidence/outcomes: A systematic review conducted and appropriate recommendations made.

5 TVL will explore options for introducing use of subtitling, BSL translation and audio description as appropriate in television trails. Due date: By end 2007 Progress: Completed. All trails since October 2007 have been subtitled. Trails which are played out next to programmes that have a BSL translation (in the Sign Zone) are similarly translated. Lead: Marketing Evidence/outcomes: Options for introducing additional assisted methods of communication assessed.

6 TVL will involve disabled people in an audit of website usability to assess accessibility and provide a positive customer experience for all. The use of pictures and easy read will be explored. Due date: By end 2007 Progress: Completed. Usability assessments of the current website were conducted in January 2008 by an international customer experience research and design company. These involved disabled people. Recommendations were made for improving the accessibility of the website, including clarifying some of the wording and layout, for example by maintaining the accessibility options at the top of web pages (such as those referring to PayPoint outlets). Some of these were scheduled for implementation by the end of year 1 and the remainder as soon as possible thereafter. The use of pictures and easy read for the website is currently being explored with Mencap. The expected date of completion for this is to be confirmed (the desired date is no later than the end of the financial year 2008/2009). Lead: Web Programme Manager Evidence/outcomes: A range of disabled people and carers involved in assessing usability of website.

7 TVLwill work with organisations such as Mencap so that information can be cascaded to members on TVL. Due date: Ongoing Progress: Completed. Met with Mencap at the end of year 1. Various actions have arisen from this contact, including writing some copy for the TVL website and TVL Ways to Pay leaflet in easy read. Further information is also scheduled to be provided to Mencap for distribution through its communication networks. A further meeting is planned. Lead: Communications Evidence/outcomes: Disabled people within the wider community will have access to information via representative groups.

8 Relationships will be continued and developed with a range of bodies which represent or consist of disabled people such as RADAR, the RNIB, the RNID and Mencap to develop a dialogue on licensing requirements.

Due date: Ongoing Progress: Actioned. A contact programme has been created for new stakeholders identified. The programme includes the RNIB, RNID, RADAR, Mencap, Scope and ENABLE Scotland. Lead: Communications Evidence/outcomes: Partnership working and involvement with disabled people enhanced and new mutually beneficial relationships will be developed where possible.

Drivers/informed by: DDA 2005 BBC Values: Audiences; Respect BBC public functions: Promotion of licensing requirements to the general public Promotion of licensing requirements to stakeholders Feedback following involvement with disabled stakeholders (ref. Churchill, Minty & Friend report) (CM&F) Objective 2 To ensure that all BBC TVL staff and contractors fully understand their duty to promote disability equality and are active in implementing actions identified

1 Existing and new staff who deal with customers’ queries and complaints will receive disability equality training and will be expected to put learning into practice when dealing with customers. Due date: By end 2008 Progress: Actioned. The vast majority of staff dealing with customer queries and complaints receive equality training as part of standard working practice. Further work on one supplier, and for staff within the BBC itself, has been identified for action in 2008/2009. Lead: Policy, Customer Relations Evidence/outcomes: Those staff who have direct contact with disabled people are better equipped to understand additional needs and relevant staff will understand the use of specialist equipment.

2 Visiting officers will receive disability equality training and their code of conduct will cover the BBC’s expectations of their treatment of disabled people. Due date: By end 2008 Progress: Actioned. The rollout of equality and diversity training to this group is almost complete. Lead: Field Operations Evidence/outcomes: Visiting officers are aware of the duty and will be better able to support and understand the diverse and complex needs of disabled people and carers.

3 The password system and visual identification will continue to be used so that people due to receive a visit are able to verify the authenticity of TV Licensing visiting officers. Due date: Ongoing Progress: Completed. These systems continue to be used. TVL have amended their call centre instructions surrounding the use of the password system in order to clarify when this service should be offered and have added examples to help their call handlers apply it appropriately. All TVL visiting officers have carried photo identification since the end of year 1. Lead: Field Operations Evidence/outcomes: Disabled, older and vulnerable people feel safe and secure during home visits.

4 Systems will be put into place to record and analyse information on complaints and comments which are related to disability needs and issues and ensure that all complaint monitoring is monitored for diversity (including disability). Due date: By end 2008 Progress: Work begins in June 2008. Lead: Customer Relations Evidence/outcomes: Information and data collection relating to disability issues and needs are used by staff to improve services and better understand needs.

5 Systems will be put into place to formally record requests from disabled people and their carers. Due date: By end 2009 Progress: Work begins in June 2008. Lead: Operations Evidence/outcomes: Formal systems in place and data used to avoid unnecessary duplications, etc.

6 Information from TVL’s customer satisfaction survey will be analysed to determine whether disabled people’s perception of TV Licensing’s service is lower than that of non- disabled people. Due date: By mid 2008 Progress: Actioned. A question on disability will be added to the survey for 2008/2009. Analysis of the survey responses is currently being arranged to be conducted on a monthly basis. Lead: Customer Relations Evidence: Information analysed and used where possible to improve services.

Drivers/informed by: DDA 2005 BBC Values: Audiences; Respect; Working Together BBC public functions: Customer relations Feedback following involvement with disabled stakeholders (ref. CM&F report) Objective 3 To continually review and wherever possible improve or develop service supports (including technology) to provide maximum access to support and advice services for all disabled people 1 This Action Plan will be reviewed as necessary in the light of outcomes from the analysis in action above. Due date: By end 2007 Progress: Completed Lead: Policy Evidence/outcomes: Regular reviews of Action Plan carried out. 2 An equality impact assessment (EIA) will be conducted on the automated voice- recognition system to assess how well it meets the diverse needs of disabled people. Due date: By end 2007 Progress: Implementation of this action has been delayed for the reason specified in objective 1 action 3 above and was hence not completed before the end of year 1. A new telecoms supplier has now been confirmed and is due to take up the contract on 20 September 2008. The BBC is intending to contribute towards the requirements for the new contract. A revised timescale for this action is currently being calculated, with a view to it being conducted during the new supplier’s designing of the automated voice- recognition system. Lead: Operations Evidence/outcomes: Assessment made and outcomes considered. 3 TVL will examine possible options for disabled people to be able to speak to a customer services officer during non-business hours. Due date: By end 2007 Progress: Completed. Indicator costs of a 24-hour staff team were received by TVL. Other options have also been considered, such as a member of staff homeworking out of business hours (this has been agreed as not viable for data protection reasons). While appreciating the potential difficulties for disabled people to contact TV Licensing out of hours, a decision was taken by the TVL Senior Management Team in May 2008 not to adopt any of the options for a non-business hours service. This was because the costs involved did not appear reasonable in the circumstances. Lead: Operations Evidence/outcomes: Options noted and assessed.

4 Outcome of the EIA will be used to inform further action. Due date: Ongoing Progress: Not yet completed because this action is dependent on the outcome of objective 3 action 2 above. Lead: Policy Evidence/outcomes: Regular reviews of Action Plan informed by EIA outcomes.

5 TVL will explore options for introducing a dedicated telephone payment line for disabled people. Due date: By mid 2008 Progress: Completed. Other organisations currently offering this service have been investigated, including Southern Electric which offers a Care Line specifically for disabled people, and the CCA which offers some information on this issue. While appreciating the potential difficulties for disabled people not having a dedicated telephone payment line, a decision was taken by the TVL Management Team Senior Management Team in May 2008 not to adopt this option. This was because the costs involved did not appear reasonable in the circumstances. Lead: Operations Evidence/outcomes: TVL automated voice-recognition systems will meet the differing needs of disabled people wherever practicable. Drivers/informed by: DDA 2005 BBC Values: Audiences; Respect; Working Together BBC public function: Operations Feedback following involvement with disabled stakeholders (ref. CM&F report) Objective 4 To develop and maintain a strategic and systematic approach to integrating disability equality into all TVL activities

1 All policies which are being developed or reviewed (BBC policies and the relevant contractors’ policies) will be assessed for relevance to the Disability Equality Duty. EIAs will be carried out where it is considered relevant and proportionate to meeting the duty. Due date: Ongoing Progress: Actioned. An EIA was carried out on the new Licensable Places policy in October 2007 and the TVL rebrand project in April 2008. An EIA has been conducted retrospectively on the new Refunds policy. Members of the BBC TVLMT are regularly reminded in BBC TVL Equalities Working Group meetings of the need for EIAs to be conducted on new policies and projects. Lead: Policy

Evidence/outcomes: A systematic process will be in place, to ensure that future policies and related practices will be screened at the development stage to determine potential negative (or positive) impacts on disabled people.

2 Existing BBC (and contractors’) policies and functions which are relevant to the duty will be prioritised for a programme of equality impact assessments over three years. Due date: By end 2009 Progress: Work begins in January 2009. Lead: Policy Evidence/outcomes: A systematic process will be in place for ensuring that existing policies and related practices are screened to determine whether they impact negatively (or positively) on disabled people.

3 All senior managers will be briefed on the Disability Equality Duty to ensure that they pay due regard to the needs of disabled people when developing policy and practice and reviewing TVL’s overall performance. Due date: By end 2007 Progress: Completed. Most senior managers were briefed at the first BBC TV Licensing Equalities Working Group meeting in May 2007 (for more on this group see action 4 below). Remaining senior managers were briefed at the management meeting in January 2008. Lead: Policy Evidence/outcomes: A consistent level of knowledge and awareness among senior managers who are responsible for policy decisions which may impact on disabled people.

4 A BBC TVL Equalities Working Group will be set up to monitor compliance and review future Schemes and Action Plans. Due date: By end 2007 Progress: Completed. The Group was established in May 2007 and has met eight times during year 1. Lead: Policy Evidence/outcomes: Greater clarity around who is responsible for implementing actions and a mechanism aimed at ensuring consistent monitoring and systematic reviews. Drivers/informed by: DDA 2005 BBC Values: Audiences; Respect; Working Together BBC public functions: Operations; Policy Development

Objective 5 To maximise the potential for data and information management systems to enhance and promote disability equality

1 Any review and subsequent changes to information management (database) systems will be compliant with the Disability Equality Duty (as well as the Data Protection Act). Due date: Ongoing Progress: Actioned Lead: Data Management Evidence/outcomes: Data and systems will not impact adversely on disabled people and opportunities to use information to deliver improvements will be maximised. 2 TVL will seek to use relevant information sources to inform further reviews of this action plan (subject to necessary compliance with the Data Protection Act). Due date: Ongoing Progress: Actioned. The updating of this Action Plan has incorporated information gathered throughout year 1 in connection with all of TVL’s actions. Lead: Policy Evidence/outcomes: Updates to the Action Plan are informed by relevant information and data sets. Drivers/informed by: DDA 2005 BBC Values: Audiences; Respect; Working Together BBC public functions: Operations; Policy Development Objective 6 To develop and maintain strategic leadership and commitment to the broad implementation of the Disability Equality Scheme and the TVL Action Plan

1 A three-year timetable of EIAs will be developed to assess the impact of current payment methods and processes on disabled people. Due date: By end 2009 Progress: Work begins in January 2009. Lead: Policy Evidence/outcomes: Potential adverse impacts will be identified at an early stage and actions taken where practicable to mitigate. 2 An EIA will be conducted on new (or reviewed) payment policies as part of the development process and EIA outcomes will inform further action. Due date: As necessary Progress: There are currently no new payment methods.

Lead: Policy Evidence/outcomes: A systematic process will be in place to ensure that future policies and related practices will be screened at development stage to determine potential negative (or positive) impacts on disabled people. Drivers/informed by: DDA 2005 BBC Values: Audiences; Respect BBC public function: Operations – Database management Objective 7 To ensure that all payment methods and processes are accessible and appropriate for a range of needs

1 TVL will evaluate the usability of the online purchase facility on TVL website Due date: Ongoing Progress: Completed. The online purchase facility was included in the usability study referred to in objective 1 action 6 above. Recommendations were made for improving the usability, including clarifying some of the wording and layout, for example by including more prominent reference to the amount being charged on a credit card. Some of these were scheduled for implementation by the end of year 1 and the remainder are due to be implemented as soon as possible. This action is scheduled to be repeated once the TVL website has been refreshed. Lead: Web Programme Manager Evidence/outcomes: Access to a wide range of payments options is available.

2 The Cash Easy Entry payment will be extended to all. Due date: From 1 April 2007 Progress: Completed Lead: Operations Evidence/outcomes: Those who experience more barriers in receiving or accessing information, such as those with visual impairments and those using BSL, are likely to benefit.

3 TVL will liaise with representative groups and organisations to examine how to provide more information on PayPoint accessibility. Due date: By end 2007 Progress: Completed. Quotes were received from a number of organisations for various activities to provide more information on PayPoint accessibility, including conducting an audit of accessibility at each PayPoint outlet in the UK. The costs of these activities were considered to be prohibitive and not an effective use of the licence fee. However, in order to further this action the BBC has instead placed a phone number on the TVL website for customers to call if they would like to receive information on their

nearest PayPoint with disabled access. The BBC is due to inform representative groups of this solution. Lead: Operations Evidence/outcomes: Disabled people involved in exploring options with the BBC.

4 TVL will work with disabled people to explore possible alternative ways of contacting customer services (see objective 1 action 1). Due date: By end 2007 Progress: Completed. Advice has been sought from the RNID as people with hearing difficulties may have problems contacting call centres. The RNID has advised that it is aware of no problems and has provided TVL with advice for the TVL call centres. A follow-up meeting is currently being arranged. Advice has also been sought from Help the Aged and Mencap (who also reported no specific issues). TVL already offers a textphone and BT Typetalk service. TVL is investigating how great the need is for exploring further alternative ways of contacting customer services. Lead: Operations Evidence/outcomes: TVL working with and involving disabled people where appropriate. Drivers/informed by: DDA 2005 BBC Values: Audiences; Respect BBC public function: Operations – Payment Processing Feedback following involvement with disabled stakeholders (ref. CM&F report) Objective 8 To ensure a strategic approach to integrating disability equality into all TVL procurement activities

1 TVL will continue to impose a contractual obligation on contractors to comply with legal obligations including the Disability Equality Duty and this Disability Equality Scheme. Due date: Ongoing Progress: Actioned. This was completed as part of the reprocurement of TVL’s cash schemes which was conducted in 2007. It was also included in the telecoms reprocurement exercise recently conducted by one of the TV Licensing partners. We will recirculate the BBC Equality Schemes to TVL contractors after the completion of the BBC’s Equality Schemes review project in July 2008. Lead: Operations Evidence/outcomes: Clear and explicit specifications (and contracts) regarding the duty to promote disability equality, which will allow for consistent, robust monitoring of contractors by the BBC.

2 TVL will aim to ensure that clear and explicit reference to disability equality issues and implications is contained within specifications (where permitted under the Public Contracts Regulations 2006). Due date: From April 2007 onwards Progress: Actioned Lead: Operations Evidence/outcomes: Potential contractors will be clear about the BBC’s duties and general approach to disability and will be expected to take these into account when delivering services.

3 At Invitation to Tender (ITT) stage and preferred bidder stages, all bidders will be briefed on the Disability Equality Duty and the BBC’s expectations related to the Disability Equality Duty. Due date: From April 2007 onwards Progress: Actioned Lead: Operations Evidence/outcomes: The BBC will be able to screen bidders at an early stage to ensure a positive approach to disability in planned service delivery.

4 TVL will clarify to bidders what impact the duty is likely to have on how they intend to deliver their services if their bid is successful. Due date: As necessary Progress: Actioned Lead: Operations Evidence/outcomes: Raised level of awareness among potential bidders.

5 TVL will continue to require all bidders to complete a corporate social responsibility questionnaire which includes matters relevant to the Disability Equality Duty. Due date: Ongoing Progress: Actioned Lead: Operations Evidence/outcomes: Increased understanding of how to mitigate potential adverse impacts for disabled people.

6 TVL will monitor contractors’ compliance with the BBC’s imposed contractual obligation in relation to the disability (and other) equality duties and this scheme as part of TVL’s standard business practice. Due date: From now on Progress: Actioned Lead: Policy

Evidence/outcomes: The BBC will be able to identify where a contractor may not be complying with duties or expected standards and take action to address. Drivers/informed by: DDA 2005 BBC Values: Audiences; Respect

Action Plan 2: The BBC Trust in relation to certain functions under the BBC Charter and Agreement (relating to involvement) What is the BBC Trust? The BBC Trust is supported by the BBC Trust Unit which in January 2007 took over from the Governance Unit, which had supported the BBC Governors previously. How are the public consulted and informed about the Trust’s activities and role? The Trust has a statutory requirement to consult publicly when carrying out a number of its key regulatory functions, for example when conducting Public Value Tests or Service Reviews. As it is the Trust’s role to represent all audiences, it is important that the methods it uses reach the full diversity of licence fee payers.

The Trust is always seeking to develop its understanding and awareness of the different needs and expectations that disabled people may have. The Trust regularly draws upon the support and advice of the BBC’s Diversity Centre. It also, where relevant, invites organisations who represent disabled people to stakeholder meetings, and recently encouraged these organisations to participate in the Audience Engagement consultation (for further details see page 22).

The Government previously carried out extensive public consultation connected with the transition to the Trust. The BBC’s Governance Unit also ensured that disabled licence fee payers were given the opportunity to meet with Governors and tell them first hand what they thought of the BBC’s programmes and services. (See also section 4.3 for information on involvement and a range of mechanisms already in place which aim to gather information related to disability and the Trust.) Action Plan aims That disabled people are afforded fair and equal access and maximum opportunity to participate in all relevant BBC public functions and related activities, through their increased involvement and representation in the new BBC Trust

This Action Plan details a series of planned actions which have been identified as necessary following an audit of current activity in relevant areas and through consultation and involvement with disabled people. Equality impact assessments, where appropriate, and the continual involvement with disabled people will inform ongoing review (see above and also sections 4.3 and 4.4).

Each action is cross-referenced with the relevant BBC Charter Article or Agreement Clause, where relevant to the Disability Equality Duty (see section 2 and Annex for more detail).

Objective 1 (revised in year 2) To ensure that the Trust actively engages with and seeks the views of women and men, and that engagement activities encourage participation and are accessible

1 The Trust’s Audience Engagement consultation will encourage and facilitate the full and meaningful involvement of disabled people and carers, in order to learn how disabled people and carers want to be involved in the Trust consultation and involvement activities, and how to facilitate this (ref. Charter Article 26). Due date: Year 1 (May–August 2007) Progress: Complete. The Audience Engagement Consultation EIA can be read on the BBC Trust website at: www.bbc.co.uk/bbctrust/assets/files/pdf/regulatory_framework/diversity/eia2007/audience _engagement.pdf Lead: The Trust Unit (Audiences team) Evidence/outcomes: A fair, equal and transparent consultation which produces a list of recommendations about how the Trust would involve and facilitate disabled people and carers.

2 Specific recommendations arising out of the Audience Engagement consultation will be agreed by the Trust to ensure that appropriate support is given to continuing involvement of disabled people in the Trust’s decision-making (ref. Charter Article 26). Due date: Year 1 Progress: Complete Lead: The Trust Unit (Audiences team) Evidence/outcomes: Audience Engagement Protocol published and any other associated documents that include recommendations arising out of the consultation exercise with disabled people and carers.

3 The Trust will provide Braille and audio versions of all publicly available documents on request (within a published maximum time limit) and will seek to meet other specific communications needs by providing accessible online documents and alternative formats, such as easy read or pictorial, wherever possible. (Applicable to all public functions – see Annex.) Due date: Year 1–3 Progress: Actioned Lead: The Trust Unit Evidence/outcomes: When requested, the prompt provision of audio and Braille documents so that disabled persons and carers can participate or engage in the Trust’s activities.

4 The Trust will seek to ascertain specific needs in advance of all meetings (internal and external) and appropriate adjustments will be made to facilitate the involvement of all disabled people and carers, whether members of the Trust, BBC employees or members of the public or audience. (Applicable to all public functions – see Annex.) Due date: Years 1–3 Progress: Actioned. Lead: The Trust Unit (Audiences team) Evidence/outcomes: The Trust’s meetings will be held in venues which are accessible to disabled persons. Public meetings will be supported by a sign language interpreter and, if requested, a palantypist or any other specialist services identified prior to the date.

5 All other communications (which are made as part of the discharge of a public function) will also be provided on request in Braille and audio (within a published maximum time limit). The Trust will also seek to meet other specific communications needs by providing accessible online documents and alternative formats such as easy read or pictorial versions, wherever possible. (Applicable to all public functions – see Annex.) Due date: Years 1–3 Progress: Actioned Lead: The Trust Unit Evidence/outcomes: Evidence of prompt provision of audio and Braille documents (when requested) to facilitate disabled persons’ and carers’ participation or engagement in the Trust’s activities.

6 Introduce diversity monitoring of consultations, meetings, etc to measure and report on performance and to inform action planning or review where necessary. (New action in year 2.) Due date: Years 2–3 Progress: Actioned Lead: The Trust Unit (Audiences team) Evidence/outcomes: Evidence of a monitoring system in place.

7 Working with staff, improve the implementation of diversity monitoring forms, so that there is greater consistency and regularity of use across the Trust Unit. (New action in year 2.) Due date: Years 2–3 (from July 2008) Lead: The Trust Unit (Audiences team) Evidence/outcomes: Evidence of more consistent diversity information collected by the Trust.

8 Develop a set of principles which will aid the way in which the Trust commissions its research and collects classification data, so that it improves its understanding of diverse audiences. (New action in year 2.) Due date: Years 2–3 (from July 2008) Lead: The Trust Unit (Audiences team) Evidence/outcomes: A systematic process will be put in place to ensure that over time the Trust increases its understanding of the full diversity of licence fee payers.

Drivers/informed by: DDA 2005 BBC Values: Audiences; Respect; Working Together Recommendations following involvement with disabled stakeholders (ref. Churchill, Minty & Friend report) Objective 2 (revised in year 2) To monitor and assess the BBC’s strategic approach to disability equality in order to review and continually improve outcomes for disabled people

1 The Trust will put into place mechanisms to assess the performance of the Executive Board in promoting disability equality in carrying out the public functions of the BBC and will hold it to account (ref. Charter Article 24). Due date: Year 1 (July 2007) Lead: The Trust Unit (Audiences team) Progress: Complete Evidence/outcomes: The BBC Executive Board’s performance reported by the Trust in an annual report.

2 The Trust will put into place mechanisms to assess its performance in promoting disability equality in carrying out its public functions. (New action in year 2.) Due date: Year 2 (July 2008 ) Progress: Complete Lead: The Trust Unit (Audiences team) Evidence/outcomes: A summary of the Trust’s performance reported in an annual report.

3 The Trust will monitor the steps which the BBC has taken to fulfil the disability equality duty in respect of its TV licensing public functions in the BBC Annual Report and Accounts (ref. Charter Article 24). Due date: Year 2 (July 2008) and then on an annual basis until year 3 Progress: Actioned Lead: The Trust Unit (Audiences team)

Evidence/outcomes: Effective mechanisms for monitoring activities are in place (as part of this Action Plan).

4 Through revising the relevant code of practice for the Executive Board, the Trust will ensure that independent producers are required to comply with applicable requirements under the DDA when supplying output for the BBC (ref. Agreement Clause 61). Due date: Years 1–3 Progress: Not applicable in year 1. Carried over to year 2. Lead: The Trust Unit (Finance, Economics and Strategy) Evidence/outcomes: The BBC Executive Board’s performance reported by the Trust in an annual report.

5 In reporting to the Secretary of State, the Trust will comment on the compliance by the BBC with its disability equality obligations in relation to digital switchover (ref. Agreement Clause 41). Due date: Year 2 (July 2008) and then on an annual basis until year 3 Progress: Actioned Lead: The Trust Unit (Audiences team) Evidence/outcomes: Annual report to the Secretary of State published and including relevant disability equality related information.

6 The Trust’s commentary of the Annual Report and Accounts will include the Trust’s statement on how it views the BBC is meeting the needs of different groups of people (ref. Charter Article 45). Due date: Year 2 and then on an annual basis until year 3 Progress: Actioned Lead: The Trust Unit ( Audiences team) Evidence/outcomes: Annual reports publicly available from the Trust, which show the performance of the BBC Executive Board in fulfilling the Disability Equality Duty.

Drivers/informed by: DDA 2005 BBC Values: Audiences; Respect Objective 3 (revised in year 2) To ensure that all disabled people have equal and fair access to the Trust’s complaints processes

1 The Trust will set and publish a framework for dealing with complaints. This will comply with access actions set out in objective 1 action 1 above (ref: Charter Articles 24 and 25 and Agreement Clauses 89 and 90).

Due date: Year 2 Progress: Complete. A summary of the complaints framework consultation EIA can be read on the BBC Trust website: www.bbc.co.uk/bbctrust/consult/closed_consultations/complaints_eia.html Lead: The Trust Unit (Editorial Standards team) Evidence/outcomes: Complaints framework published which has fair involvement of disabled people and carers.

2 When handling appeals, the Trust will ensure that the Complaints Manager identifies and provides the necessary advice and support required for those persons who are unable to submit their appeal in writing (ref. Charter Article 24). Due date: Already operational Progress: Actioned Lead: The Trust Unit (Editorial Standards team) Evidence/outcomes: Disabled persons are able to submit a complaint in a timely way and with the necessary support, so that they are not deterred or prevented from participating in the BBC complaints process.

3 In relation to hearings, information on specific needs will be sought in advance and the appropriate adjustments will be made to facilitate the full participation of any disabled person (ref: Charter Article 24). Due date: Years 1–3 Progress: Actioned Lead: The Trust Unit (Editorial Standards team) Evidence/outcomes: When requested or identified, additional adjustments will be made to facilitate the participation of disabled people and carers.

4 In setting and publishing a framework for dealing with complaints, the Trust will identify alternative accessible methods for making a complaint and ensure that these are publicised (ref. Charter Articles 24 and 25). Due date: Year 2 Progress: Complete Lead: The Trust Unit (Editorial Standards team) Evidence/outcomes: When consulting on the complaints framework, the Trust will ensure the involvement of disabled people and carers so that alternative accessible methods for making a complaint are identified.

Drivers/informed by: DDA 2005 BBC Values: Audiences; Respect; Working Together

Objective 4 (revised in year 2) To ensure that disabled people have equality of access to consultations and are involved in Trust decision-making regarding issues which are of a public nature

1 The Trust will issue and consult on a draft protocol on its engagement with licence fee payers, covering public meetings, website and consultations for example. The consultation planning will seek to ensure the full involvement of disabled people through a range of appropriate and accessible initiatives (ref. Charter Articles 25, 26 and 27). Due date: Year 1 (May–August 2007) Progress: Complete Lead: The Trust Unit (Audiences team) Evidence/outcomes: Publication of the Audience Engagement Protocol and any other associated documents that incorporate the recommendations coming out of the consultation exercise with disabled people.

2 As part of the consultation on the Audience Engagement Protocol, particular attention will be paid to the Audience Councils and how disabled people are positively encouraged to become involved. If there are any implications for the Trust’s Audience Councils Protocol this will also be identified (ref. Charter Article 39 (7) and (8)). Due date: Year 1 (May–August 2007) Progress: Complete Lead: The Trust Unit (Audiences team and the Governance and Accountability teams across the nations and regions Evidence/outcomes: An inclusive Audience Council Protocol published and available on the Trust website.

3 An EIA will be conducted prior to the Trust commencing any new consultations. The outcomes of this will inform further action. (New action in year 2.) Due date: Years 2-–3 Progress: Actioned Lead: The Trust Unit (The Audiences team) Evidence/outcomes: A systematic process will be in place to ensure that future policies and related practices will be screened at the development stage to determine potential negative (or positive) impacts on different groups.

Drivers/informed by: DDA 2005 BBC Values: Audiences; Respect; Working Together Recommendations following involvement with disabled stakeholders (ref. CM&F report)

Objective 5 (revised in year 2) To ensure that, where appropriate and reasonable, the Trust’s public reports and communications (including online) are accessible (in language, format and content) for disabled people

1 The Trust will ensure that Braille and audio versions of the Annual Report and Accounts will be provided on request (within a maximum set time limit) and will explore what other formats might be necessary to meet other specific needs. Due date: Years 1–3 Progress: Actioned Lead: The Trust Unit (Finance, Economics and Strategy team) Evidence/outcomes: Evidence of prompt provision of audio and Braille documents (when requested) to facilitate disabled persons’ and carers’ participation or engagement in the Trust’s activities.

2 The Trust will review the BBC’s commitments for access services in relation to party political broadcasts and referendum campaigns (ref. Agreement Clause 48). (Revised action.) Due date: Years 1–3 Progress: Action reviewed Lead: The Trust Unit (Editorial Standards team) Evidence/outcomes: The Trust will approve a policy by the Executive Board on party political and referendum campaign broadcasts. The Trust will expect the Executive Board to review the policy from time to time, and not less than every five years.

3 The Trust will provide Braille and audio versions of all publicly available documents on request (within a published maximum time limit) and will seek to meet other specific communications needs by providing accessible online documents and alternative formats such as easy read or pictorial wherever possible. (Applicable to all public functions – see Annex.) Due date: Years 1–3 Progress: Actioned Lead: The Trust Unit Evidence/outcomes: When requested, the prompt provision of audio and Braille documents so that disabled persons and carers can participate or engage in the Trust’s activities. 4 An EIA will be conducted prior to the Trust publishing the Annual Report. The outcomes of this will inform further action. (New action in year 2.) Due date: Years 2–3 Progress: Actioned

Lead: The Trust Unit (Finance, Economics and Strategy team) Evidence/outcomes: A systematic process will be in place to determine potential negative (or positive) impacts on different groups, in the publication of the Annual Report. 5 To ensure that the Trust website meets both the statutory and the BBC’s accessibility requirements. (New action in year 2.) Due date: Years 2–3 Lead: The Trust Unit (The Communications team) Evidence/outcomes: An accessible website. Drivers/informed by: DDA 2005 BBC Values: Audiences; Respect; Working Together Objective 6 (new in year 2) To ensure that diversity and equality matters are integrated into the Trust’s governance tools

1 The appropriate Trust Unit team will be responsible for conducting an EIA prior to the Trust commencing any new activity, project, policy, strategy or review which is of a public nature. The outcomes of this will inform further action. (New action in year 2.) Due date: Years 2–3 Lead: The Trust (Audiences team) Evidence/Outcomes: A systematic process will be put in place to ensure that future activity, project, policy, strategy, policies and reviews will be screened at the development stage to determine potential (or positive) impacts on different groups. 2 Implement the recommendations in the independent ‘Mainstreaming Equality and Diversity’ report. (New action in year 2.) Due date: Years 2–3 (from July 2008) Lead: The Trust (Audiences team) Evidence/outcomes: Long-term commitment to embedding diversity into all of the Trust’s work.

Drivers/informed by: DDA 2005 BBC Values: Audiences; Respect; Working Together

Objective 7 (new in year 2) To ensure that Audience Councils are fully inclusive and should as far as possible reflect the diversity of society they represent. The Trust will actively encourage membership from disabled people, people from diverse ethnic and cultural backgrounds and a gender-balanced membership wherever practicable and possible. The Trust will also work with Audience Councils to ensure that they engage effectively with diverse communities to enhance members’ understanding of audience concerns.

1 Continue to monitor the diversity of Audience Council members to inform action planning and review where necessary. (New action in year 2.) Due date: Years 2–3 Progress: Actioned Lead: The Trust Unit (Governance and Accountability teams across the nations) Evidence/outcomes: Audience Councils having a balanced and representative membership over time. 2 In discharging their Charter responsibilities, the Audience Councils will ensure that they engage with and positively encourage the involvement of people from different ethnic and cultural backgrounds and disability-relevant organisations where appropriate (ref. Charter Article 39 (7) and (8). (New action in year 2.) Due date: Years 2–3 Progress: Actioned Lead: The Trust Unit (Governance and Accountability teams across the nations) Evidence/outcomes: Evidence that different groups of people inform the work of the Audience Councils. Drivers/informed by: DDA 2005 BBC Values: Audiences; Respect; Working Together NB: Charter Articles 22 and 23: No specific actions, but will be addressed through actions against the more detailed public functions of the Trust.

Agreement Clause 18: This provision has been assessed by the BBC and found to be a public function not relevant to the general duty.

Action Plan 3: The BBC in relation to certain functions under the BBC Agreement Section (i): The BBC’s obligations in relation to digital switchover (Agreement Clauses 34–41) What is digital switchover? Starting in 2008 and ending in 2012, TV services in the UK will go completely digital. This switchover process will take place region by region. The UK’s analogue television broadcast signal will be switched off and digital terrestrial TV coverage will increase to 98.5% across the UK.

Digital switchover involves major technological changes across the UK television broadcast infrastructure which need to be carried out not only by the BBC but also by all other terrestrial broadcasters including ITV, Channel 4, Five and S4C, and the transmission companies SDN and National Grid Wireless. Digital switchover is also about ensuring that people have adapted or upgraded their televisions and recording equipment to receive digital TV. What help will be available to consumers who need it? On confirming the timetable for digital switchover in the UK, the Secretary of State for Culture, Media and Sport made it clear that the transition to digital-only broadcasting needed to be an inclusive process and gave a commitment that people who would find the change to digital TV most challenging would be supported through a comprehensive help scheme. Under the Charter and Agreement, the BBC is responsible for delivering the Digital Switchover Help Scheme. The BBC, through its subsidiary DSHS Ltd, recently appointed eaga plc as the appropriate contractor. The tender process included a specific focus on meeting the needs of disabled people. For more information on the Help Scheme please visit www.digitaltelevision.gov.uk/helpscheme/hs_home.html. Digital Switchover Help Scheme To help ensure that everyone can switch more easily to digital TV, there will be a Digital Switchover Help Scheme for those who need it most.

The Digital Switchover Help Scheme is focused on providing practical assistance and support to people who need it most, specifically those who: are 75 and over receive Disability Living Allowance, Attendance Allowance, Constant Attendance Allowance or Mobility Supplement are registered as blind or partially sighted

The scheme will help people to select, install and use digital television equipment and will include: providing equipment to convert one TV set help with installation follow-up support

The scheme will cost £40 to participate in. However, it will be free to those receiving Income Support, Job Seeker’s Allowance or Pension Credit.

The BBC’s subsidiary DSHS Ltd expects 7 million households to be eligible for the Help Scheme in the UK. These households will be able to opt in region by region between 2008 and 2012.

A pilot Help Scheme was in place as part of Project Whitehaven where digital switchover was trialled. A full evaluation has informed how both digital switchover and the help scheme are introduced across the country. www.digitaluk.co.uk/__data/assets/pdf_file/0004/9670/DUK_Copeland_ReportWEB010508.pdf How are the public being consulted on and informed about digital switchover? Digital UK is the independent, not-for-profit organisation leading the process of digital switchover in the UK. Digital UK provides impartial information on what people need to do to prepare for the move to digital, and when they need to do it.

Digital UK was set up at the request of the Government to manage all communications with the public regarding digital switchover. Digital UK works closely with the Department for Culture, Media and Sport (DCMS) and the Department for Business, Enterprise and Regulatory Reform (BERR), as well as the regulator Ofcom, to prepare the UK for the changes.

Digital UK is owned by the UK’s public service broadcasters (BBC, ITV, Channel 4, Five, S4C and Teletext) and the transmission companies SDN and National Grid Wireless. Digital UK works with digital TV platform operators, equipment manufacturers, installers, retailers, rental companies and consumer groups to coordinate the technical rollout of digital television across the UK.

(See also section 4.3.3 for information on involvement and a range of mechanisms already in place which aim to gather information related to disability and digital switchover.)

In 2007 the BBC, through DSHS Ltd, consulted with nearly 150 disabled and older people and over 30 disability organisations in order to shape the Digital Switchover Help Scheme, for example developing a Code of Service Standards which sets out what people eligible for the scheme can expect from the service. This consultation has also informed how the scheme will communicate with people eligible for the scheme.

NB: Because of the collaborative nature of the digital switchover project, involving Digital UK, the DCMS, BERR and Ofcom, the BBC does not have control over all of the actions in its Action Plan. Where this is the case, the BBC will meet its commitment by working closely with the relevant organisation and will use its best endeavours to ensure that the actions are achieved. Action Plan aims That disabled (and older) people experience or receive appropriate and accessible digital switchover and Digital Switchover Help Scheme information, advice and targeted support throughout the entire transition period

This Action Plan, section (i), shows in detail how current digital switchover activities which are relevant to the Disability Equality Duty will be maintained and progress monitored. It also details a series of planned actions which have been identified, including those in relation to the Help Scheme, through consultation and involvement with disabled people. Equality impact assessments, where appropriate, and continual involvement with disabled people will inform ongoing review (see also above and sections 4.3 and 4.4).

In particular, the Action Plan sets out how the BBC, and its subsidiary DSHS Ltd, and Digital UK will work together (see also section 4.3.3) and will specify: The ways in which disabled people have been involved in development of the digital switchover (DSO) communications and activities. Methods for assessing the impact of DSO and Help Scheme policies and practices or proposed policies and practices on disabled people. The steps which Digital UK is taking towards the fulfilment of the Disability Equality Duty in respect of equal access to information and support through the DSO programme. Arrangements for gathering information on the effect of DSO policies and practices on disabled people and the arrangements for information usage to assist the BBC in complying with the Disability Equality Duty. How Digital UK and the BBC will work together to ensure that the BBC has sufficient information to comply with the Disability Equality Duty. How policies which aim to ensure that disabled organisations and individuals are actively engaged with DSO have been shared with the BBC and will be forwarded and shared as they are developed.

Note: this Action Plan reflects future activity only and does not reference where activities are well established and ongoing.

Objective 1 To assist the “most vulnerable beneficiaries” (older and disabled people) to make the switchover to digital TV

1 The BBC to continue to work with DCMS, BERR and Digital UK on the Digital Switchover Help Scheme. Due date: 2007 onwards Progress: Ongoing Lead: BBC Chief Operating Officer and BBC Director of Marketing, Communications & Audiences, working alongside Digital UK and other industry partners Evidence/outcomes: Older and disabled people entitled to assistance benefit from the Help Scheme. Measured by the BBC’s subsidiary DSHS Ltd through contractual service level agreements.

2 The BBC, through its subsidiary DSHS Ltd, to identify an appropriate provider to deliver the Digital Switchover Help Scheme. The BBC to reflect disability equality in the Invitation to Tender and the scheme’s Schedule of Service Requirements to ensure that the successful organisation is fully accessible to all scheme users. Prospective bidders to be assessed against accessibility-related service requirements. Due date: February 2008 onwards Progress: Completed. eaga plc was selected in February 2008 to deliver the Help Scheme. Lead: BBC Finance Director Evidence/outcomes: Older and disabled people can access the Help Scheme. The Help Scheme is measured by the BBC through its subsidiary DSHS Ltd against specific performance indicators which reflect satisfaction rates and accessibility of the scheme.

3 The BBC, through its subsidiary DSHS Ltd, to work with the successful contractor to ensure that equality impact assessments (EIAs) of their policies, procedures and practices are conducted. Due date: February 2008 Progress: Ongoing Lead: BBC Finance Director Evidence/outcomes: Older and disabled people can access the Help Scheme. The Help Scheme is measured by the BBC through its subsidiary DSHS Ltd against specific performance indicators which reflect satisfaction rates and accessibility of the scheme.

4 The BBC, through its subsidiary DSHS Ltd, to measure the performance of the successful contractor according to accessibility-oriented indicators.

Due date: February 2008 Progress: Ongoing Lead: BBC Finance Director Evidence/outcomes: Older and disabled people can access the Help Scheme. The Help Scheme is measured by the BBC through its subsidiary DSHS Ltd against specific performance indicators which reflect satisfaction rates and accessibility of the scheme.

5 The BBC, through its subsidiary DSHS Ltd, to ensure that the Code of Service Standards (CoSS), developed through comprehensive consultation and involvement with disabled people, is available to every person eligible for the Help Scheme. Due date: 2008–2012 Progress: Ongoing. The CoSS has been developed in consultation with disabled people. Lead: BBC Finance Director Evidence/outcomes: Older and disabled people can access the Help Scheme. The Help Scheme is measured by the BBC through its subsidiary DSHS Ltd against specific performance indicators which reflect satisfaction rates and accessibility of the scheme.

6 The BBC, through its subsidiary DSHS Ltd, to ensure that analysis and evaluation of the pilot scheme operating as part of Project Whitehaven informs the development of the Digital Switchover Help Scheme to be rolled out across the country. Due date: Analysis of Project Whitehaven findings by end of Quarter 2 2008 Progress: Completed Lead: BBC Finance Director Evidence/outcomes: Older and disabled people can access the Help Scheme. The Help Scheme is measured by the BBC through its subsidiary DSHS Ltd against specific performance indicators which reflect satisfaction rates and accessibility of the scheme.

7 BBC Digital UK board members monitor and influence Digital UK activities and ensure that the needs of disabled people and carers (and older people) are being addressed. Due date: May 2007 onwards Progress: Ongoing. BBC representatives meet quarterly with Digital UK to monitor progress on equality and diversity, including disability equality. Lead: BBC Finance Director Evidence/outcomes: Digital UK information is accessible and includes options for receiving digital TV.

8 BBC representatives will attend Digital UK’s quarterly Finance & Marketing Committee (F&MC) meetings to drive forward a strategy aimed at ensuring a consistent and systematic approach to assisting disabled people. Due date: May 2007 onwards Progress: Ongoing Lead: BBC Finance Director Evidence/outcomes: F&MC operates as a formal arena to ensure a consistent approach to assisting disabled people.

9 The BBC to advise on minimum standards for ensuring accessibility and inclusiveness for the most vulnerable groups. Due date: June 2007 onwards Progress: BBC representatives meet quarterly with Digital UK to monitor progress specifically on equality and diversity, including disability equality. Lead: BBC Finance Director Evidence/outcomes: Policy on agreed minimum standards in place. The BBC to forward accessibility communications policy.

10 The BBC will attend BERR Usability Group meetings and use these to encourage the digital television supply chain to give full technological consideration to providing a solution for those dependent on environmental controls and to ensure that relevant information is promoted appropriately to disabled audiences. Due date: 2007 onwards Lead: BBC Finance Director Evidence/outcomes: The BBC regularly attending Usability Group meetings and contributing advice regarding needs of disabled users.

11 Ongoing engagement of Digital UK Regional Managers with disability relevant organisations including consumer groups, charities (including disabled groups), volunteer groups and social services departments within local authorities. Due date: Region-specific start dates according to regional rollout of DSO: 2007 onwards Progress: Digital UK has contracted Digital Outreach Limited (a consortium made up of Help the Aged, Age Concern, Community Service Volunteers and Collective Enterprises Ltd) for work in the first four regions to undergo digital switchover. Digital Outreach Limited will map the demographics and community infrastructure of each region in order to develop a strategy for meeting people’s needs in partnership with local community organisations and volunteers. Lead: BBC Finance Director Evidence/outcomes: Outcomes included in Digital UK’s current reporting procedures.

Drivers/informed by: DDA 2005 Government White Paper BBC Values: Audiences; Respect Recommendations following involvement with disabled stakeholders (ref. CM&F report)

Objective 2 To ensure that the transition to digital-only broadcasting is a fully inclusive process

1 Through attending its quarterly F&MC meetings, the BBC will monitor Digital UK’s general and specific marketing for inclusiveness and accessibility and request improvements as and when necessary, for example following evaluation of Project Whitehaven communications. Due date: May 2007 onwards Progress: Ongoing. BBC representatives meet quarterly with Digital UK to monitor progress on equality and diversity, including disability equality. Lead: BBC Finance Director Evidence/outcomes: Digital UK consistently produces inclusive and accessible communications on digital switchover (copies supplied to the BBC). Ofcom/Digital UK Tracker results. Lessons learned from Project Whitehaven.

Drivers/informed by: DDA 2005 Government White Paper BBC Values: Audiences; Respect Recommendations following involvement with disabled stakeholders (ref. CM&F report)

Objective 3 To ensure that all digital switchover and Help Scheme related information and modes of communication are appropriate for the target audience and are fully accessible

1 Digital UK actively engages with relevant disabled organisations and disabled people through its ongoing work with a number of groups such as Consumer Expert Group, RNIB, RNID, TAG, Wireless for the Bedridden, SENSE, Age Concern, Help the Aged, Ofcom Consumer Panel, and Ofcom Advisory Committee on Older and Disabled People. This work may involve research from time to time and any findings will be used to inform further review of this Action Plan. Due date: 2007 onwards

Progress: Ongoing. BBC representatives meet quarterly with Digital UK to monitor progress on equality and diversity, including disability equality. Lead: BBC Finance Director Evidence/outcomes: Ofcom/Digital UK Tracker results and Churchill Minty & Friend report feedback. 2 At F&MC quarterly meetings, the BBC and Digital UK will monitor the spectrum of digital switchover and Help Scheme communications to check for appropriate style and format plus relevant content. Due date: May 2007 onwards Progress: Ongoing. BBC representatives meet quarterly with Digital UK to monitor progress on equality and diversity, including disability equality. Lead: BBC Finance Director Evidence/outcomes: People can contact Digital UK in various ways, for example by telephone, textphone, white mail, email, through local roadshows and digital clinics. Information on specialist resources for disabled people is provided.

3 The BBC will work with Digital UK to ensure basic minimum standards of accessible communications which are appropriate to different media platforms as some standard routes may present barriers to some groups, for example subtitling and audio description. Due date: June 2007 onwards Progress: Ongoing Lead: BBC Finance Director Evidence/outcomes: Policy on standards in place. Code of Service Standards.

4 The BBC will work with Digital UK to provide, wherever practicable, specific forms of communication which are relevant and appropriate for relevant audiences, for example those with sensory impairments or learning difficulties. Due date: June 2007 onwards Progress: Ongoing. Lead: BBC Finance Director Evidence/outcomes: Identified target groups receiving information in specific formats, where practicable.

5 The BBC will attend BERR Usability Group and encourage the development of a platform-neutral information resource which signposts people to specialist equipment and functions, such as compatibility with audio description or subtitling. Due date: June 2007 onwards Progress: Ongoing.

Lead: BBC Finance Director Evidence/outcomes: Specialist information is available in Digital UK communications to advise on access functions and services, for example audio description. Digital UK provides signposts to relevant information on its website such as Ricability consumer reports. Objective 4 To involve disabled people in the planning and rollout of digital switchover and in the planning and rollout of the Help Scheme

1 Consumer Expert Group (CEG) meetings occur regularly to advise DCMS and Digital UK on the DSO programme. Due date: May 2007 onwards Progress: Ongoing Lead: BBC Finance Director Evidence/outcomes: CEG meetings and Digital UK CEG feedback.

2 Regular meetings of the Usability Action Plan group will take place led by BERR. Due date: May 2007 onwards Lead: BBC Finance Director Evidence/outcomes: BERR Usability Action Plan Group Meetings.

3 The BBC will ensure that the findings of the Churchill, Minty & Friend consultation report are shared with Digital UK. Progress: Complete Lead: BBC Finance Director Evidence/outcomes: Digital UK has the Churchill Minty & Friend consultation report.

4 The BBC, through its subsidiary DSHS Ltd, to run a programme of consultation and involvement with disabled people with experience of a range of disabilities, through face-to-face interviews and focus groups, in order to inform the development of the Help Scheme. Progress: Complete Lead: BBC Finance Director Evidence/outcomes: Code of Service Standards developed with disabled and older people setting out clearly and accessibly what users can expect from the service. Preferred set of communication formats also identified. Consultation findings.

5 Outcomes of the consultation and involvement with disabled people conducted in order to shape the Help Scheme, also to inform Digital UK’s communications strategy. Due date: November 2007 onwards Progress: Not completed Lead: Digital UK Evidence/outcomes: Digital UK communications strategy reflects the outcomes of the consultation and involvement with disabled people. Communications by Digital UK and potential Help Scheme users are fully accessible.

6 Digital UK and Ofcom monthly research into disabled people’s attitudes, awareness and understanding of digital switchover and the Help Scheme will be used to assess the impact of the Digital UK communications strategy. Due date: May 2007 onwards Progress: Ongoing. BBC representatives meet quarterly with Digital UK to monitor progress on equality and diversity, including disability equality. Lead: Digital UK Evidence/outcomes: Ofcom/Digital UK Tracker results. Digital UK communications evolve during the digital switchover programme.

7 Digital UK regional managers to meet with local charity and volunteer organisations and local authorities. Due date: May 2007 onwards Progress: Digital UK has contracted Digital Outreach Limited (a consortium made up of Help the Aged, Age Concern, Community Service Volunteers and Collective Enterprises Ltd) for the first four regions. Digital Outreach Limited will map the demographics and community infrastructure of each region in order to develop a strategy for meeting people’s needs in partnership with local community organisations and volunteers. Lead: Digital UK Evidence/outcomes: Digital UK regional manager meetings with local charity and volunteer organisations and local authorities taking place.

Drivers/informed by: DDA 2005 Government White Paper BBC Values: Audiences; Respect Recommendations following involvement with disabled stakeholders (ref. CM&F report)

Objective 5 To gather and use information effectively in order to monitor and assess the impact of current and planned DSO policies and practices with regard to disability equality 1 Digital UK will use this research to review which groups may need more targeted digital switchover and Help Scheme communications. Due date: 2007 onwards Progress: Ongoing. BBC representatives meet quarterly with Digital UK to monitor progress on equality and diversity, including disability equality. Lead: Digital UK Evidence/outcomes: Ofcom and Digital UK publish consultation reports on their websites.

2 Digital UK and Ofcom Advisory Committee on Older and Disabled People (ACOD) will carry out digital switchover and the Help Scheme qualitative research and focus groups with disabled people. Due date: August 2007 Progress: Ongoing. BBC representatives meet quarterly with Digital UK to monitor progress on equality and diversity, including disability equality. Lead: Digital UK Evidence/outcomes: Ofcom/Digital UK Tracker reports are published quarterly and available on both organisations’ websites.

3 Analyse and evaluate findings from Project Whitehaven to capture learning and report back to the Diversity Board, BBC Executive Board and BBC Trust. Due date: Analysis of Project Whithaven findings by end Quarter 2 2008 Lead: Digital UK Evidence/outcomes: Recommendations from Project Whitehaven demonstrably incorporated into future digital switchover communications.

4 The BBC will work with Digital UK to identify all key DSO policies, functions, project elements and prioritise for (disability) equality impact assessments. Due date: From February 2008 Progress: Ongoing Lead: Digital UK Evidence/outcomes: Prioritised timetable in place for equality impact assessments.

5 The BBC will work with Digital UK to conduct (disability) equality impact assessments according to prioritised timetable. Due date: From January 2008 and as timetabled Progress: Ongoing Lead: Digital UK Evidence/outcomes: Records of equality impact assessments available.

Drivers/informed by: DDA 2005 Government White Paper BBC Values: Audiences; Respect Recommendations following involvement with disabled stakeholders (ref. CM&F report)

Objective 6 To ensure effective internal monitoring and Disability Equality Scheme outcomes evaluation 1 The BBC will monitor and update this Action Plan and review as necessary, for example following the Project Whitehaven evaluation. Due date: May 2007 onwards Lead: Digital UK Evidence/outcomes: Action Plan is regularly reviewed and updated.

2 The BBC and Digital UK DSO team will conduct Action Plan annual reviews, and the three-yearly formal scheme review will go to the BBC Executive Board and the BBC Trust for approval. Due date: April 2008 onwards Progress: Ongoing Lead: Digital UK Evidence/outcomes: Formal reviews approved by responsible team and reports available to the BBC and Digital UK.

3 The BBC will set up internal mechanisms for progress monitoring and reporting to the Diversity Board, BBC Executive Board and BBC Trust. Due date: May 2007 onwards Progress: Ongoing Lead: Digital UK Evidence/outcomes: Clear roles and responsibilities are documented for the internal team.

Drivers/informed by: DDA 2005 Government White Paper BBC Values: Audiences; Respect Recommendations following involvement with disabled stakeholders (ref. CM&F report)

NB: Agreement Clauses 40 and 41: These provisions have been assessed by the BBC and have been found to be public functions not relevant to the general duty.

Action Plan 3: The BBC in relation to certain functions under the BBC Agreement Section (ii): Other functions of the BBC in relation to certain functions under the BBC Agreement (Agreement Clauses 12, 59–60, 74, 81) What is the BBC Agreement? In addition to the Royal Charter, the BBC has entered into a Framework Agreement with the Secretary of State for Culture, Media and Sport. This Agreement deals with a number of important matters (see page 10 and Annex for more detail). How are the public consulted and informed about the BBC Agreement? During recent extensive public consultation connected with the transition from the BBC Governors to the BBC Trust arrangement, disabled licence fee payers were given the opportunity to meet with Governors and tell them at first hand what they thought about the proposed Charter and Agreement (see also sections 4.3 and 4.4). Action plan aims That disabled people and audiences are afforded fair and equal access and maximum opportunity to participate in all relevant BBC public functions and related activities, through ensuring full access to all public information and involvement activities

This Action Plan (section ii) details a series of planned actions which have been identified as necessary following an audit of current activity in relevant areas and through consultation and involvement with disabled people. Equality ipact asessments, where appropriate, and continual involvement with disabled people will inform ongoing review (see above and also section 4.3). Each action is cross- referenced with the relevant Agreement Clause, where relevant to the Disability Equality Duty. Objective 1 To anticipate and wherever practicable meet the diverse needs of disabled people who access or seek to access UK public services

1 The BBC will continue to extend and monitor the provision of access services in order to meet its targets for television: • 100% subtitling April 2008 • 10% audio November 2007 • 5% signing November 2007

The BBC will continue to develop and publish online services that meet the accessibility requirements of our users. Due date: Ongoing Progress: All three targets have been achieved and exceeded. Lead: Wilf White Evidence/outcomes: BBC Access Services target met (TV). 2 The BBC will continue to develop and publish online services that meet the accessibility requirements of our users. Due date: Ongoing Progress: Ongoing Lead: Tony Ageh Evidence/outcomes: Digital accessibility is a fundamental objective of the BBC’s digital service strategy. All new access services will meet the accessibility requirements of its users through compliance with the BBC’s Digital Accessibility Standards and Guidelines and involvement of users with disabilities when developing and testing its innovative services. 3 The BBC will continue to monitor the provision of access services for radio including: • Availability of majority of programmes online for seven days after transmission via BBC iPlayer • Provision of transcripts, where proportionate and reasonable, for example high demand anticipated for popular transmissions and specific requests, where practicable Due date: Ongoing Progress: Ongoing Lead: Richard Titus Evidence/outcomes: BBC Access Services commitments met via BBC iPlayer facility. 4 The BBC will consult groups which are representative of those with sensory impairments, regarding the most appropriate range of access services and in evaluating their effectiveness (ref. Agreement Clause 12). Due date: Ongoing Lead: Wilf White Evidence/outcomes: Documentary evidence of consultation and engagement with a range of relevant groups. Drivers/informed by: DDA 2005 BBC Values: Audiences; Respect; Working Together Recommendations following involvement with disabled stakeholders (ref. CM&F report)

Objective 2 To anticipate and meet communication needs of those with sensory impairments in order to ensure their access to UK services and to related information and consultation activities (as required by Ofcom’s code)

1 The BBC will ensure compliance with the Ofcom code (relating to provision for the deaf and visually impaired) as it is set out in the BBC Charter (ref. Agreement Clauses 59–60). Due date: Ongoing Progress: Ongoing Lead: Wilf White Evidence/outcomes: Compliance monitoring report available.

2 The BBC will ensure that any public documents relating to the Ofcom code and the BBC’s implementation of that code will be made available in accessible Braille and audio tape on request (within a maximum time limit) (ref. Agreement Clauses 59–60). Due date: May 2007 and ongoing Progress: Ongoing Lead: Wilf White Evidence/outcomes: Mechanisms in place for those with sensory impairments to request relevant accessible documents.

3 The BBC will seek to identify in advance of meetings or consultations related to the BBC’s implementation of the Ofcom code any specific requirements or support needs and will make appropriate adjustments in order to facilitate full participation by disabled people – whether members of BBC staff, members of Ofcom’s staff or representative persons (ref. Agreement Clauses 59–60). Due date: May 2007 and ongoing Progress: Ongoing Lead: Wilf White Evidence/outcomes: Relevant meetings are held in fully accessible venues, meetings are supported by a sign language interpreter and, if requested, a palantypist or any other specialist services identified prior to the date.

Drivers/informed by: DDA 2005 BBC Values: Audiences; Respect; Working Together Ofcom code Recommendations following involvement with disabled stakeholders (ref. CM&F report)

Objective 3 To ensure that specific financial information is fully accessible, through meeting the various communication needs of all disabled people

1 The BBC will ensure that copies of the Annual Report and Accounts will be provided on request to disabled persons in Braille or audio versions (within a maximum time limit) (ref. Agreement Clause 74). Due date: Ongoing Progress: Ongoing Lead: BBC Communications, Diversity Centre Evidence/outcomes: Evidence of prompt provision of audio and Braille versions of the Annual Report and Accounts (when requested) and additional alternative formats (as applicable), to facilitate full and equal access to such public documents for disabled persons and carers.

Drivers/informed by: DDA 2005 BBC Values: Audiences; Respect Recommendations following involvement with disabled stakeholders (ref. CM&F report) Objective 4 To ensure that all disabled people have equal access to specific public information announcements

1 The BBC will seek to ensure that all access service commitments are fully met when broadcasting or otherwise distributing announcements concerning defence and emergency arrangements (ref. Agreement Clause 81). Due date: Ongoing Progress: Ongoing Lead: Wilf White (Television) and Tony Ageh (Online) Evidence/outcomes: Broadcast distribution announcements concerning defence and emergency arrangements are fully accessible and clearly understood by all groups.

Drivers/informed by: DDA 2005 BBC Values: Audiences; Respect; Working Together

Annex

The BBC’s public functions A TV Licensing 1 Promotion of licensing requirements: Communication with general public

2 Promotion of licensing requirements: External stakeholder management

3 Customer relations

4 Operations: General

5 Operations: Policy development (which covers new and existing policies)

6 Operations: Database management

7 Operations: Payment processing

8 Operations: Issuing licences

9 Enforcement: Visiting and prosecution

10 Procurement

B The BBC Trust in relation to certain functions under the BBC Charter and Agreement The following functions of the BBC Trust are public functions for the purpose of this Scheme.

Charter Article 22: The Trust has responsibility for: • BBC stewardship of the licence fee revenue and its other resources. • Upholding the public interest within the BBC, particularly the interest of licence fee payers.

Article 23: General duties of the Trust. Article 24 • Assessing the performance of the Executive Board and holding it to account. • Issuing service licences for BBC services. • Discharging the regulatory functions accorded to the Trust and holding the Executive Board to account for the BBC’s compliance with programme standards, quotas and the law. • Setting the framework within which the BBC should handle complaints.

• Conducting investigations into any activity of the BBC which it suspects does not comply with the requirements supervised by the Trust. • Commissioning value-for-money investigations into specific areas of BBC activity. • Setting the BBC’s fair trading policy and holding the Executive Board to account for compliance with it. • Setting an approvals framework within which the Trust will assess proposals from the Executive Board for new services, significant changes to existing services, commercial services and other activities. • Ensuring that arrangements for collection of the licence fee are efficient, appropriate and proportionate.

Article 25: The Trust must adopt and publish Protocols setting out a detailed framework within which the Trust will discharge its functions. Article 26: Protocols must require the Trust to seek the views of, and engage with, licence fee payers and set out how it will do so. The Trust must consult publicly before adopting any protocol under Article 27. Article 27: Protocols on openness and transparency. Article 39 (7) and (8): The Trust shall set out in a Protocol details of how Audience Councils are to be set up, run and recruited. The Trust may make whatever arrangements it considers appropriate for supporting the work of the Audience Councils. Article 45 • The Trust must consider the annual report and statement of accounts prepared by the Executive Board and prepare a commentary. • The Trust must transmit the report and accounts and its commentary to the Secretary of State.

Agreement Clause 5: The Trust shall prepare purpose remits for each of the six public purposes. The Trust shall consult publicly about these. The Trust must keep these under review and may amend them. Clause 11 (6) : The Trust may approve the launch of new UK public services, or the termination of or material change to the nature of existing services. Clause 15: In performing its functions in relation to the UK public television services, the Trust shall have regard to the purposes of public service television broadcasting set out in section 264(4) of the Communications Act 2003. Clause 18: The activities which need a service licence. Clause 19: Before issuing a service licence, the Trust must have consulted publicly.

Clause 20: The Trust must review service licences periodically and at least once every five years. The Trust must publish information on its intended programme of reviews. In reviewing a service licence, the Trust must consult publicly. Clause 21 (5) (in relation to the BBC’s Statements of Programme Policy): The Trust must monitor the BBC’s performance in carrying out the proposals. Each annual report presented by the BBC shall contain a report on the performance of the BBC in this area. Clause 22 (3): It is the Trust’s responsibility to ensure that the principles which underlie the treatment of services are, where relevant, applied to non-service activities in a way which the Trust considers appropriate to the circumstances. Clause 25 (2): The Trust must judge when the Public Value Test must be applied before a decision is taken to make any significant changes to the UK public services. Clause 26 (4), (5) and (6): The Trust must consider the outcome of the public value assessment and the market impact assessment and reach provisional conclusions regarding the proposed change. The assessments must be published. The Trust must consult about its provisional conclusions. Clause 41: The Trust must provide the Secretary of State with an annual report. Clause 42: The Trust shall secure the efficient use of the radio spectrum available for use by the BBC or its contractors. Clauses 43–46: Duties of the Trust in relation to programme codes, etc. Clause 48: The BBC must include party political broadcasts and referendum campaign broadcasts. The Trust must determine which of the UK public broadcasting services are to include these and the basis on which and the terms and conditions subject to which such broadcasts are to be included. Clause 50: The Trust must impose on the Executive Board the requirements it considers appropriate in relation to programming for the nations and regions. The Trust must consult Ofcom on these proposals and must not make certain changes without the agreement of Ofcom. Clause 58: The Trust must impose requirements on the Executive Board in relation to the production of radio programmes and material for online services. Clause 61: The Trust shall require the Executive Board to draw up and from time to time revise a code of practice in relation to the commissioning of independent productions. Clause 65: The Trust must after a public consultation adopt and publish a statement of policy on fair trading. The Trust must keep the policy under review and conduct a comprehensive review at least every three years.

Clause 66: The Trust must publish a statement of its duty to have regard to the competitive impact of the BBC’s activities on the wider market. The Trust must adopt and publish codes dealing with those aspects of the operation of the UK public services that in its view could raise significant issues regarding the competitive impact to the BBC’s activities. Clause 85 (2) (in relation to the Executive Board’s report on equal opportunities and training arrangements): The Trust must publish its observations on the report. Clauses 89 and 90 (complaints): The Trust must set and publish one or more frameworks for dealing with complaints. This must include the handling and resolution of complaints about the observation of the relevant programme standards.

C The BBC in relation to certain functions under the BBC Agreement The following functions of the BBC are public functions for the purpose of this Scheme.

Agreement Clause 12: Making the UK public services widely available. Clauses 34–41: The BBC’s obligations in relation to Digital Switchover. Clauses 59–60: Code relating to provision for deaf and visually impaired people and power to modify targets. Clause 74: Reports and accounts about the commercial services. Clause 81: The BBC may be requested to broadcast or distribute announcements in relation to defence and emergency arrangements. Clause 88: The BBC may be directed to monitor and record specified media output. In complying with such direction the BBC is to be regarded as an agent of the Crown and to be acting in the public interest.