Welsh Language Commissioner Standards Investigation: Questionnaire

Q Existing practice, or easily achievable with little or no resource 30% of the implications. (54) standards Q Existing practice but currently inconsistent, or potentially achievable but 12% of the with some resource implications (possibly even requiring partnership or standards cross-boundary working) (22) Q Difficult to achieve / significant resource implications / not considered 58% of the reasonable or proportionate. (101) standards

Section 1 – General

1.1. Full name of the organization:

Cardiff and Vale University Health Board

1.2. Type of organization:

National Health Service – Health Care Provider

1.3. Which geographical area is served by the organization?

Cardiff and Vale of Glamorgan primary, but extended to across South Wales for specialist care

1.4. Provide a description of the organization's main duties.

Cardiff and Vale University Health Board provides health services for nearly 500,000 people living in Cardiff and Vale of Glamorgan with approximately 15,000 staff. We serve a wider population of 2.4 million people across South and Mid Wales for specialities such as paediatric intensive services, specialist children’s services, renal services, cardiac services, neurology, bone marrow transplantation and medical genetics. The organisation manages nine hospitals and 17 health centres and also provide services in health centres run by NHS partner organisation.

1.5. What is the location of the organization's headquarters and main regional offices?

The organisation main building is the University Hospital Wales.

1.6. Does the organization have other administrative offices? Yes [ ] No [ x ]

1.7. If 'yes', where are the organization's other administrative offices located?

1.8. Apart from the administrative offices previously noted, list all other public buildings within the organization's boundaries and responsibilities which are open to the public or a section of the public.

The organisation manages nine hospitals and 17 health centres and also provide services in health centres run by NHS partner organisation. University Hospital Noah’s Ark Children’s Rookwood Hospital Llandough Hospital of Wales Barry Hospital St David’s Hospital* Whitchurch Hospital University Dental Hospital Lansdowne Hospital Cardiff Royal Infirmary Barry Street Clinic Llanrumney Clinic Butetown Health Centre Llantwit Major Clinic Colcot Clinic Park View Health Centre Cowbridge Health Centre Penarth Health Centre Dinas Powys Health Centre Pentwyn Health Centre* Gabalfa Clinic Rhiwbina Health Centre Grangetown Health Centre* Riverside Health Clinic* Llanedeyrn Health Centre Roath Clinic* Llanishen Clinic Rumney Health Centre • * These areas have a high cluster of Welsh language speakers (Please view annex 1 to see population maps)

1.9. How many employees work for the organization?

Approximately 15,000

1.10. How many of those employees have Welsh language skills? (note fluency levels if known)

Section Staff with Welsh skills grade 2 and 3 Clinical Diagnostic 327 Dental 68 Medicine 192 Mental Health 148 Primary, Community and 107 Intermediate Care Specialist 213 Surgical 253 Corporate 160 This constitutes percentage around 10% of total staff employed by the organisation.

1.11. Please provide information and/or evidence regarding the institutional arrangements the organization has in place to support and lead the work of planning Welsh language services and to comply with the current Welsh language scheme's requirements (if relevant).

The organisation has been developing the Welsh language health care. The monitoring and compliance towards the Welsh Language Scheme is done by the Equality, Diversity and Human Rights Sub Committee. The Sub Committee reports to the Board’s People, Performance and Delivery Committee.

All Clinical Boards, who provide all health services on behalf of the Board, have responsibility for integrating the Welsh Language Scheme into their day to day services. They report to the Equality, Diversity and Human Rights Sub Committee on how they’ve developed Welsh language services by reporting against the Key Performance Indicator as set by the Sub Committee.

1.12. Please provide information and/or evidence regarding any facility the organisation has to support the use of the Welsh language.

The organisation has a full time Welsh Language Officer and Equality Manager. They provide professional support for staff across the organisation around the Welsh Language. They work in Workforce and Organisational Development team.

Within each clinical board, the Heads of Workforce and Organisational Development have been tasked to mainstream the Welsh Language into the services they provide. The Clinical Boards report to the Equality, Diversity and Human Rights Sub- Committee. Furthermore, the Welsh Language Steering Group and the Equality Champions Group have responsibility towards ensuring that services areas improve their Welsh Language services. This has assisted the organisation to disseminate and awareness of responsibility of the Welsh language across the areas and frontline services. The Health Board has also responsibility towards teaching nursing and medical staff. It regularly links in with the local population through schools to talk about the importance of the Welsh Language within Healthcare. This will aid the organisation in the long term to utilise those student with welsh skills who want a career in healthcare.

Section 2 – Service delivery standards [1-85]

2.1. Activity 1: Correspondence sent by a body 2.1.1. Does the organization carry out the activity in question? Yes [x ] No [ ]

2.1.2. Does the organization carry out the activity in question in Welsh? Yes [ x ] No [ ]

2.2 Standards specified in the draft regulations for correspondence sent by a body [1-7] 2.2.1. If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standard Evidence/Comment Risk Rating 1 We already welcome correspondence in Welsh (2.1.1 – Welsh Language Q Scheme) and reply in Welsh when possible 2 We have already committed to do this on point 2.1.3 of the Welsh Language Scheme. There is a concern however Q that front line resources would have to be reallocated to achieve this standard. 3. We have already committed to do this on point 2.1.3 of the Welsh Language Scheme. There is a concern however Q that front line resources would have to be reallocated to achieve this standard. 4 We are committed to send out bilingual standard letters under 3.3.1 of the Welsh Language Scheme. There is a concern Q however that front line resources would have to be reallocated to achieve this standard. 5. While we are committed to send out standard letters in Welsh if we do not know the preferred language this is Q currently presenting a challenge. 6. The organisation is already carrying out this standard under the current Welsh Q Language Scheme under point 3.3.2 7. The organisation can insert this statement on all organisational stationery Q and publicity material, but space and impact of the design may be an issue.

2.2.2. Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [ ] No [ x ]

2.2.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

We have to some degree been able to comply with these standards under the current Welsh Language Scheme, but we face resource challenges to comply with many of them. The breadth of Standards being proposed indicate that we would have to reallocate funds from the frontline services to ensure compliance.

On a long term basis however, with appropriate resources, we believe many of the standards may be achievable.

2.3. Activity 2: Telephone calls made and received by a body 2.3.1. Does the organization carry out the activity in question? Yes [ x ] No [ ]

2.3.2. Does the organization carry out the activity in question in Welsh? Yes [ x ] No [ ]

2.4 Standards specified in the draft regulations for telephone calls made and received by a body [8-22] 2.4.1. If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standard Comment/feedback Risk Rating 8 The organisation is committed to this on point 2.2.1 of the current Welsh Language Scheme. Q 9 This will be challenging to achieve as we do not currently offer these services in Welsh Q 10. While the organisation is committed to this standard under point 2.2.4, there isn’t sufficient Q staff skills to meet this standard. During course of the Welsh Language Scheme and despite our commitment to the point in the scheme. Our direct experience has been that this is currently unachieveable. 11. The organisation is committed to this standard under 2.2.4 of the Welsh Language Scheme. Q 12. The organisation is committed to this standard Q under point 3.3.2 of the Welsh Language Scheme 13. There would be significant logistical and staff skills Q to achieve this. 14. The organisation can insert this statement on all QQ organisational stationery and publicity material. However, due to 10% of staff with Welsh language skills the organisation would find the delivery very challenging. 15. The organisation does not have key performance indicators on answering telephone calls 16. The organisation is already committed under the Q point 2.2.7 of the Welsh Language Scheme 17. Due to issues around logistics and staff, this would Q be difficult to achieve 18. Due to 10% of staff with good Welsh language Q skills, the standard would be very challenging to achieve across the whole of the organisation and the varied services it provides including clinical information. 19. Due to 10% of staff with good Welsh language Q skills, the standard would be very challenging to achieve across the whole of the organisation and the varied services it provides including clinical information. 20. The organisation is committed to this standard Q under point 2.2.4 Welsh Language Scheme. But Due to 10% of staff with good Welsh language skills, the standard would be very challenging to achieve across the whole of the organisation and the varied services it provides including clinical information. 21. This standard would be logistically challenging to Q the organisation. We do not keep a specific record

8 of telephone preference. Also due to 10% of staff with Welsh language skills, we cannot guarantee future calls in Welsh from staff in other services.

2.4.2. Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [ ] No [ x ]

2.4.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

The organisation would find some of these standards unreasonable and would face some huge challenges in trying to achieve them. The main telephone switchboard of the organisation process and route a large volume of calls consistently throughout the day. They do greet the call bilingually, and can a basic bilingual service for the caller. Staff with good Welsh language skills constitutes 10% of the total staff , so providing more sophisticated service would be very challenging. Additionally, due to rapid nature of routing external calls, it would be very difficult to have performance indicators on the amount of Welsh medium calls they receive.

It would be less challenging for the organisation to provide welsh speaking service at the organisation call centres, but there would be some recruitment and logistical challenges to overcome. There is a concern regarding help lines which provide specialist advice, these would need the call handler to have health expertise. This is as necessary as Welsh language skills. The organisation would find it extremely challenging overall to apply these standards. But it would like to point out that there is considerable work done in developing the Welsh Language as part of the automated telephone system.

2.5. Activity 3: A body holding meetings that aren’t open to the general public 2.5.1. Does the organization carry out the activity in question? Yes [ x ] No [ ]

2.5.2. Does the organization carry out the activity in question in Welsh? Yes [ ] No [ x ]

2.6. Standards specified in the draft regulations for a body holding meetings that aren’t open to the general public [23-29] 2.6.1. If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standard Comment/Evidence Risk Rating 23 Not all staff employed by the Health Board are bilingual. Q When a person is invited to a meeting it is essential that the person they are meeting has the appropriate clinical and professional skills. This would always take precedence over holding the meeting in Welsh to ensure that patient safety is not compromised. 24. The standard is unclear in a health setting, due to Q diverse nature of patients meet with staff. There would be a clear resource impact around this issue where Welsh speakers are not available in the immediate area, as the Board would have to regularly contract an simultaneous translator. There would a resource impact.

Standard Comment/Evidence Risk Rating 25. The organisation would be able to ask and provide if Q all staff member were able to speak Welsh. Due to staff skills level, it would be difficult to achieve. 26 Providing simultaneous translation at the meeting Q can be arranged, as well as the follow on meetings. The Boards lacks adequate staff levels to provide which would lead to a resource impact, which would be directed away from frontline services. 27. We have, to a degree, committed to this under 2.3 Q of the Welsh Language Scheme. There would be however cost implications to extend it further. 28. The organisation would be able to ask but with a Q 10% of staff who can provide an effective welsh service, this would be difficult to achieve. 29. The organisation would have great concerns around Q patient confidentiality around this standard.

2.6.2. Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [ ] No [x ]

2.6.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

The organisation has concerns on whether it could comply with these standards. The organisation meets its patients, service users and the public by different means: • Clinical appointment after GP referral (Scheduled Care) • Emergency appointment via Emergency Unit (Unscheduled Care) • Hospital ward based care – regular contact with medical and nursing staff • Community visit – Visits by community health workers into service users house and community hubs (i.e. local schools) Being able to achieve these standards under these types of meetings would be very challenging. Many of our meetings are one to one between medical staff and patient. We have a limited amount of staff member who would be able to provide Welsh- medium care under these kind of staff-patient meetings without the need for a simultaneous translation. We would be able to provide simultaneous translation but this would have resource impact. The organisation would also have concerns around patient confidentiality or patient confidence in the meeting with an interpreter present.

2.7. Activity 4: Meetings arranged by a body that are open to the public. 2.7.1. Does the organization carry out the activity in question? Yes [ x ] No [ ]

2.7.2. Does the organization carry out the activity in question in Welsh? Yes [ x ] No [ ]

2.8 Standards specified in the draft regulations for meetings arranged by a body that are open to the public [30-34] 2.8.1. If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standard Evidence/Feedback Risk Rating 30 -34 The organisation is already committed to this under point Q 2.3.1 of the Welsh language Scheme, but we have experienced some resource and logistical challenges to achieve it on any meaningful level.

2.8.2. Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [ ] No [ x ]

2.8.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

In the past we provided the option of welcoming people to use Welsh in our public meetings. We have encouraged people in the past to contact us in advance for us to make necessary arrangement if they want to communicate in Welsh. There would be cost implications with little public benefit to provide all papers (i.e. committee papers) available through the medium of Welsh. One of the major challenges during the annual general meetings would be to provide all papers bilingual, this would have a major resource impact for a limited audience. The organisation would also have concerns about environment impact on whether to public such large quantity of paper.

2.9. Activity 5: Public events organised or funded in its entirety by a body 2.9.1. Does the organization carry out the activity in question? Yes [ x ] No [ ]

2.9.2. Does the organization carry out the activity in question in Welsh? Yes [ ] No [ x ]

2.10 Standards specified in the draft regulations for public events organised or funded in its entirety by a body [35-36] 2.10.1. If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standard Evidence/Feedback Risk Rating 35 - 36 The organisation finds the standard Q achievable but with cost implications

2.10.2. Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [ ] No [x ]

2.10.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

The organisation runs a wide variety of these kind of events. The organisation may run public events alongside local community groups to promote a new health service, gather feedback or spread awareness. Therefore, communicating with the audience in the most effective is a priority. The organisation would be able to treat Welsh and English on the same level to a degree (i.e. advertising, information material). There would be limitations on how we could liaise with the public due to our limited availability of staff with Welsh language skills.

We would not be able to transfer staff from frontline services, which is the organisational priority. The impact of taking staff away from wards clinical areas for a public engagement could not be justified. The way to achieve the engagement standard would have cost implications as well as inherent human resource implication.

2.11. Activity 6: A body’s publicity and advertising 2.11.1. Does the organization carry out the activity in question? Yes [ x ] No [ ]

2.11.2. Does the organization carry out the activity in question in Welsh? Yes [ x ] No [ ]

2.12. Standards specified in the draft regulations for a body’s publicity and advertising [37] 2.12.1. If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standard specified in the draft regulations, if that standard was to be made specifically applicable to them.

Standard Evidence/Feedback Risk Rating 37 We are committed to the Q achieve this under the Welsh Language Scheme point 3.6

2.12.2. Do you consider that making the standard specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [ x ] No [ ]

2.12.3. If ‘No’, please explain which aspect(s) of the standard appears to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standard specified in the draft regulations specifically applicable to your organization.

2.13. Activity 7: A body displaying material in public 2.13.1. Does the organization carry out the activity in question? Yes [ x ] No [ ]

2.13.2. Does the organization carry out the activity in question in Welsh? Yes [ x ] No [ ]

2.14. Standards specified in the draft regulations for a body displaying material in public [38-39] 2.14.1. If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standards Evidence Feedback Risk Rating 38-39 We are committed to do Q this under the Welsh Language Scheme point 3.6

2.14.2. Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [ x ] No [ ]

2.14.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

2.15. Activity 8: A body producing and publishing documents 2.15.1. Does the organization carry out the activity in question? Yes [x ] No [ ]

2.15.2. Does the organization carry out the activity in question in Welsh? Yes [x ] No [ ]

2.16 Standards specified in the draft regulations for a body producing and publishing documents [40-49] 2.16.1. If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standards Response/Feedback Risk Rating 40 The organisation is complying to a degree under point Q 3.3 of our Welsh Language Scheme 41 The organisation is publishing a bilingual annual Q report. Providing meeting material which are available to the public bilingually would be very challenging 42 Providing bilingual certificates for example in training Q course would be challenging, with resourcing issues be taken away from frontline services. 43. The organisation is complying under the point 3.3.1 of Q the Welsh Language Scheme. 44 – 45 Providing these documents bilingual would be very Q challenging, and would impact on resources. Directing it away from frontline services. 46. Due to the urgency of the press releases and Q statements, providing these documents bilingually would be very challenging for the organisation. This is due to the volume and the rapid response needed for press statements. 47. The organisation is complying with this standard Q under point 3.3.1 of the Welsh Language Scheme. There would be issues around resource impact for larger documents. 48. The organisation is complying to this under point Q 3.3.2 of our Welsh Language Scheme 49. The organisation is complying to this under point Q

2.16.2. Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [ ] No [ x ]

2.16.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

The organisation can and has been producing information leaflets for public, patients and service users bilingually. While progress has been made to ensure that areas provide bilingual material, some difficulty in monitoring and compliance continues due to the size and complexity of the organisation. One issue that the organisation has found challenging is leaflets produced by third sector. These are given to service free of charge by charities who have refused in the past to provide bilingual information due to cost issues. There are concerns on the other hand about providing other material bilingually such as papers from meetings which are available for the public. The organisation would find this requirement very onerous with little impact for a public audience. The Board has 10 committees and three advisory groups which all publish their papers publically. Providing bilingual papers for these would have a major resource impact with little benefit for the public.

The organisation shares the same concern around providing bilingual version of policies. It has a wide range of policies, dealing with from specific clinical issues (Ectoparasitics Infestations/Infections: Fleas, Lice and Mites (Scabies) Policy and Procedure) to a wide ranging issue (Domestic Abuse, Violence against Women and Sexual Violence Policy). To provide all of these in a bilingual format would have a major resource impact but with little benefit due to the limited audience they have. To support these standards and ensure that the organisation can provide bilingual information to the biggest audience with minimal resource impact is by introducing a methodology. This would then assess all documents produced by the organisation and prioritise them.

2.17. Activity 9: A body producing and publishing forms 2.17.1. Does the organization carry out the activity in question? Yes [ x ] No [ ]

2.17.2. Does the organization carry out the activity in question in Welsh? Yes [ ] No [ x ]

2.18. Standards specified in the draft regulations for a body producing and publishing forms [50-51] 2.18.1. If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standards Response/Feedback Risk Rating 50 We are complying to a degree to the standard under Q point 3.4.1 51 This standard would be challenging to meet ,there Q would be an impact on staff resources.

2.18.2. Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [] No [ x ]

2.18.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

While the organisation has been working to develop bilingual forms such eido and consent forms, but developing such forms across a large and complex organisation has been a challenge. Monitoring and compliance in all areas to provide bilingual forms has been difficult. Additionally, many of these forms can be produced by third parties such as contractors or charities. They can only be encourage to provide bilingual forms While the clinical risk of not providing bilingual forms for Welsh speakers is clear. It is recognised a risk for staff to deal with a patient who is completing a Welsh consent form. For example, staff with no Welsh language skills might be expected to fill out the welsh version of a consent form. Due to the clinical and legal risk that this could entail, the organisation would have serious concerns about this standard.

2.19. Activity 10: A body’s websites and online services 2.19.1. Does the organization carry out the activity in question? Yes [ x ] No [ ]

2.19.2. Does the organization carry out the activity in question in Welsh? Yes [ x] No [ ]

2.20. Standards specified in the draft regulations for a body’s websites and online services [52-57] 2.20.1. If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standards Response/Feedback Risk Rating 52 The organisation is required to comply to this standard Q under the current Welsh Language Scheme. Achieving compliance has been challenging 53 The organisation is already complying to this Q achievable standard. 54 The organisation is required to comply to this standard Q under the current Welsh Language Scheme. Achieving compliance has been challenging. 55 The organisation is already complying to this Q achievable standard. 56 The organisation is already complying to this Q achievable standard. 57 The applications that have been developed are for staff Q only. They are of a technical/clinical nature and it would not be appropriate to provide them in Welsh.

2.20.2. Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [x ] No []

2.20.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

2.21. Activity 11: Signs displayed by a body 2.21.1. Does the organization carry out the activity in question? Yes [ x ] No [ ]

2.21.2. Does the organization carry out the activity in question in Welsh? Yes [ x ] No [ ]

2.22. Standards specified in the draft regulations for signs displayed by a body [58- 60] 2.22.1. If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able 19 to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standard Feedback Risk Rating 58 While the organisation is already Q complying with this requirement under the 3.2 of the Welsh Language Scheme, ensuring bilingual temporary signage would be a challenge. 59 While the organisation is already Q complying with this requirement under the 3.2 of the Welsh Language Scheme, ensuring bilingual temporary signage would be a challenge. 60 The organisation is already Q complying with this requirement under the 3.2 of the Welsh Language Scheme.

2.22.2. Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [] No [ x ]

2.22.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

The organisation has mainstreamed the Welsh language into the developing permanent public signage across the organisation, this includes capital projects such as new building. The greatest challenge the organisation faces in complying with these standards would be temporary signage. Temporary public notices are produced by staff on a regular basis across the organisation, on a wide variety of subjects and at urgent times. Due to the limited skill of staff to produce them bilingually, it would be challenging for the organisation to expect staff to provide temporary bilingual signs. Furthermore due to the size and complexity, it would very difficult for the monitoring and compliance of these signs to standard 58-60 to take place.

2.23. Activity 12: A body receiving visitors at its buildings 2.23.1. Does the organization carry out the activity in question? Yes [ x ] No [ ]

2.23.2. Does the organization carry out the activity in question in Welsh?

Yes [ x ] No [ ]

2.24 Standards specified in the draft regulations for a body receiving visitors at its buildings [61-66] 2.24.1. If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standard Feedback Risk rating 61 The organisation is committed under the Welsh Q Language Scheme point 2.4.2. There are challenges with staff skills sufficiency to achieve this. 62. The organisation is committed under the Welsh Q Language Scheme point 2.4.3. There are challenges with staff skills sufficiency to achieve this. 63. There would be significant challenges in Q achieving this, specifically around staff skills. 64. There would be significant challenges in Q achieving this, specifically around staff skills. 65. Providing such signage would be achievable Q 66. The organisation is already providing Iaith Q gwaith badges for staff with Welsh language skills

2.24.2. Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [ ] No [ x ]

2.24.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

These standards would be very difficult to achieve. All hospital sites have numerous reception areas for each clinic area which welcome patients to the clinics. To ensure that all reception areas would be able to provide a Welsh language service would be very challenging indeed considering the limited availability of Welsh speaking staff in these areas. The organisation has in the past run ‘meet and greet’ in Welsh lessons for these staff to improve the situation, but it remains a challenge. Furthermore, we have provided ‘iaith gwaith’ lanyards and badges for staff who are able to speak Welsh.

2.25. Activity 13: Official notices made by a body 2.25.1. Does the organization carry out the activity in question? Yes [ x ] No [ ]

2.25.2. Does the organization carry out the activity in question in Welsh? Yes [ x ] No [ ]

2.26. Standards specified in the draft regulations for official notices made by a body [67-68] 2.26.1. If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standard Feedback Risk Rating 67- 68 The organisation is already complying to this Q standard under 3.2.1

2.26.2. Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [ x ] No [ ]

2.26.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

2.27. Activity 14: A body awarding grants 2.27.1. Does the organization carry out the activity in question? Yes [ ] No [ x ]

2.27.2. Does the organization carry out the activity in question in Welsh? Yes [ ] No [ x ]

2.28. Standards specified in the draft regulations for a body awarding grants [69-73] 2.28.1. If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

2.28.2. Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [ ] No [ x ]

2.28.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

The organisation does not have grant funding system. Our charitable funds system hands out funds generated from the Cardiff and Vale Health Charity to different areas internally. The money is used to improve the patient service, which is expected to comply under these proposed standard regardless.

2.29. Activity 15: A body awarding contracts 2.29.1. Does the organization carry out the activity in question? Yes [ x ] No [ ]

2.29.2. Does the organization carry out the activity in question in Welsh? Yes [ ] No [ x ]

2.30. Standards specified in the draft regulations for a body awarding contracts [74- 78] 2.30.1. If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standard Feedback Risk Rating 74 There will be minimal Q resource impact but the standards is achievable 75 There would be some Q resource impact but it can be achievable 75(a) This would be achievable Q 76 -77 This standard would be Q very difficult to achieve due impact on resource and staff skills 78 There would be some Q organisational challenges and resource impact in order to achieve this.

2.30.2. Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [ ] No [ x]

2.30.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

The organisation would find some aspect of these standards onerous. Although it would have a financial impact, providing bilingual tender information could be achievable. There is concern on how staff would be able to interview possible tenders without the assistance of simultaneous translation, due to the limited Welsh skills in the procurement staff. There would be significant resource impact additionally if the organisation had to provide simultaneous translation during the interviewing process. It should be noted that many of procurement activities have now been transferred centrally under Shared Services, so the organisation no longer is responsible for many tendering and contracting activities. This will include bilingual information such as forms.

2.31. Activity 16: Raising awareness of Welsh language services provided by a body

2.31.1. Does the organization carry out the activity in question? Yes [ x] No [ ]

2.31.2. Does the organization carry out the activity in question in Welsh? Yes [ ] No [ x ]

2.32. Standards specified in the draft regulations for raising awareness of Welsh language services provided by a body [79-80] 2.32.1. If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standard Feedback Risk Rating 79 This standard, beyond cost issues, is Q achievable for the organisation. 80. This standard is achievable for the Q organisation.

2.32.2. Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [ x ] No [ ]

2.32.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

While the standards is achievable, it will be difficult for it to be consistent and achievable. A patient or service user in their patient pathway will be receiving treatment or care by multiple team of different disciplinary as part of their patient experience. The ability in each of these teams to provide a Welsh language service will vary, so the organisation will be unable to provide a complete Welsh service. Furthermore, in some cases patients are receive a part of their healthcare by a third sector organisation. The Health Board would find it difficult to expect these charities and voluntary group to provide a Welsh language service.

Simultaneous translation could be provided, but there would be an resource issue for this.

2.33. Activity 17: A body’s corporate identity 2.33.1. Does the organization carry out the activity in question? Yes [ x ] No [ ]

2.33.2. Does the organization carry out the activity in question in Welsh? Yes [ x ] No [ ]

2.34. Standards specified in the draft regulations for a body’s corporate identity [81] 2.34.1. If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standard specified in the draft regulations, if that standard was to be made specifically applicable to them.

Standard Feedback Risk Rating 81 The organisation is already complying with Q this standard under point 3.1 of the Welsh Language Scheme.

2.34.2. Do you consider that making the standard specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [ x ] No [ ]

2.34.3. If ‘No’, please explain which aspect(s) of the standard appears to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standard specified in the draft regulations specifically applicable to your organization.

2.35. Activity 18: Courses offered by a body 2.35.1. Does the organization carry out the activity in question? Yes [ x ] No []

2.35.2. Does the organization carry out the activity in question in Welsh? Yes [ ] No [x]

2.36. Standards specified in the draft regulations for courses offered by a body [82- 84] 2.36.1. If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standard Feedback Risk Rating 82-83 The organisation would be able to provide Q bilingual information from the course, but limited staff skills in Welsh would limit the amount of course can be taught in Welsh.

2.36.2. Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [ ] No [ x ]

2.36.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

The organisation provides a wide range of courses for patients and service users. These can vary from ante-natal classes, smoking cessation courses and weight management clinics. While the organisation would be able to provide bilingual information (such as course packs, leaflets etc) there would be limitation on providing welsh medium courses. This is due to limited availability of staff who can run the course in Welsh. There would also be a resource impact when developing course material.

2.37. Activity 19: Public address systems used by a body

2.37.1. Does the organization carry out the activity in question? Yes [ x ] No [ ]

2.37.2. Does the organization carry out the activity in question in Welsh? Yes [ ] No [ x ]

2.38. Standards specified in the draft regulations for public address systems used by a body [85] 2.38.1. If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standard specified in the draft regulations, if that standard was to be made specifically applicable to them.

Standard Feedback Risk Rating 85 Depending on the nature of the public announcement, there would be challenges. Q For an automatic repetitive announcement, in can be achieved. For other announcements, issues around sufficient staff skills and confidence will make the aim challenging.

2.38.2. Do you consider that making the standard specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [] No [ x ]

2.38.3. If ‘No’, please explain which aspect(s) of the standard appears to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standard specified in the draft regulations specifically applicable to your organization.

The Health Board has a limited amount of public address systems, located in the organisations’ major health centre. Pre-records or automated public address systems would be able to provide bilingual messages, for example reversing vehicles. The challenge would be for staff operated public address system, where they are used for a wide variety of announcement.

Due to limited Welsh language skills of the system operators, it would be difficult to ensure that they are used bilingually. Furthermore, due to size and complexity of the organisation, monitoring and ensuring compliance to the standards would be very challenging.

2.39. Standards specified in the draft regulations which deal with supplementary matters in relation to service delivery standards [158-163] 2.39.1. Please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the Standards specified in the draft regulations which deal with supplementary matters in relation to service delivery standards, if those standards were to be made specifically applicable to them.

Standard Feedback Risk Rating 158 The organisation would be Q able to comply by providing full reports on its websites but believes providing copies in the 25 sites as onerous. 159 The organisation has Q procedures in place to deal with complaints around the Welsh language. The procedure towards dealing with complaints is available bilingually on the website. Leaflets are available for the public on how to provide concerns. 160 The oversight for the Q standard will continue for the Welsh Language under the current arrangements. It would also be able to publish the arrangements on the websites. Providing a copy of the arrangements in public areas would be onerous. 161 The organisation already Q complies with this under point 4.5 of the Welsh Language Scheme. It would be able to comply with most of the reporting requirements. It would also be able to publish the arrangements on the websites. Providing a copy of the arrangements in public areas would be onerous. 162 The organisation already Q provides a copy of the Welsh Language Scheme on its website. 163 The organisation has been Q consistently providing information for the commissioner on its compliance to the Welsh Language Scheme. 31

2.39.2. Do you consider that making the standards specified in the draft regulations, concerning the supplementary matters relating to service delivery standards, specifically applicable to your organization would be reasonable and proportionate? Yes [ ] No [ x ]

2.39.3 If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

The Health Board is already complying to the level of these standards under the current Welsh Language Scheme. The Health Board has policies and record practices that would provide an oversight on complying with these standards. For example, the organisation complaints procedure details how it will deal with concerns with specific response deadlines.

The organisation does have a concern on the expectation of making these arrangements bilingually in all public areas of the organisation. The Health Board has 21 sites in total where the public can access. In major sites, there is multiple public areas due to range of services available there. To make available copies of arrangement in all of these areas would be very onerous.

Section 3 – Policy making standards [86-95]

3.1. Please provide information and/or evidence demonstrating to what extent the organization assesses and monitors the effects of a new or reviewed policy, or revising an existing policy, whether positive or adverse, on: a) opportunities for persons to use the Welsh language b) treating the Welsh language no less favourably than the English language.

The organisation has extensively mainstreamed the Welsh Language into the policy development process, through the Equality Impact Assessment Exercise (EQIA). All policies are assessed on how they would impact on the Welsh Language and give patients and service users an opportunity to use their preferred language.

For example, in the revised policy for staff on the care of deceased following an expected death, relatives and friends should be given the opportunity to discuss with staff any issues through Welsh. Additionally, staff should also consider religious and cultural needs. Many deceased and their relatives might have specific Welsh language religious needs. Another example is the revised Data Protection Policy, with the EQIA process stating that the policy should comply with the Welsh Language Scheme.

However, the policies are developed with a view to identifying our ability to provide a service in Welsh. The organisation have not, to date taken the approach of ensuring that policy decisions have an “increased positive effects” on opportunities for persons to use Welsh.

The Board also do not specifically ask questions at the consultation stage re the impact on Welsh Speakers or the potential for decisions to have an “increased positive effect” on opportunities for persons to use Welsh. This section does not only relate to our policy documents. Part 2 explains that it also means (d) strategies and plans, (e) internal structures.

The Welsh Language Officer is regularly consulted by staff members who are producing the policy. They are consulted on evidence and good practice which would help the development.

3.2. Having considered the requirements of standards 89-91specified in the draft regulations, does the organization consult on any policy decisions? Yes [ x ] No [ ]

3.3. Please provide information and/or evidence to demonstrate to what extent the organization discusses and asks for opinions on the effect, if any, whether positive or adverse, a policy would have on the following: a) opportunities for persons to use the Welsh language b) treating the Welsh language no less favourably than the English language.

The organisation, as part of establishing the Welsh Language Scheme, ran a consultation exercise with local volunteer and community groups to seek views on the policy. They asked if the scheme would be effective on how the organisation could develop a bilingual healthcare service.

The South Wales collaborative programme also ran an extensive consultation with the local community across South East Wales. They ran the consultation bilingually, welcoming any feedback in English or Welsh. Local Welsh Language community groups and organisations were also consulted for views, especially on the impact of the programme on the language.

3.4. Having considered the requirements of standard 92 specified in the draft regulations, please note whether the organization has a policy on awarding grants? Yes [ ] No [ x ]

3.5. Please provide information and/or evidence to demonstrate to what extent the organization assesses the effect, if any, whether positive or adverse, awarding a grant would have on: a) opportunities for persons to use the Welsh language b) treating the Welsh language no less favourably than the English language.

3.6. Please provide information and/or evidence to demonstrate to what extent the organisation, when commissioning or conducting research to assist with the policy decision, considers the effects, if any, (whether positive or adverse) that policy decision would have on: a) opportunities for persons to use the Welsh language b) treating the Welsh language no less favourably than the English language.

Commissioning research to assist policy is part of the Equality Impact Assessment. Under the exercise, its required to research on policy by looking at policies from other organisation and service users feedback for example. The research helps to measure the positive and negative impact of the policy on patients and service users. The impact is categorised as such: Positive: Improves equal opportunities and/or relationships between groups. This can be “differential” i.e. where the impact can be greater for one group than another. It also takes into account multiple and cross cutting equality needs whilst avoiding assumptions and recognising individuality. For example, by not assuming a patient is heterosexual Negative: Equality groups could be disadvantaged, and this can be differential where the negative impact on one equality group is likely to be greater than that on another. None: No impact identified.

3.7. Please provide information and/or evidence to demonstrate to what extent the organisation, when commissioning or conducting research to assist with the policy decision, considers how that policy decision could be made so that it has positive effects or increased positive effects on: a) opportunities for persons to use the Welsh language b) treating the Welsh language no less favourably than the English language.

Please see impact 3.6

3.8. Do you consider that making the policy making standards specified in the draft regulations specifically applicable to your organization would be reasonable and proportionate? Yes [ x ] No [ ]

3.9. If ‘No’, please explain which aspect(s) of the standard(s) appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the proposed standard(s) specifically applicable to your organization.

The Health Board has made some considerable work towards ensuring that the Welsh Language is part of the policy development. It has been integrated as part of the Equality Impact Assessment exercise, which measure how the policy impact protected characteristics of the Equality Act 2010. This can complement each other because Welsh language can impact of a person health and wellbeing due to their age for example.

There are challenges to develop awareness of the Welsh language by those drafting the policies. However, the organisation finds these standards reasonable.

3.10. Standards specified in the draft regulations which deal with supplementary matters in relation to policy making standards [164-169] 3.10.1. Please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standards Feedback Risk Rating 164 The organisation would be Q able to comply by providing full reports on its websites but believes providing copies in the 25 sites as onerous. 165 The organisation has Q integrated the Welsh language into its concerns system to this standard. 166 The organisation can Q comply with this standard by integrating the Welsh language into the Equality Impact Assessment of all policies. Providing a copy of the procedure in the 25 sites would be onerous. 167 The organisation is Q already complying with this standard under 4.5 of the Welsh Language Scheme. It believes on the other hand, that providing copies in the 25 sites to be onerous. 168 The organisation will be Q able to publish the information onto its website 169 The organisation has been Q complying with this standards as part of the Welsh Language Scheme

3.10.2. Do you consider that making the standards specified in the draft regulations, concerning the supplementary matters relating to promotion standards, specifically applicable to your organization would be reasonable and proportionate? Yes [ x ] No [ ]

3.10.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

Please see response on 2.39.3

Section 4 – Operational standards [96-142]

4.1. Standards relating to the use of the Welsh language within a body’s internal administration [96-109]

4.1.1. Does the organization operate a policy on using the Welsh language internally for the purpose of promoting and facilitating the use of the language? Yes [ ] No [ x ]

4.1.2. If ‘Yes’, has the organization published it on its intranet? Yes [ ] No [ x ]

4.1.3. Please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with standard 96 specified in the draft regulations if that standard were to be made specifically applicable to them.

Standard Feedback Risk Rating 96 The organisation can develop a policy on Q developing the Welsh language internally

4.1.4. Does the organization provide the following documents in Welsh if required by the employee or worker? I. contract of employment Yes [ ] No [ x ]

II. contract for services Yes [ ] No [ x ]

III. paper correspondence relating to his or her employment and which is addressed to him or her personally Yes [ ] No [x ]

IV. documents that outline his or her training needs or requirements Yes [ ] No [ x ]

V. documents that outline his or her performance objectives Yes [ ] No [ x ]

VI. documents that outline or record his or her career plan Yes [ ] No [x ]

VII. forms that record and authorise the following: annual leave Yes [ ] No [ x ] absences from work Yes [ ] No [ x ] flexible working hours. Yes [ ] No [ x ] 4.1.5. Does the organization ask an employee or worker regarding whether they would like to receive the above documents in Welsh? Yes [ ] No [x]

4.1.6. Please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with standards 97 - 102 specified in the draft regulations if those standards were to be made specifically applicable to them.

Standard Feedback Risk Rating 97 Achievable but with a small resource impact Q 98 Due to individual nature of the correspondence, Q and the large variety of letters issued (many of which are not standard letters) this would be a significant challenge. There are information governance concerns (e.g. ensuring that the correct translated material is inserted by non- Welsh speaking line managers) and the impact translation could have on the timeliness of correspondence, especially when it is of a sensitive nature. 99 Achievable but there would significant resource Q impact 100 Where information / correspondence is Q personalised or tailored to the individual, there would be information governance risks, significant resource costs, and potential delays due to translation. 101 The organisation does not provide specific career n/a plans for employees. 102 This would be difficult to achieve e.g. flexible Q working application forms contain personalised information and would therefore be more difficult to manage

4.1.7. By ticking the relevant boxes, please specify in which language the organization publishes policies in relation to the following. If the documents are available bilingually, both boxes should be ticked.

I. behaviour in the workplace Welsh [ ] English [ x ]

II. health and well-being at work Welsh [ ] English [ x ]

III. salaries and workplace benefits Welsh [ ] English [ x ]

IV. performance management Welsh [ ] English [ x ]

V. absence from work Welsh [ ] English [ x ]

VI. working conditions Welsh [ ] English [ x ]

VII. work patterns. Welsh [ ] English [ x ]

4.1.8. Please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with standards 103 - 109 specified in the draft regulations if those standards were to be made specifically applicable to them.

Standard Feedback Risk Rating 103 The organisation has a number of Q these policies, so there will be resource impact. 104-109 There will be a resource impact, Q but many of the policies are issued by NHS Wales.

4.2. Standards in relation to complaints made by a member of a body’s staff [110- 113] 4.2.1. Does the organization allow each member of staff to do the following? make complaints to the organization in Welsh Yes [ ] No [ x ]

respond in Welsh to any complaint made about him or her. Yes [ ] No [ x ]

4.2.2. If ‘Yes’, does the organization inform each member of staff of the possibility of doing the above in Welsh? Yes [ ] No [x ]

4.2.3. When the organization receives a complaint from a member of staff or a complaint about a member of staff, and a meeting is required with that member of staff, does the organization do the following? offer to conduct the meeting in Welsh Yes [ ] No [ x ]

ask the member of staff whether he or she wishes to speak Welsh at the meeting Yes [ ] No [x ]

conduct the meeting in Welsh (without the assistance of translation service) Yes [ ] No [ x ]

provide a simultaneous translation service at the meeting (unless it is possible to conduct the meeting in Welsh without translation services). Yes [ ] No [x ]

4.2.4. Does the organization inform a member of staff of its decision in Welsh following a complaint made by or about him or her? Yes [ ] No [ x ]

4.2.5. Please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with standards 110 - 113 specified in the draft regulations if those standards were to be made specifically applicable to them.

Standards Feedback Risk Rating 110 The organisation would be Q able to receive written complaints in Welsh. There are concerns around staff confidentiality and resources issues when responding. 110 (a) The organisation would be Q able to receive written complaints in Welsh. There are concerns around staff confidentiality and resources issues when responding. 111 While receiving Q complaints in Welsh would be achievable, having a meeting in Welsh would have a resource impact and issues around confidentiality. There are also concerns about whether the meeting could be conducted by the most appropriate staff if it was arranged on the basis of language skills rather than suitability/appropriateness of conducting the meeting 112 There would be a large Q resource impact and organisational challenges with this standard. Meetings could also be delayed beyond what was considered ‘reasonable’ by the requirement to arrange a simultaneous translation 113 Due to the unique nature Q of meetings, there would be confidentiality risks, resource impacts and organisational challenges to achieve this.

4.3. Standards in relation to a body disciplining staff [114-117] 4.3.1. Does the organization allow all members of staff to respond in Welsh to allegations made against them as part of any internal disciplinary process? Yes [ ] No [ x ] 44

4.3.2. If ‘Yes’, does the organization inform all members of staff of the possibility to do the above in Welsh? Yes [ ] No [ x ]

4.3.3. When the organization organizes a meeting with a member of staff regarding a disciplinary matter that relates to his or her conduct, does the organization do the following?

I. offer to conduct the meeting in Welsh Yes [ ] No [ x ]

II. ask the member of staff whether he or she wishes to speak Welsh at the meeting Yes [ ] No [ x ]

III. conduct the meeting in Welsh (without the assistance of translation services) Yes [ ] No [ x ]

IV. provide a simultaneous translation service at the meeting (unless it is possible to conduct the meeting in Welsh without translation services). Yes [ ] No [ x ]

4.3.4. Does the organization inform a member of staff of its decision following a disciplinary process in Welsh? Yes [ ] No [ x ] 4.3.5. Please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with standards 114 - 117 specified in the draft regulations if those standards were to be made specifically applicable to them.

Standard Feedback Risk Rating 114 There would be major resource Q issue and organisational challenges around necessary staff skills to achieve this. 114 (a) There would be major resource Q issues, organisational challenge especially around staff skills to achieve this. 115 There would be major resource Q issue, organisational challenge especially around staff skills to achieve this. 116 The standard can be achievable Q but there would be major resource impact surrounding it. 117 There would be a major impact in Q resources, as well organisational challenges with staff skills in order to achieve this. There are also concerns about whether the meeting could be conducted by the right people if it was arranged on the basis of language skills th th

4.4. Standards in relation to a body’s information technology and about support material provided by a body, and in relation to the intranet [118-124] 4.4.1. Does the organization provide computer software for checking spelling and grammar in Welsh for employees and workers? Yes [ x ] No [ ]

4.4.2. Does the organization provide Welsh language interfaces for software where an interface already exists? Yes [ x ] No [ ]

4.4.3. Does the organization operate an intranet system? Yes [ x ] No [ ]

4.4.4. Are intranet pages available in Welsh, including the home page, the interface and menus? Home Page Yes [ ] No [ x ] Interface Yes [ ] No [ x ] Menus Yes [ ] No [ x ]

4.4.5. Please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with standards 118 - 124 specified in the draft regulations if those standards were to be made specifically applicable to them.

Standard Feedback Risk Rating 118 Staff can request and have access to such Q software. 119 The organisation has a large intranet site, Q edited by staff across all areas. To provide it in a bilingual would challenging and onerous, with questionable and limited benefits. 120 Providing a bilingual homepage on the intranet Q could be challenging but possible 121 The intranet is managed by a large group of Q staff across all areas in the organisation. To achieve this standard would be onerous with limited benefit. 122 The technological aspects would be Q challenging but achievable 123 The organisation is already achieving this Q standard. 124 The technological aspects would be Q challenging but achievable

4.5. Standards in relation to a body developing Welsh language skills through planning and training its workforce [125-133] 4.5.1. Does the organization assess the Welsh language skills of its employees? Yes [ x ] No [ ]

4.5.2. By ticking the relevant boxes, please specify in which language the organization provides training in the following areas. If they are provided bilingually, both boxes should be ticked. I. recruitment and interviewing Welsh [ ] English [ x ]

II. performance management Welsh [ ] English [ x ]

III. complaints and disciplinary procedures Welsh [ ] English [ x ]

IV. induction Welsh [ ] English [x ]

V. dealing with the public Welsh [ ] English [ x]

VI. health and safety. Welsh [ ] English [x ]

4.5.3. Please provide information and/or evidence to demonstrate to what extent the organization does the following: I. provide training in Welsh on using Welsh effectively in meetings, interviews and complaints and disciplinary procedures II. provide opportunities during working hours for its employees and workers to receive basic Welsh language lessons III. provide opportunities during working hours for its employees and workers who manage others to receive training on using the Welsh language in their role as managers IV. provide opportunities for its employees and workers who have completed basic Welsh language training to receive further training free of charge to develop their language skills.

Basic Welsh Language skills for meeting and greeting patients has been offered for frontline staff in reception areas and outpatient clinics. The Welsh Language Officer also has organised small informal welsh language lessons for staff want to learn some basic greetings. Staff have also participated in ‘cinio a chlonc’ lunch time meetings, where staff with Welsh language skills can practice their welsh. A section of the intranet has all the information on learning Welsh for all levels.

4.5.4. Does the organization provide training for its employees and/or workers for the purpose of raising their awareness of the following?

I. awareness of the Welsh language Yes [ x ] No [ ]

II. understanding of the obligation to operate in compliance with a Welsh Language Scheme Yes [ x ] No [ ]

III. understanding of how the Welsh language can be used in the workplace. Yes [x ] No [ ]

4.5.5. Does the organization provide information to new employees and/or workers to raise their awareness of the Welsh language? Yes [ x ] No [ ]

4.5.6. Please provide information and/or evidence on those arrangements below.

All members of staff must attend a corporate induction course. It is an intensive one day course for staff to learn about essential corporate information for example, waste management, occupational health, infection control and health and safety. One important aspect is Welsh Language awareness, where attendees are given a welsh language awareness session. The session includes awareness about Welsh in Cardiff and Vale, importance of language in healthcare, patient stories and how they can help provide bilingual healthcare.

The Welsh Language Officer and the Equality Manager also provides specific Welsh language awareness on request for teams across the organisation as part of Equality training.

4.5.7. Does the organization provide text or a logo to include in its employees’ and/or workers’ e-mail signatures which will enable them to indicate whether they speak Welsh fluently or whether they are learning the language? Yes [ x ] No [ ]

4.5.8. Are the contact details of employees and/or workers included in e-mail messages provided in Welsh? Yes [ x ] No [ ]

4.5.9. Are the e-mail messages of the organization’s employees and/or workers which inform others that they are unavailable to respond to e-mail messages provided in Welsh? Yes [ x ] No [ ]

4.6. Standards in relation to a body recruiting staff [134-138] 4.6.1. Please provide information and/or evidence of the methodology used by the organization in order to come to a decision on the Welsh language skills required when advertising a vacant or new post.

Standard Feedback Risk Rating 134 The organisation is already Q committed to do this under 3.7 and 4.1 of the Welsh Language Scheme 135 The organisation is already Q committed to this under 3.7.2 of its current Welsh Language Scheme 135 (a) The organisation would be able Q to provide standard job application material in a bilingual format. Providing a bilingual version for each job specification would be very challenging 135 (b) The organisation is already Q committed to this under 3.7.2 of its current Welsh Language Scheme 136 The organisation would face Q significant organisational challenges around staff skills to achieve this. In order to ensure that the right people are appointed to posts within the UHB, (which is essential for patient safety etc,) it is important that the right interview panel is able to select them. There are concerns about whether this is achievable if language skills were the primary reason for selecting the interview panel. 137 The organisation would find it Q challenging to achieve this due to a significant resource impact and there are risks attached as the provision of a translation service could delay the recruitment process. This could have a knock on effect on patient care and bank & agency costs. 138 Providing written Q communication to the applicant would have minimal resource impact and organisational challenge. Discussing the matter face to face would have a significant staff skills issue. The UHB prefers to let applicants know the outcome of all interviews in person or by phone.

4.6.2. Please provide information and/or evidence regarding the number and percentage of posts advertised with necessary Welsh language skills during the past year.

Number: 0 Percentage: 0%

4.6.3. Does the organization provide the following documents in Welsh? I. application forms Yes [ x ] No [ ]

II. job descriptions Yes [ ] No [ x]

III. material that explains the procedure for applying for posts Yes [ ] No [ x ]

IV. information about the interview process or other assessment methods. Yes [ ] No [ x ]

4.6.4. Does the organization state that persons are welcome to apply for a post in Welsh and that an application made in Welsh will not be treated less favourably than an application made in English? Yes [ x ] No [ ]

4.6.5. Do application forms provide a space for applicants to indicate that he or she would like an interview or other method of assessment in Welsh? Yes [ ] No [ x ] 4.6.6. If ‘Yes’, does the organization do the following? I. provide a simultaneous translation service at the interview or assessment (unless it is possible to conduct the interview or assessment in Welsh without translation services) Yes [ ] No [ x ]

II. conduct the interview or assessment in Welsh (without the assistance of translation services). Yes [ ] No [ x ]

4.6.7. When an applicant has applied for a post in Welsh, does the organization inform the applicant of its decision in Welsh?

Yes [ ] No [x ]

4.7. Standards specified in the draft regulations in relation to signs displayed in a body’s workplace [139-141] 4.7.1. Are the signs displayed inside the organization's buildings in Welsh? Yes [ x ] No []

4.7.2. If ‘Yes’, is the Welsh-language text positioned so that it is likely to be read first?

Yes [ ] No [ x ]

4.8. Standards specified in the draft regulations in relation to audio announcements and messages in a body’s workplace [142] 4.8.1. Are announcements made in the organization's buildings via audio equipment? Yes [ x ] No [ ]

4.8.2. If ‘Yes’, does the organization make these announcements in Welsh? Yes [ ] No [x ]

4.8.3. Do you consider that making the operational standards specified in the draft regulations specifically applicable to your organization would be reasonable and proportionate? Yes [ ] No [ x ]

4.8.4. If ‘No’, please explain which aspect(s) of the standard(s) appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the proposed standard(s) specifically applicable to your organization.

Audio announcements are limited to reception areas where staff call patients out for their appointment. There would be difficulty due staff level in Welsh skills to provide a bilingual service through audio announcements. There would also be difficulty in effectively monitoring due to numerous areas who may provide audio announcements in an informal manner.

4.9. Standards specified in the draft regulations which deal with supplementary matters in relation to operational standards [170-175] 4.9.1. If the organization carries out the activities in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standards Feedback Risk Rating 170 The organisation would be able to provide the Q document online. Due to the amount of workplaces areas which are open to the public, the provision of the standards in each of them would be onerous. 171 The organisation, under the current Welsh Q language Scheme, has integrated the Welsh language into its complaints procedure. 172 The organisation would be able to make Q arrangements that would make the organisation comply with the standards. 173 The organisation has been complying to this level Q under the Welsh Language Scheme requirements. Due to the amount of workplaces areas which are open to the public, the provision of the standards in each of them would be onerous. 174 The organisation will be able to publish such Q document 175 The organisation will be able to publish such Q document

4.9.2. Do you consider that making the standards specified in the draft regulations, concerning the supplementary matters relating to operational standards, specifically applicable to your organization would be reasonable and proportionate? Yes [ ] No [x ]

4.9.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

The organisation does have concerns around the requirement for distribution of documents across all the workplaces. The organisation has in total 21 sites across the Cardiff and Vale, varying major hospitals such as the University Hospital Wales ( which has multiple buildings that provide a service for the patients) to small community based health clinics. To provide copies of policy guidelines in all of these building would be onerous with very public benefit. The organisation would support the idea of publishing them on the internet and intranet. We also information centres in all major reception areas, where we can make these copies available.

Section 5 – Promotion standards [143-144] Welsh Ministers may, by order, amend the table in Schedule 6 of the Welsh Language (Wales) Measure 2011 to make promotion standards potentially applicable to a person. Promotion standards are not potentially applicable to your organization at present. A

53 person can give consent that promotion standards should be potentially applicable to them by giving written consent to Welsh Ministers.

5.1. Does the organization give consent to be potentially applicable to promotion standards? Yes [ ] No [ x ]

If ‘No,’ please proceed to Section 6 of the questionnaire.

5.2. If ‘Yes,’ please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standards Feedback Risk Rating 143 The organisation would be able to Q draft the 5 year strategy with intended aims. But the aim of the strategy (increasing the number of Welsh speaking staff) would be very challenging for the organisation. 144 The organisation already reports on Q the Welsh language skills of its staff and the activities it does to develop Welsh language care. The organisation believes that requiring to report on the ages of Welsh speakers would not have any impact on how the organisation could improve welsh medium healthcare.

5.3. Do you consider that making the promotion standards specified in the draft regulations specifically applicable to your organization would be reasonable and proportionate? Yes [ ] No [ x ]

5.4. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

The standards would not contribute to the main aim of organisation, which is to provide healthcare across cardiff and vale.

5.5. Standards specified in the draft regulations which deal with supplementary matters in relation to promotion standards [176-177] 5.5.1. Please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standard Feedback Risk Rating 176 The organisation would be Q able to comply with this scheme. Due to the amount of workplaces areas which are open to the public, the provision of the standards in each of them would be onerous. 177 The organisation would be Q able to comply with this standard

5.5.2. Do you consider that making the standards specified in the draft regulations, concerning the supplementary matters relating to promotion standards, specifically applicable to your organization would be reasonable and proportionate? Yes [ ] No [x ]

5.5.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

The organisation does have concerns around requiring for distribution of documents across all our workplaces. The organisation has in total 21 sites across the Cardiff and Vale, varying major hospitals such as the University Hospital Wales ( which has multiple buildings that provide a service for the patients) to small community based health clinics. To provide copies of policy guidelines in all of these building would be onerous with very public benefit. The organisation would support the idea of publishing them on the internet and intranet. We also information centres in all major reception areas, where we can make these copies available.

Section 6 – Record keeping standards [145-157] 6.1. Please provide information and/or evidence regarding the procedures the organization has in place to keep records of the steps taken to ensure compliance with the current Welsh language scheme. Organizations should identify any additional/new procedures that will be required, if at all, in order to comply with the record keeping standards specified in the draft regulations. If the organization does not feel that it can implement some of the record keeping standards, relevant information and/or evidence on the reasons why should be provided.

Standards Feedback Risk Rating 145 Organisation keep records of employment Q assessment. 146 Our current training records are held in the Q Employee Staff Records system. 147 The Welsh Language is mainstreamed as part of Q the Equality Impact Assessment exercise. All assessment exercise are kept as record. 148 The organisation is already complying with this Q standard under the 4.6 section of the Welsh Language Scheme. 149 The organisation is already complying with this Q standard under the 4.6 section of the Welsh Language Scheme. 150 The organisation would find this very challenging Q to complete. 151 The organisation is already complying with this Q standard. 152 The organisation could log the patients language Q preference on the patient management system. But providing language choice on the telephone would be very challenging. 153 The organisation could log the patients language Q preference on the patient management system. But providing language choice specifically in correspondence would be very challenging. 154 The organisation could log the patients language Q preference on the patient management system. But providing language choice specifically in meetings would be very challenging. 155 The organisation is already complying with this Q standard. 156 The organisation would be able to comply Q 157 The organisation would be able to comply Q

6.2. Having considered the requirements of the record keeping standards, please provide information and/or evidence regarding the procedures the organization has in place to keep records of the following: I. employees’ and workers' Welsh language skills II. assessments of the Welsh language skills requirements of vacant and new posts III. number and percentage of new posts where the need for Welsh language skills was identified IV. action taken to plan the workforce in order to ensure compliance with the current Welsh language scheme V. training offered through the medium of Welsh, and the numbers who attend the training VI. complaints received regarding your compliance with the Welsh language scheme VII. the number of calls to your main telephone number(s), to helpline numbers and call centre numbers, which were made by person who requested a Welsh language service VIII. the number of persons who wish to receive services through the medium of Welsh in response to an offer made by your organization IX. steps taken to ensure policies comply with your Welsh language scheme

1. Recorded under the Employment Staff Record. 2. No formal procedures are in place 3. No formal procedures are in place 4. Action plans with each clinical board have been devised to improve compliance. 5. Workforce department hold such information 6. The Concern team record and hold all complaints regarding the Welsh Language. 7. No formal procedures are in place. 8. Information can be recorded on the patient management system. 9. The Equality Impact Assessment Exercise record information around the Welsh language, and what steps should be taken to improve the impact on the Welsh language by the policy.

6.3. Do you consider that making the proposed record keeping standards specifically applicable to your organization would be reasonable and proportionate? Yes [ x ] No [ ]

6.4. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

6.5. Standards specified in the draft regulations which deal with supplementary matters in relation to record keeping standards [178-179] 6.5.1. Please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them.

Standard Feedback Risk Rating 178 The organisation would be able Q to comply with this scheme. Due to the amount of workplaces areas which are open to the public, the provision of the standards in each of them would be onerous. 179 The organisation would be able Q to comply with this standard

6.5.2. Do you consider that making the standards specified in the draft regulations, concerning the supplementary matters relating to promotion standards, specifically applicable to your organization would be reasonable and proportionate? Yes [ ] No [ x ]

6.5.3. If ‘No’, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization.

Section 7 – Further information 7.1. Please provide information and/or evidence of partnerships on which the organization leads either strategically or financially, for the purposes of delivering services.

The organisation works closely with many local groups across the Cardiff and Vale. Partnership are set up to liaise closely with the groups, in order to spread awareness of health service or to be consulted on the services.

For example, recently the Cardiff and Vale University Health Board worked with the local Transgender community in Cardiff and Vale to help develop awareness amongst its community about health issues.

The organisation has a single integrated planning group. The group is a mechanism to co- ordinate all local health services jointly in Cardiff and Vale of Glamorgan. For example, it co- ordinate the Substance Misuse Service with local authorities such as Cardiff Council, local health groups and third sector.

7.2. Please provide information and/or evidence of partnerships which the organization is part of, either strategically or financially, for the purposes of delivering services.

The Health Board works closely with many local groups, community organisation, charities and volunteering circles. Working together to inform on changes and assisting in delivering of services. For example, it is a member of the Local Services Board which co-ordinate large amount of local and primary services across the communities in Cardiff and Vale of Glamorgan.

It is a member of the Cardiff Debate, a group of local public services providers which run public engagements events in the community. The aim is to discuss, consult, feedback and make aware of changes in services by the public sector.

7.3. Please provide information and/or evidence of any consortia which the organization is part of for the purposes of supplying services.

The organisation has many service level agreements with third sector charities to run together a number of health related services.

For example, the Gerontology service change where the Health Board is working with third sector organisations, service users and the local council to develop and supply a new service for older people.

7.4. Please provide information and/or evidence of the services provided by the organization by a contractor or third party. Details should be provided regarding the organization's monitoring procedures for those contracts, stating how you ensure that third parties provide those services in accordance with the relevant sections of the current Welsh language scheme.

The organisation relies on contractors and commissioned services to provide primary cares service across the Cardiff and Vale area. These include General Practice surgeries, pharmacies, optometrist and dentistry. Due to the contractual obligations as agreed between these parties and the Welsh government, the organisation has always found it challenging to ensure that these practices can provide health through the medium of Welsh. It is limited to encourage the practices to provide the bilingual healthcare. Therefore, it will be difficult for the organisation to monitor and ensure that they provide Welsh medium healthcare.

In regards to third party contractor, the organisation has included the Welsh language as part of the tendering process for contractors. These contractors provide a wide variety of services and goods for the organisation. Due to the wide range of contractor activities across the organisation, compliance and monitoring has been challenging.

7.5. Are there any planned or proposed changes to the organization's services (e.g. outsourcing services) that will affect the answers to this questionnaire? Yes [ ] No [x ]

7.6. If 'Yes', please provide information and/or evidence of those services, in accordance with the proposed timetable below.

The Health Board services constantly changes for numerous reasons. For example, new services are introduced or change in public demand for specific services. Medical innovation or practice can also demand changes to happen. Recently, the organisation has been involved with the South Wales Programme where services have been relocated or change on how they’ve been delivered. These changes are affecting the 5 health boards in the South East Wales area.

7.7. Further comments:

Of the 179 comments we have reported against, 60 have been classed as green in risk. Many of them the organisation have agreed to do under the current Welsh Language Scheme. However, we classed the other standard as unreasonable and disproportionate given the resources available to the UHB and some consideration of patient and environmental impacts.

This process has been complex for the organisation. In discussing the proposed Standards with our partner organisations, we have found that the aims of each standard are open to interpretation and thus an agreement or consensus is more challenging. The Welsh NHS is one of the biggest organisations in Wales and has a wide range of activities dealing with patients and service users. Most of the interactions will be on an individual patient consultation basis. The volume in itself makes it challenging to achieve the range identified in the proposed Standards.

We recognise that the Commissioner is attempting to create a group of standards that would reach across the Welsh public sector, aiming to be consistent and uniform. The issue for the organisation is that many standards might look disproportionate or unreasonable for many of the organisations’ activities; particularly those which involve front line service. There is a case for them to be toned down and look more achievable for the organisation. .