Disability Equality Scheme
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1 Disability Equality Scheme If you require information contained in this document in an alternative format, such as large print, Braille or audio tape contact:
Sara Burgess Head of Student Services Student Centre University of Bolton Deane Road Bolton BL3 5AB
Telephone: 01204 903482 Email: [email protected]
2 Contents: Page
1. Introduction 3
2. The Specific Duties 3
3. Disability Statement 4
4. Social Model of Disability 5
5. Involvement of disabled people in developing the scheme 6
6. Legal Framework 10
7. Responsibility of implementation 12
7.1 Collective and Institutional 12 7.2 Individual responsibility 13
8. Description of Current Approach 14
8.1 Student Centre 14 8.2 Academic Projects 18 8.3 Learning Support and Development 19 8.4 Staff 22 8.5 Estates 25 8.6 Finance, Procurement and Purchasing 26
9. Current Good Practice – External Validation 26
10. Data Collection 27 10.1 Benchmark data for disabled staff 27 10.2 Benchmark data for disabled students 28
11. Impact Assessment 28
12. Monitoring, Evaluation and Review 29
13. Publication of Outcomes 29
14. Action Plan 31
15. Appendices 39
Appendix 1 Impact Assessment Process 39
3 1. Introduction
The University is committed to taking positive steps to eliminate discrimination in its policies, practices and procedures and this intention underpins the University’s Equal Opportunities Policy.
The Disability Equality Scheme is designed to assist managers to review their services and to remove barriers to disabled people. These barriers may be attitudinal, informational, environmental, organisational or cultural.
The Disability Discrimination Act 2005 has amended the Disability Discrimination Act 1995 so that it now places a duty on all public authorities to:
promote equality of opportunity between disabled persons and other persons; eliminate discrimination that is unlawful under the Act; eliminate harassment of disabled persons that is related to their disabilities; promote positive attitudes towards disabled persons; be pro-active in taking account of disabled person’s disabilities, even where that involves treating disabled persons more favourably than other persons.
The duty places positive responsibilities on us to work towards a more equal society by mainstreaming disability equality into the way in which we carry out our functions.
The duty has two elements, a General Duty (see above) and Specific Duties which are intended to assist public authorities in meeting the general duty.
2. The Specific Duties
The DES is required to include statements on:
How disabled people have been involved in the DES development; How the University intends to impact assess its policies, procedure and practices; How the University proposes to meet its General Duty within a 3-year period; How the University consults with disabled service users on the effect of policies, procedures and practices; How recruitment, development and retention affects disabled people; How the provision of services take account of disabled people;
4 How the University makes use of information to assist in meeting its obligations; How it intends to review the effectiveness of the scheme’s implementation How it intends to publish an annual report to include those steps taken as a result of information gathered.
3. Disability Statement
At the University of Bolton we are committed to the promotion of equality, diversity and a supportive environment for all. For the purposes of this statement disability is understood in the broadest sense including physical and sensory impairments, mental health issues, medical conditions and specific learning difficulties which have an impact on day to day activities.
We aim to:
Anticipate the needs of disabled staff and students.
Recognise the particular contribution to achievement of the University's mission made by individuals with a wide range of backgrounds and experiences.
Foster independent learning through comprehensive student support whilst creating an environment in which students feel they can declare their support requirements.
Maximise our capacity to create career opportunities for disabled people in which they are in no way disadvantaged in comparison with their peers and colleagues.
By ensuring that:
Applications for admission from potential students are assessed on the basis of the applicant’s aptitudes, abilities and qualifications.
Disabled candidates who meet the essential criteria for job vacancies are automatically invited for interview and considered on their abilities.
Students and staff have access to the appropriate support and adaptations to enable them to be fully included in the life of the University.
The views of the disabled student and staff are taken into account at all times when their requirements are being assessed or discussed.
With the individual’s consent, staff have the relevant information to offer their full support.
5 We provide staff working with disabled students and staff with the necessary support and development opportunities.
We support students and staff who become disabled during their time at the University to continue in their chosen course of study or stay in employment.
We consult widely and regularly with student and staff representatives in addition to external organisations and use this information to further improve and develop our support services.
We train all staff in order to improve their understanding of the impact of disability on students, colleagues and members of the public and how they can act to minimise it.
We work to improve the accessibility of our physical environment.
4. Social Model of Disability
The University of Bolton will use the ‘social’ model of disability. In the past much of our understanding of disability used a ‘medical’ model. Issues and solutions tended to focus around the idea of curing the individual or making them ‘better’.
The social model approaches disability from the viewpoint that what ‘disables’ the individual is social structures, barriers and attitudes not the person’s impairment or medical condition.
The University will no longer use the traditional approach based on what a disabled person cannot do and instead will focus on what they can do. Following the social model should result in a better environment for all service users and the entire community and better access for disabled and service users generally.
The University of Bolton has developed a Disability Equality Scheme to help us to achieve a number of things:
to carry out equality impact assessments on existing policies, practices and procedures to identify where action needs to be taken to make improvements or changes, and to promote equality of opportunity for disabled people; to make sure that we are taking the needs and views of disabled people into account when, for example, we design and deliver services, make access improvements or develop policies;
6 to continuously monitor and improve the ways in which we deliver services to disabled people; to ensure that there are resources and support available to deliver our Disability Equality Scheme’s core priorities.
5. Involvement of disabled people in developing the scheme.
The University is committed to working in partnership with the disabled community in the development, implementation and ongoing review of its DES. In broad categories our community consists of:
Students and potential students Staff and potential staff Contractors External contacts and stakeholders Visitors and members of the public
To date communication and involvement has focussed on identifying what is working well, what is not working well, where there are barriers to equal opportunities and access, and where there are gaps.
The University’s principal vehicle for consultation on matters relating to Equality of Opportunity, including disability, is the Equal Opportunities Steering Group. This is responsible for ensuring that corporate objectives relating to equal opportunities are set and met. It is responsible to the Executive Board for the creation of policies and for pursuing and monitoring these policies.
The Equal Opportunities Steering Group is currently chaired by the Director of Human Resources and membership of the group includes the trade unions, President of the Students’ Union and the chairs of the promotion/project groups. Only one member of this group has a declared disability, however, the Disability Promotion Group represents the view of those disabled members of staff and students who are either members of Joining Up Disability or Project Enable or who contribute to these groups through the various service user groups.
The structure of the Steering Group is outlined below:
7 Board of Governors
Academic Executive Board Team
Equal Opps Steering Group
Age Chair Race Disability Gender & Student Equality Chair Sexual Experience Chair Orientation Attainment Chair Chair
The Disability Promotion Group reports to the Equal Opportunities Steering Group on progress of its other sub-groups. These sub-groups are demonstrated in the following structure:
8 Disability Promotion Group
Disability Joining up Project Enable Equality Disability Group Group Scheme (Disability Steering Partnership) Group
In addition to the Disability Promotion Group within the Equal Opportunities Steering Group, the University has a well established focus group for students and staff, the Joining Up Disability Group. This meets once per term to contribute and advise on good practice.
The purpose of the group is to foster inclusion for disabled students and staff throughout the University community by:
contributing to the formulation of strategy preparing draft policy documents for discussion or commenting on policy presented acting as a consultative forum for estates issues advising on resource allocation promoting awareness of the needs of disabled students and staff implementing practical ideas for delivering the above
Membership is available to any staff or students who have an interest in this area and wish to contribute ideas to promote good practice.
The University has established a Disability Partnership with - Bolton Council, Royal Bolton NHS Trust, Bolton Primary Care Trust, and Bolton Community College to consult with the local community through the Disability Consultative forum on making Bolton a better place to live and work as part of the University’s Project Enable initiative. The first joint consultation event with the community entitled the Better Bolton Café took place on 21 July 2006. Feedback from this event will be delivered in a
9 report and the first feedback session took place on 20 October 2006 with the local community.
This involvement of the disabled community is engagement with groups of disabled people not organisations for disabled people. Membership embraces the full spectrum of disability such as backcare, osteoporosis, hearing and visual sensory impairments, mental health patient group in addition to members of the public who are disabled. An audit of local groups will be made to ensure that they fully reflect all disabilities. Those organisations that work closely with the University such as Mayflower, Shaw Trust, and Remploy are invited to attend these communal events. Outcomes from this involvement has been included in our action plan.
An outcome of this involvement is the movement to set up an independent organisation of disabled people to form a core group acting as a pressure/lobby group for local services. The group will call themselves the Disability Action Group with leadership by disabled people rather than those agencies named above. It is anticipated that the above named agencies will be extended to include the Greater Manchester Police, Greater Manchester Transport and Bolton at Home/community housing. These agencies will be invited to make a contribution of funds to pay for an administrator who could provide administration for meeting, web pages and payment of transport and support mechanisms to enable the disabled community to contribute to and attend these meetings on a regular basis wherever possible.
The University held its first Celebrating Diversity Week during the week commencing 30 October 2006. This event was for both staff and students to participate in. The Equal Opportunities Steering Group promotion action groups all had displays with promotional and information material and the Disability promotion group contributed to this event. Next year and in subsequent years, this Celebrating Diversity Week will provide an additional vehicle to not only promote but to actively involve disabled people and acknowledge the contribution that they bring to the University’s community.
A wide range of local disabled groups and people will be directly involved in the development of this Disability Equality Scheme.
Students– through student surveys and Joining Up Disability focus group Potential students – through application process surveys Staff – through staff surveys including the bi-annual diversity survey and staff focus groups Potential staff - through application process surveys Contractors – through procurement surveys
10 External contacts and stakeholders – through Project Enable involvement and surveys Visitors and members of the public – through Project Enable involvement and surveys
This involvement will continue and develop into the implementation phase of the scheme. Our implementation process will be:
Consultative, with our students and the Student Union Accessible, making sure that a wide range of disabled people have an opportunity to engage with the University; Clear about where we can make changes and what resources are available to deliver against our actions; Proportionate in our aim to be fair in the context of our available resources; Specific in terms of providing evidence that our priority actions are being delivered; Transparent in terms of the outcomes from our action plans and any changes that need to be made. These will be regularly scrutinised by the University Secretary.
6. Legal Framework
The Disability Discrimination Act 1995 (DDA) defines that a “disabled person” is a “person who has a disability”. A person is treated as having a disability if “he has a physical or mental impairment which has a substantial and long term adverse effect on his ability to carry out normal day to day activities”.
It is unlawful to discriminate against disabled people by:
refusing to provide a service without justification; providing a service to a lesser standard without justification; providing a service on worse terms without justification; failing to make reasonable adjustments to the way services are provided for disabled people; failing to make reasonable adjustments to the physical features of service premises, to overcome physical barriers to access.
The Disability Discrimination Act (DDA) was passed in 1995. This Act consists of 3 parts. The first part of the Act defines disability and who is protected under the Act. The second part of the Act covers employment and the third part covers goods, services and facilities.
Whilst some elements of education were covered in this Act ie services and employment, some key aspects were omitted. As a result in September 2001 the
11 Special Educational Needs and Disability Act was passed and became more commonly known as SENDA.
SENDA more specifically covers students; those studying in post 16 education. This part of the DDA 1995 sets clear deadlines during which time responsible bodies need to ensure they are carrying out their duties under the Act. In September 2002 it became unlawful to discriminate against a disabled student. In practice this means disabled students must not receive “less favourable treatment” due to having a disability and that “responsible bodies” must make “reasonable adjustments” to accommodate specific needs.
In September 2003 the second part of SENDA came into force stating that responsible bodies must make adjustments that involve the provision of auxiliary aids and services. SENDA also placed a duty on universities to be “anticipatory” in their support of disabled students. As well as making reasonable adjustments for students who are already studying, universities need to consider support requirements for prospective students before they begin their studies. The Act also clarifies that it is unlawful to discriminate against a disabled person “in admissions, enrolment or exclusion”.
Reasonable adjustments cover a whole variety of scenarios. A student may benefit from receiving handouts in advance of lectures, or may need a portable loop system in class or extra time in their examinations. Whilst some adjustments can be on an individual basis responsible bodies need to consider holistic approaches that can benefit all students. This could be providing all modular handouts as downloadable documents on the web, through the Intranet or via WebCT. All students then have the choice to access this information at their own convenience. In addition to that students could also download the information in their preferred format; font size, type, colour of printer paper etc. Providing information in this way and improving its accessibility would also address the universities anticipatory duties under the Act.
In addition to considering access to curriculum, teaching facilities and the physical environment, other areas of the University are also covered by the DDA. The Students’ Union must ensure that its services, activities, societies and events are accessible to disabled students. University accommodation, such as halls of residence must undertake reasonable adaptations to suit the needs of disabled users.
The duty to make reasonable adjustments is an anticipatory one. This means that educational providers must think ahead to the type of adjustments that may be required and, where feasible, put these adjustments in place.
This might involve:
12 Ensuring the accessibility of courses is considered during course validation.
Planning accessibility features into buildings at the design stage.
Staff training.
Auditing institutional procedures and processes to ensure that they do not set up unnecessary barriers to disabled people
Ensuring e-learning materials are accessible to student with visual impairments or those who are unable to use a mouse
The Disability Discrimination Act 2005 places additional duties on responsible bodies in relation to the support of, involvement and progression of disabled people in the workplace and disabled students in their studies.
This amendment to the Act extends the definition of “disability” in two ways:
It now covers people with progressive conditions; specifically cancer, HIV and multiple sclerosis. They will be recognised as having a disability from the point of diagnosis.
A mental illness no longer has to be “clinically well recognised”.
This is very significant as this further opens up the definition of disability under the Act and therefore will incorporate many more people than previously.
(Further implications of the DDA 2005 have already been addressed within the Introduction).
7. Responsibility for Implementation of DES
7.1 Collective and Institutional
The Board of Governors is responsible for determining the Educational Character and Mission of the University. This is set out in the University’s Strategic Plan. In referring to the ethos of the University this states:
“We are proud that all the elements of society are fully represented among our staff, students and partner organisations”
and
13 “We embrace diversity and value difference”
It is the responsibility of the Executive Board, to ensure that in its strategy, management and day to day operations the University acts in a manner which is consistent with the ethos set out in its Strategic Plan. The Disability Scheme is one of a number of delivery vehicles in this respect. It is the responsibility, therefore, of the Executive Board to see that the Scheme is implemented, monitored and effectively resourced. Disability is represented in their membership.
It is the responsibility of the Academic Board to ensure that it delivers its accountability for academic quality in a manner which is consistent with the specifics and principles of the Disability Scheme. In particular it should ensure that content, modes of study, learning methods and assessment and examination processes do not present any impediment, barrier and/or disadvantage to disabled students.
The University does not collate equality target information on the composition of all committees, particularly those whose membership are elected. Academic Board falls into this remit. Collection and collation of this information has been addressed in the action plan. The University does collect this information for the University’s Board of Governors members who are required to complete equal opportunities monitoring forms. None of them have declared a disability.
7.2 Individual Responsibilities
The Vice Chancellor, as Chief Executive, is ultimately responsible to the Board for the implementation of all agreed policies of the University, including the Disability Scheme. Sh/e is also responsible for ensuring that adequate resources are made available for the effective pursuit of the schemes objectives
The Pro Vice Chancellor (Academic) has responsibility for implementation of the scheme with respect to the curriculum, academic quality, learning and teaching and student progression through identifying existing and potential barriers and develop strategies to remove them.
The University Secretary has overall responsibility for informing the Board of Governors that the University’s Disability Equality Scheme objectives are being met.
The Director of Human Resources has overall responsibility for the implementation of the scheme as it effects current and prospective staff
14 and contractors through identifying existing and potential barriers and develop strategies to remove them.
The Dean of Students has overall responsibility for the implementation of the scheme as it affects current and prospective students through identifying existing and potential barriers and develop strategies to remove them.
The Director of Estates has special responsibility for the implementation of the Scheme with respect to the accessibility of premises and facilities through identifying existing and potential barriers and develop strategies to remove them.
Directors of Schools and Heads of Department have responsibility for the implementation of the Scheme in their spheres of operation and among the staff and students for whom they are responsible by identifying existing and potential barriers and develop strategies to remove them.
All staff with management responsibility have responsibility for the implementation of the Scheme in their spheres of operation and among the staff and students for whom they are responsible by identifying existing and potential barriers and develop strategies to remove them.
All staff with responsibility for strategy, policy and procedure have responsibility for undertaking the impact assessments process on strategy, policy and procedures to ensure they minimise the impact of disability on students, staff and other members of the community.
All staff have responsibility for adhering to the policy and for minimising the impact of disability on students, colleagues and all those with whom they come into contact in the course of their work.
8. Description of Current Approach
The Student Centre
The Student Centre was formed in 2001, following a review of Central Services (Academic-Related) Administration. It is designed to provide a seamless service for students from initial contact with the University to graduation organised around A “first-stop shop” Student Information Service Student Recruitment and Admissions Team Student and Residential Services Team Student Data Management Team
15 The Disability Service is part of the Student and Residential Services team and its work is outlined in Section 7.1 In addition to its key role in supporting individual students the Disability Service has a wider role in promoting understanding of legislative and accessibility requirements and disseminating good practice. It is through this that all staff can embed these requirements into their work.
Below are two examples of how two services are working with disabled students and ex-students:
The Careers Service All of our handouts are copied on pastel coloured paper. On our help desk we have a copy of “Your guide to a careers guidance appointment and drop in services” in large font alongside the normal font version. This includes a statement “The Careers Service particularly encourages use of its services by students with disabilities, mature students and those from an ethnic minority or socially disadvantaged background.” As careers advisers we are part of The DDN, the Disability Development Network, part of AGCAS( Association of Graduate Careers Advisory Services) We are careers advisers interested in those students with disabilities. It has an email discussion facility and meetings and training topics at least once a year.
From the Volunteering Administrator It is of concern that disabled students leave the University having gained a degree but are not necessarily equipped for employment in the outside world. In meetings earlier in the year with the Disability Adviser, it was decided to alter the form that students filled in so that the Disability Service could pass contact information to me. This would enable me to contact students in order to offer them the opportunity to gain work based skills via the Volunteering Project.
At the end of the Academic Year an audit was made and it was found that 42 out of the 216 students on the volunteer database were registered with our disability service.
The next stage of the plan will be to contact local community groups and organizations that use volunteers in to secure volunteer placements for disabled students, and then to monitor their experience. It is anticipated that students will be provided with the opportunity to enhance their employability prospects.
For the Academic Year 2006/7 one of the Student Centre’s objectives is to take a leading role in the formulation and dissemination of the University’s Disability Equality Scheme. All Student Centre Procedures are to be reviewed to ensure that they are anticipatory and complaint. Once the review has been completed, an action plan will be implemented.
16 The staff of the Student Centre work closely with representatives of the University of Bolton’s Students’ Union to ensure that the Union is fully represented on those fora which discuss disability matters.
The Disability Service offers support, advice and guidance to students who have declared a disability from pre-application to graduation, as well as to academic staff. In addition to this diagnostic screenings are offered in order to make referrals to assess for specific learning difficulties ie Dyslexia.
This support is offered via confidential one to one appointments and Drop In sessions, staff and student inductions and through awareness raising events. The service must be accessible and therefore communication and liaison with its users is available through a variety of mediums; information packs, telephone, email, website, fax, Minicom, SMS text messaging and, when requested, audio format and Braille.
The Disability Service has been extensively developed over the last four years to cater for the needs of its users. There are a number of reasons for this. The profile of the service has been greatly improved throughout the University through Staff Development sessions focusing on supporting disabled students and improving accessibility to all. Practices and procedures have been consistently developed and fine tuned to deal with the ever increasing amount of students who access the service. Publicising the support that is available through the University prospectus, disability information packs & booklets, the website, academic departments, Learning Support and Development and through talks given to external contacts, such as schools and colleges, adds to the increased demand on the service.
During the academic year 2002/03 543 students declared a disability, over 500 one to one confidential appointments were conducted and the service received around 500 phone calls. In comparison by 2003/04 the service had conducted 550 appointments, received approx 1200 phone calls and had over 600 students registered with a disability. These figures have continued to increase and during 2005/06 just under 800 appointments were conducted and over 750 students were registered with the Disability Service.
The Introduction of part IV of the DDA 1995, the Special Educational Needs and Disability Act in 2001, which involved various deadlines for meeting the needs of disabled students, meant that raising awareness of the University’s responsibilities under this Act became a priority. Thus entailed many staff development sessions run by the Disability Adviser.
In November 2004 a Senior Disability Adviser post was created (SO1), and a full time Disability Adviser (Scale 5) and part time (0.5) Clerical Assistant (Scale 2) were appointed. By this stage approx 700 students had disclosed a disability to
17 the University. Since this time to date the Disability Service has continued to develop and improve the services offered to students and staff. There are more one to one appointments available at both campuses with both advisers, a weekly Drop-In Session has been created, and study skills support for students awaiting their study needs assessments are available.
The Disability Service has developed a form to enable students to “Disclose a Disability” with any member of staff within the University. This has involved raising awareness amongst staff as well as students. A Consent Release form is also used with every student who has disclosed a disability. The students have the option of signing to agree to liaison with other people both inside and outside of the University ie tutors, Local Authorities, GPs, Community Psychiatric Nurses, Study Needs Assessors. Student can specify if they agree liaison with some people and not others.
The service now has a range of assistive technology available to loan to students who are not entitled to funded support or are still waiting for it. The Disability Service works alongside Learning Support and Development in ensuring the needs of disabled students are met and also liaises at many levels with academic departments.
A new module has been developed in the central student records system within the Disability Service. This module, “Accessibility Manager”, will eventually be rolled out University wide to aid the dissemination of information throughout relevant academic departments, to improve the learning experience for disabled students.
The Senior Disability Adviser works with HR in ensuring disability awareness raising sessions are provided on a rolling programme for both academic and professional staff at the University. This involves presenting sessions at Academic Briefings throughout the academic year as well as running specific half- day awareness raising events. An impact assessment on this has identified that take up has been limited and will be addressed by offering a diversity stream in the annual Teaching and Learning conference, issuing good practice guides for all staff who teach and through the mandatory diversity training through Theatre-in and the Dignity and Respect training that will include disability awareness.
The Disability Service continues to gather feedback from Disabled students via questionnaires, focus groups and participation in awareness raising events and uses this information to develop and improve service provision.
Since the amendment of the Disability Discrimination Act 1995 to the Disability Discrimination Act 2005, the University has further recognised it responsibilities to not only support disabled staff and students but to be proactive in approach to create an accessible working/learning environment.
18 As 2006/07 academic year commences well over 700 students have declared additional support requirements and this is anticipated to exceed 800 by the end of the academic year.
8.2 Academic Projects
8.2.1 Good Assessment Workbook
In 2005, the University‘s Learner Experience Committee Assessment Task Group published it’s” Good Assessment Guide: A Practical Guide To Assessment for Lecturers”. The Disability section emphasises that there must be no unnecessary barriers for students with a disability, and it also reminds staff about contacting the University Disability and LS and D services.
8.2.2 ABECAS
Built Environment staff have written a guidance booklet “ Removing Barriers and Making Adjustments for Disabled Students in Built Environment Degree Programmes” The booklet is an outcome from Project ABECAS (Accessible built environment careers for all students), funded by HECCE through the National Disability Team (NDT) and the University of Bolton.
8.2.3 DART
Built Environment lecturers at the University have been key partners in a project designed to help disabled students. The Disabilities: Academic Resource Tool (DART), pioneered and led by Loughborough University, has created a web-based tool designed to make the curriculum more accessible to students with a disability. The project gives academics access to a database where they can find the best- practice advice suitable for individual students. The database also holds case studies where students give their views on what suits their needs best. http://dart.lboro.ac.uk
8.2.4 MIDAS
Making Inclusive Design Accessible and Successful is a European Social Fund project through which design experts at Bolton aim to bring together disabled people, design students and businesses to create new products that can be used by the vast majority. For the first time, the whole design process is accessible to disabled people as they play a key part in it.
19 8.3 Learning Support and Development
8.3.1 LS and D works closely with both students and staff in other departments to ensure that services are appropriate for users with specific needs. In particular, its strong relationships with Estates, Student Services, and Communications and Information Technology, are facilitated via the University committee structure, detailed elsewhere, working groups, with student participation, and networking. This ensures that relevant strategic and operational areas are addressed at the right level, by the right people, and that student views are sought.
In 2001/02, LS and D undertook a major review of specific needs’ provision. The recommendations for enhancements to the service took into account the requirements of the Disability Discrimination Act 1995 (DDA), and the Special Needs and Disability Act 2001 (SENDA), the Quality Assurance Agency Code of Practice for Students with Disabilities, and the SCONUL Guidelines on services to students with specific needs. Many improvements have been made as a result of the review.
As part of its work in obtaining a Government Charter Mark for excellent customer service (2002 and 2005), LS and D has been more pro-active in providing and promoting its disability services, thus pre-empting newer legislation. In November 2005, the Charter Mark Assessor wrote “Outstanding features of the application are:
The attention paid to developing systems and facilities to support students with specific needs. The positive role played by staff in this respect is of the highest quality.
A high quality of service information in a variety of formats.
The provision is impressive and is highly valued by students.”
We have in place Equal Opportunities, Specific Needs and Disability policies and procedures.
This Disability Equality Scheme contains further enhancements to LS and D services in its Action Plan section.
8.3.2 Inductions for all specific needs students include :-
Introduction to LS and D’s specific needs facilities, services and documentation
20 Setting up of personal computer profiles where this will enhance use of the PC network Booking personal appointments, by mutual arrangement, for an introduction to software or equipment.
8.3.3 Learning Support Centres – (LSCs)
Both Learning Support Centres have had modifications made which aid those with mobility problems. (The LS and D web pages detail the facilities). Physical access is DDA compliant, and the working environment is equipped with accessible toilet facilities, lifts, reconfigured book shelves, low- level door pushes, wide access doors and ramping, and matt laminate signage, Minicom machines and hearing loop systems are provided at the Information and Issue desks, together with portable hearing loops for use when necessary. www.bolton.ac.uk/learning/generalsupport/snlearners.htm-
8.3.4 Enhanced Services
A service offering a more tailored provision of additional services, matched to the needs of each individual is in operation. All students registered with the University as having specific needs are entitled to a range of additional services.
copies of most in-house leaflets in Braille, large print format, on audiotape or on floppy disk. Flexible loan arrangements. Transport and return of books between sites Facilities for a proxy. Inter library loan requests by post or phone Subject searches of electronic resources and the Internet. Advice on choosing materials from the appropriate subject specialist. Photocopying service.
8.3.5 Special Equipment
There are two fully supported Enabling Technology rooms for users with specific requirements: Laurel in Eagle LSC and Sapphire in Chadwick LSC. These rooms contain multimedia networked computers that can access the internet, email, and electronic services, as well as all the normal networked software.
Specialist hardware and software to assist students with disabilities includes:
screen reader/magnifier software
21 dictation software text help “Read and Write”, to assist with reading and writing difficulties Kurzweil 3000 CCTV viewers Braille translation programme (grade 1 and 2) Braille embosser optical character recognition software tactile image enhancer ergonomic chairs and other furniture
8.3.6 Specialist Software
High level support is, or will be provided, for four packages:-
Read and Write Gold, Supernova, Dragon Naturally Speaking, and Inspiration. In order to foster more inclusivity for students with special needs, more software is being made available over the network. Network-wide access is available to:- Texthelp Read and Write GOLD (for users with Dyslexia) Inspiration 8.0 (for dyslexic users but a powerful visual learning tool for everyone)
8.3.7 Publications
A range of LSS publications is available on audiocassette and in large print and Braille. Publications can be accessed in PDF format via the web pages enabling students with specific needs to access them in the LSC’s Enabling Technology rooms, or remotely. The LS and D web pages meet or exceed the minimum legal requirement of accessibility on all pages. The web pages have been tested on a variety of browsers including Lynx, the Macintosh browser Safari, Internet Explorer (IE) 6, Mozilla Firefox, and Opera. The LS and D Specific Needs group has organised a number of themed displays in the LSC’s on subjects such as blind and deaf awareness, mental health, dyslexia, and aspergers syndrome. These displays promote a wider awareness of specific needs to the wider university community.
8.3.8 Staffing
In October 2005, LS and D designated a computer based Information Officer to be responsible for dedicated specific needs users’ support. The post involves:-
Supporting specific needs students on a one-to-one basis
22 Investigating/sourcing/costing/testing/advising on the purchase of new specialist software and equipment Writing support materials for specialist software and equipment Training other members of staff, particularly core Information Desk Team Writing and maintaining content for the LS and D Specific Needs website.
The post reports to the LS and D Disability Project Group, and the post holder is also a member of the LS and D web pages group.
The majority of the Department’s staff have taken part in the University wide diversity learning programme “Respect for People”. Staff are also beginning to take part in the new “Theatre In” programme for diversity. LSS policies such as the Values Policy, Guidelines for Customer Care, and the Policy on Disability ensure that everyone is treated with respect, fairly and sensitively.
In recent years, disability awareness training has been a staff development priority for the majority in the department in order to help staff to appreciate, understand, and assist users with specific needs. This is provided by external trainers and covers mental, physical, and specialist learning needs.
8.3.9 NoWAL
LS and D is a member of NoWAL- the North West Academic Libraries consortium. The NoWAL Diversity Group is a task and finish group which exists actively to promote equality and diversity in all areas of Library and Information provision for both staff and users. The Group recognises that addressing issues of diversity involves respect for, and sensitivity to, the needs of individuals and seeks therefore to advise and inform rather than to offer prescriptive solutions.
8.4 Staff
8.4.1 Diversity Survey
In order to evaluate the perceptions of staff with respect to the current equality policies and practices within the University of Bolton, a Diversity Survey of all employees working for the University was undertaken in May 2006. The anticipated outcome of the research was that it would identify the areas where the University of Bolton is performing well in its anti-discriminatory practice and areas of policy and practice where it could do better.
23 The results of the Diversity Survey and a follow-up focus group indicate the University is performing relatively well compared to the sector in its current practices. However, there are areas which need strengthening:-
Bullying and harassment, where there was under reporting and low confidence in the University’s ability to deal with these instances. Flexible working arrangements which need extending to those with caring responsibilities for elderly or disabled dependents, and to those reaching their preferred retirement date. Flexible retirement arrangements, where the University is encouraged to take a pragmatic approach to encouraging workers to work longer based upon its strategic needs. Recruitment and selection, where the likelihood of age, disability and gender discrimination needs to be reduced by amending guidance notes and introducing a system for monitoring the profile job applicants by age, disability and gender at all stages of the recruitment process. Disclosure rate for staff with disabilities, which needs to be improved by identifying the reasons why staff are reluctant to disclose disability status through further focus groups.
8.4.2 Diversity Workbook
The Diversity Workbook was introduced in 2003 to all staff. All staff were issued with a pin number to identify if they had completed the training. Training consisted of a telephone test that required the individual to answer 9 out of 12 questions correct in order to pass their diversity training.
All new staff received the workbook as part of their induction and issued with a pin number. Although the Diversity Workbook was regarded as groundbreaking upon its release, the outcomes from the use of the telephone test was that it was a test of memory rather than changing attitudes and behaviours.
The workbook was delivered in alternative format, for example, the cleaning staff had a paper test rather than use the telephone test.
8.4.3 Diversity Training
In 2006, the HR Community Officer and Training Officer, developed a new diversity workbook that rather than focus on employment legislation, informs new staff of the staff and student profiles within the University, focuses on the Equal Opportunities Steering Group Promotion Action Groups and other University groups work with the community including initiatives and projects that the University is leading and working in partnership with the local borough and other external agencies.
24 Changing attitudes and behaviours is essential to making diversity training successful and in 2006 the diversity workbook telephone test approach was replaced by a new version for staff with an on-line quiz. In addition an experiential approach to Diversity Training, delivered by a theatre company has been implemented. This training is delivered by Theatre-in, an innovative training, development and creative presentation company who incorporate drama-based training techniques to deliver a series of workshops identifying different equality strands, including disability, to focus on driving behavioural and attitudinal changes .
This training was delivered to the University’s senior management team who agreed that this be mandatory and rolled out to all staff. The university are committed to this staff development programme which was launched during June 2006 and continues to be rolled out.
8.4.4 Dignity and Respect at Work and in Learning and Study
In 2006, the University re-launched its Dignity and Respect at Work and in Learning and Study Policy and Procedure. The Dignity and Respect at work policy has been approved by ACAS and incorporates mediation through out its processes. It aims to ensure that no University of Bolton employee, student or visitor is subject to harassment or bullying of any nature in the teaching, learning, or working environments. The Dignity and Respect at Work and in Learning and Study Policy and Procedures seek to encourage staff, students and visitors to come forward with their concerns that will be dealt with in complete confidence, impartiality and with sensitivity. The University of Bolton has Dignity and Respect Advisers to provide a networked support system for members of the University's community who believe that they are experiencing harassment. Our Advisers are recruited from members of the Student Union staff, the University of Bolton’s staff and students. All our Advisers are trained in dealing with harassment and bullying issues.
The policy on Dignity and Respect at Work and in Learning and Study is applicable to both staff and students; however, there are separate procedures for dealing with staff (Dignity and Respect at Work) and student (Dignity and Respect in Learning and Study) complaints. Both involve an informal and formal procedure.
8.4.5 Human Resources Strategy and Annual Departmental Plans
These set out how the organisation will maximise the contribution of its staff in delivering services and achieving their annual planning priorities. As a two ticks symbol holder we will review our progress in meeting the national minimum standards for the recruitment, retention and promotion of disabled people on an annual basis.
25 The University seeks to anticipate the needs of disabled staff and remove barriers to every aspect of their employment covering recruitment, personal and professional development, promotion, and other terms and conditions to enable them to make a positive contribution in the workplace.
The aims are:
Encourage a culture where disabled staff can declare their disabilities in a supportive environment.
Recognise the particular contribution to achievement of the University's mission made by individuals with a wide range of backgrounds and experiences.
Provide a framework that ensures a consistent and equitable approach to make reasonable adjustments for the University of Bolton staff community.
Support staff in the University by encouraging a culture where managers take an active interest in the health and well-being of their staff through regular communication and anticipate the needs of disabled staff wherever possible.
Provide access to appropriate advice and assistance to optimise staff physical and psychological wellbeing in the workplace.
Actively promote disability awareness that fosters positive attitudes by providing diversity training programmes and events.
Make sure that disabled people who meet the essential minimum requirements for jobs are interviewed.
Make reasonable adjustments to the working environment to allow disabled applicants to be appointed.
8.5 Estates
Access to Buildings
The University has already made many adjustments and improvements to the physical features of its buildings. Access plans assist in prioritising necessary works for improving accessibility to campuses.
An access audit was conducted in 2001 and many buildings issues will be improved as part of an on-going estates general maintenance and future improvement plan.
26 As a University, we are aware that the estate’s needs to take into account those with visual impairments and mental health disabilities.
The University of Bolton has 3 flats in each of the two halls of residence that have ensuite facilities and other adaptations ie a seat and supportive hand rails in the shower. In standard halls accommodation adjustments can also be made such as providing a private fridge to store medication or flashing fire alarms, vibrating pads and pagers for deaf students. In some instances students who have a lot of equipment as a result of their disability may be allocated two rooms together for the price of one to accommodate their needs. An example of this is a student with a visual impairment who has a large computer monitor, CCTV and other specialist equipment as well as their standard possessions therefore requiring additional space.
8.6 Finance, Procurement and Purchasing
The University of Bolton will ensure that procurement policies and practices take account of our legal duties to promote equality and in this instance to make sure we are meeting the disability equality duty. We will do this by undertaking the following:
placing an expectation on our appointed contractors to share and deliver our equalities and diversity goals; make sure that disability equality along with other areas of diversity is taken into account when procuring goods, works or services from external providers; monitoring our contracts for compliance including appropriate terms and conditions.
9. Current Good Practice – External Validation
The University achieved the “Two Ticks” Job Centre Plus award in March 2006.
The University has been an Investor in People since 2001 and achieved successful re-assessment in 2004, under the new criteria which include assessment of its approach to Equal Opportunities.
In 2003, the University produced the ground breaking diversity workbook “Respect for People”. This was issued to all staff and involved a telephone test which staff were able to take to confirm their understanding of the content.
27 In February 2004 the staff of the Student Centre were awarded the matrix Standard, a quality award for the high quality of their Information, Advice and Guidance services. The high standard of disability awareness was remarked upon in the matrix Assessment Report . The students who had been interviewed commented on’ exceptional responsiveness and flexibility’
Staff of the Learning Support and Development achieved the Charter Mark award for Excellence in Customer Service in 2002. The department were successfully re-assessed in December 2005, with one of the highest scores achieved nationally.
The University holds an annual weekly event on “Celebrating Diversity” to experience a week of the University’s diverse culture with activities and events that bring alive the many facets and characteristics of our staff and student community. The event is an opportunity for the Equal Opportunities Steering Group’s Promotion Groups to publicise their focus group objectives and engage with staff and students. It will also be used to promote the University’s Diversity Information Portal, as well as add impetus to diversity training including the Dignity and Respect at Work and in Learning and Study Policy.
10. Data Collection
10.1 Benchmark data for disabled staff
It is our aim to prepare and analyse monitoring information of employee’s profiles, to publish data and to set appropriate targets for increased representation of disabled people. The percentage of our staff who have declared a disability is 2.3%. This type of data is not collected for the University’s a-typical staff including part time hourly paid lecturers and temporary supply staff. This omission is addressed in our action plan.
The diversity survey sent to all staff including a-typical staff (achieved a 27% response rate) has indicated that 3.6% of the staff considered that they had a disability under the DDA. In contrast 14.5% declared that they had a health problem, medical condition or impairment which indicates that employees are either not recognising that they have a disability under DDA or are unwilling to disclose it. The data indicates that the university has significant proportion of staff with a wide range of disabilities but with small numbers in each category.
The University have invested in a new computerised personnel record system that will enable the University to benchmark their data against national statistics.
28 Recruitment – see action plan Promotion – see action plan Disciplinary and Grievance Procedures – see action plan Integration in the workforce – see action plan Access to staff development Exit Interviews – see action plan
10.2 Benchmark data for disabled students
Gap analysis:
Recruitment The national percentage for disabled students in Higher Education is 5%. At the University of Bolton the figure for 2005/6 was 12%.
The number of students declaring a disability continues to rise
Year No. of Disabled Students 2002/3 543 2003/4 653 2004/5 695 2005/6 737 2006/7 to date 800
Retention – See Action Plan Progression – See Action Plan Disciplinary and Complaints Procedure – See Action Plan Employability Attainment
11. Impact Assessment Impact assessments are an essential tool for achieving disability equality within our organisation. As part of their Disability Equality Scheme all public authorities must include a statement of their methods for assessing the impact and potential impact of their policies on equality for disabled persons.
The purpose of impact assessment is both to ensure that all University decisions and activities do not disadvantage disabled people, and also to identify where they might better promote equality of opportunity, including consideration of
29 where the different parts of the disability equality duty (such as promoting positive attitudes) might be built into those policies and practices.
It is our intention to improve the current impact assessment process through the involvement of disabled people and to make sure we publish the results of all our assessments. Impact Assessments on policies and procedures will be completed by February 2007.
12. Monitoring, Evaluation and Review We will involve our disabled community in the evaluation of our scheme and action plans and make sure that the scheme is evaluated. This will include: Students and potential students Staff and potential staff Contractors External contacts and stakeholders Visitors and members of the public
This process will include making any changes to the scheme so that continuous performance improvements and overall effectiveness demonstrate our commitment to the disability equality duty.
The Disability Equality Scheme will be reviewed on an annual basis reviewed by the University Secretary with a report to the Board of Governors.
The Disability Equality Scheme Action Plan will be reviewed quarterly and accompanied by published progress reports through the Equal Opportunities Steering Group route.
As a two ticks symbol holder employer, we are committed to review the five commitments and what has been achieved, plan ways to improve on them and let employees and Job Centre Plus know about progress and future plans. This is conducted on an annual basis, every March.
As the University’s Library service has the Charter Mark standard there is a commitment to regular health checks with a review in December 2006 and every two years after.
The University’s Student Centre has matrix Standard this will be re-assessed in February 2008.
The University will be re-assessed for Investors in People in July 2007.
13. Publication of outcomes
30 Publication of the Disability Equality Scheme outcomes will be published on the Diversity Information Portal (located under the Corporate heading of the University Web Page) with links from both staff and student pages with available access to the broader community and partner organisations. Regular progress reports will be published in line with Equal Opportunities Steering Group review timetables.
They will also be published in paper and alternative formats on request to be made available to each university department, partner organisations and to the general public. Those partner organisations and broader community involved in the Project Enable will be circulated this information as part of that remit and it is envisaged that the partner organisations will set up a web site for this specific purpose.
31 14. Action Plan
Objective Action Target Date Lead Outcome Impact Assessment Develop a comprehensive equality Purchase or develop an Feb 2007 University Compliance with DDA and impact assessment process with costing equality impact Secretary maintained into business assessment tool planning process
Identify policies, procedures and Each department to assess Feb 2007 University Produce list and timetable practices to impact assess policies, procedures and Secretary for impact assessment practices for any schedule adverse impact – checked by EOSG promotion groups?
New policies and procedures to Set up new process for all Feb 2007 University Feed into impact assessment undergo the impact assessment process new policies and Secretary list and timetable schedule for procedures to be impact three year cycle assessed Publish the outcomes of impact Set up process for Feb 2007 University Results of impact assessments publication of outcomes Secretary assessments open to from impact assessment – public scrutiny Diversity information portal Access to Buildings Continue to carry out works to improve Programme of work to be ongoing Director of Continuous improvement or remove barriers to access in University agreed by the Estates Estates buildings Strategy group Disabled people to view accessibility to User surveys ongoing Director of Disabled users to identify University buildings before completion Estates access and service options Identify common problems with Involvement of staff ongoing Director of Produce information and accessibility in or to University (diversity survey), service Estates good practice guidance
32 buildings users or visitor surveys Service Delivery Conduct a survey of broader community A joint consultation event with 4 meetings HR Community Written report on outcomes (Project ENABLE) the community - Better Bolton per annum Officer with follow up action plan Café joint event - 21 July to be 2006 and follow up 20 scheduled DDA compliance and October 2006. evidence of good practice Written report on outcomes
Consultation and involvement of service Disability DDA compliance and provision will include disabled people Promotion Group evidence of good practice Review Mitigating Circumstances Policy June 2007 Head of Quality Assurance & Enhancement Undertake research to establish Publish outcomes 2006/7 Head of Learning DDA compliance and reasons for non-usage of LSS services. Support Services evidence of good practice
Develop a fully enhanced operational 2006/7 Head of Learning specific needs Induction system. Support Services
Ongoing enhancements to equipment, ongoing Head of Learning software and other LS and D services Support Services resulting from user feedback and staff development activities.
Investigate/implement delivery of 2006/7 Head of Learning training for specific needs students in Support Services the use of assistive technology.
33 Review and set new standards for As specified 2006/7 Head of Learning specific needs support. Support Services
Broadening the learning experience Obtain volunteering 2006/7, Head of Student Monitor the experience of through support for student volunteering placements for disabled 2007/8 and Services disabled students students 2008/9
Supporting success and progression Establish a project to Audit – 2006 Head of Student Implementation of for students with diverse needs research how the curriculum /7 Services enhancements in response including disability relates to disabled students Action Plan – to the findings in 2007/8 and and access to the curriculum 2007/8 2008/9 with review in 2008/9
Employment Benchmarking data Data collection to include July 2007 HR Systems a-typical staff Officer Diversity survey Report on first diversity Survey - Head of Evidence of organisational survey every two Personnel and awareness and self confidence Report outcomes: years – May Organisational Publicise on diversity 2008 Development information portal and Celebrating Diversity Event
Introduce job redesign as part of Staff training on June 2007 HR Community Evidence of organisational recruitment, selection and retention of risk assessments for Officer and awareness and self confidence disabled staff Training Officer staff Dignity and Respect Training Recruitment and Selection Personnel Officer Training and Training Officer
34 Produce a policy on reasonable Set up process for reasonable December HR Community Evidence of organisational adjustment adjustment 2006 Officer awareness and self confidence Training programme for managers
Conduct a review for reasons why Promotion of policies on: Aug 2007 Head of Evidence of organisational employees do not to declare a disability Reasonable adjustment Personnel and awareness and self confidence Dignity and Respect Organisational Disability information at Development induction Diversity Survey to focus groups Benchmarking data Extend to Planning and Cover Information Governors, Adviser Part time Lecturers & Supply staff Launch Occupational Health Strategy Promotion of policies on web Dec 2007 HR Community Evidence of organisational that also covers Disability pages. Officer and awareness and self confidence Training Officer Management development on Feb 2007 reasonable adjustment, sicknessonwards absence and health initiatives.
Review the “Two Ticks” symbol actions Annual review process Annually - HR Community DDA compliance and Promote this award through March Officer evidence of good practice Diversity Workbook and Information portal
35 Increase staff knowledge of DES Staff Development programme: June 2006 Head of Increase in knowledge and Diversity Training Personnel and skill Organisational Theatre-in – compulsory Development Diversity workbook – new Jan 2007 starters Reasonable adjustments Dignity and Respect Training Feb 2007 Recruitment and Selection onwards Training Health and wellbeing £1 million challenge initiative to getMay 2007 – the workforce active to include May 2009 Head of Student engaging all equality groups Services, HR including disabled staff to offer Community activities based on their needs Officer and Sports Centre Manager
Develop mental well-being policy for staff and students 2007
Perception of broader community of the Investigate how the University 2007 Disability DDA compliance and Partnership evidence of good practice University of Bolton as an employer is perceived by joint (Project Enable) questionnaire with Disability Partnership employers at the disability forum events (4 per annum) Procurement
36 Develop relevant disability considerations Review current 2007 Procurement into the current procurement process procurement process and Manager amend as appropriate Involvement and engagement All staff use agreed standards for Diversity training – Theatre-In Head of Staff aware communication for disabled people Diversity Workbook – new Personnel and DDA compliance and starters Organisational evidence of good practice Diversity Information portal Development Communication Promotion of Good Practice Diversity information portal Dec 2006 Head of DDA compliance and Diversity Workbook onwards Personnel and evidence of good practice Organisational Student Handbook Development and Dignity and Respect Training Head of Student Annual Celebrating Diversity Services Event
Produce a Policy on Alternative Formats forProcess to be set up 2007 Senior Disability DDA compliance and University publications Link into Diversity Information Adviser and evidence of good practice Portal Joining up disability group Complete an overhaul of LS and D Create micro-site with 2006/07 Head of Learning Link into Diversity Information Specific Needs website individual pages: 2007/08 Support Services Portal Dedicated to different disability DDA compliance and conditions evidence of good practice Supporting specific needs students via the web Raising awareness of various disabilities to the University
37 population as a whole Train all core Information Desk staff to Training programme. ongoing Head of Learning support specific needs students. Support Services Insert into PDP and departmental plan Jan 2007 DART and ABECAS projects Diversity Workbook – new Dec 2006 HR Community & DDA compliance and awareness raising starters Training Officer evidence of good practice Diversity Information portal and Celebrating Diversity Week Celebrating Diversity Event Annual one week event to October HR Community Annual one week event plus promote awareness of 2006 and Officer one day event every month disability, disability projects, annually during term time focussed on disability focus groups thereafter different topics – dance, costume, sport, etc Diversity awareness Establish programmes of June 2006 Head of diversity awareness updating Educational for all staff (Teaching and Development Learning Strategy) Unit Supporting continuing professional Annual teaching and learning 2006/7, Head of One conference per year for development activity conferences 2007/8 and Educational 2006/7 to 2008/09 2008/9 Development Each conference at least 20 Unit presentations with at least 2 relating to the promotion of race, disability and gender Promote good practice in learning and Three symposia per annum 2006/7, Head of 6 presentations with at least 1 teaching 2007/8 and Educational to incorporate the promotion 2008/9 Development of race, disability and gender Unit Supporting progression – enhancement Establish a project with 2007/08 Head of to curriculum action plan to enhance Educational access Development
38 Unit Working with the Student Union to 2007/8 Head of Student Increase the number of students involve them with Disability Equality Services, who attend Joining up Disability Scheme Student Union President and Student Union General Manager Numerical Targets for benchmarking on 2006/7 Planning and students and staff data collection Information Adviser
39 Appendix 1 An impact assessment is a thorough and systematic analysis of policy, whether that policy is written or unwritten, formal or informal to determine whether it has a differential impact on a particular group.
The terminology of “policy” in this context covers the following: policies and procedures systems and processes all functions and services customs and practices
This process should be regarded in the same way as any good management practice and resources for impact assessment directed to the policies, functions and practices which have the greatest relevance and impact on equality and diversity. The long term objective is to embed this practice into all University policy writing procedure. All staff with responsibility for strategy, policy and procedure have responsibility for undertaking the impact assessments process to ensure they minimise the impact of disability on students, staff and other members of the community.
The impact assessment process follows a simple template and in order to be effective, an impact assessment should be made at the beginning of its policy cycle and then throughout its development.
Impact assessments are not a one-off exercise but should be incorporated in to a three-year cycle for review. All existing policies and practices of the University are mapped out, prioritised for action, and responsibilities have been established to ensure a thorough and systematic coverage of all University functions. Results of assessments will be monitored and made available for internal and external stakeholders.
The Higher Education Funding Council for England (HEFCE) produced a flow chart in their guidance that identifies a mapping exercise showing the stages of the impact assessment process. This flow chart is included in this document to reflect how the University will conduct impact assessments.
Improving disability equality performance is what disability equality impact assessment is all about. Conducting disability equality impact assessments should lead to action to improve performance in relation to disabled people. If nothing changes as a result of the disability equality impact assessments carried out by the University across its range of functions, then it is unlikely that these will have been adequately conducted, or that the University is genuinely meeting its disability equality duty. The outcomes of impact assessments already made on our processes by consultation with our students and staff through questionnaires, surveys and focus groups as well as involvement with the broader community
40 have been used to produce our action plan. Work on this will be ongoing to identify those priorities for action.
In determining our arrangements for impact assessment, we have agreed criteria for determining the extent to which disabled people should be involved in impact assessment. Do we advocate full involvement of disabled people?
A judgement of adverse impact is made if the impact of a policy disadvantages on disabled staff, students or other stakeholder. Steps then have to be taken to mitigate this adverse or negative impact.
The concepts of proportionality and relevance are essential for carrying out an impact assessment. The University are expected to have ‘due regard’ to the six parts of the general duty. ‘Due regard’ comprises two linked elements, known as proportionality and relevance. In all their decisions and functions, the University will give due weight to the need to promote disability equality in proportion to its relevance.
Disability equality will be more relevant to some functions than others. The University will take care when assessing relevance to those functions that are likely to be of relevance to disabled people.
Proportionality requires greater consideration to be given to disability equality in relation to functions or policies that have the most effect on disabled people. Where changing a function or proposed policy leads to significant benefits to disabled people, the need for such a change will carry added weight when balanced against other considerations. Where it not possible for the University to adopt the course of action that will best promote disability equality, the University will ensure that they show due regard to the requirement to promote disability equality alongside other competing requirements.
The general duty requires the University not only to have due regard to disability equality when making decisions about the future but also to take action to tackle the consequences of decisions in the past which failed to give due regard to disability equality. This will require some adaptation to existing or proposed activities and the impact assessment process will ensure this.
Ensuring that services give due regard to disability equality may require the University to consider, in relation to any services delivered specifically to disabled people, whether the way in which they are delivered maximises disabled people’s ability to exercise real choice, and promotes their equality more generally. Because the general duty requires the University to give due regard to disability equality in every aspect of their activities it may, depending on the nature and remit, require the University to consider what action it can take to dismantle attitudinal and environmental barriers within its sphere of influence. The impact assessment process will take this into consideration.
41 Appendix 1 - The stages of an impact assessment
Key Consultation No. 1. Identify aims Review in of policy. Is it End of future equality process Decision relevant?
Action
Yes.
2. Analyse available data. Collect further data if necessary.
3. Assess impact of No adverse impact. Publish policy End of process results and review in future Adverse impact shown
4. Mitigate adverse impact. Consider other ways of achieving same aims
5. Consult on final policy
7. Monitor for 6. Publish impact adverse impact in the assessment and future and publish 42 findings results 43