NORTHERN IRELAND ASSEMBLY COMMISSION

We welcome the offer of hard copies and meetings with representatives of the Assembly Commission and other demonstrations of the inclusive approach being taken by the Commission. We would however suggest that the offer of alternative formats be placed earlier in the correspondence and in a more prominent position.

Noted

Disability Action welcomes the clear statement contained in the Confirmation of Commitment.

Noted

We commend the Commission’s intention to fully and inclusively consult with disabled people and their representative organisations.

Noted

We would ask the Commission to look at the Equality Commission’s recent Review of s75 in relation to timescales for Equality Schemes and Disability Action Plans.

Noted. The Assembly Commission will take into consideration the findings of the Review of Section 75. We will align the review of the Scheme to coincide with our business /corporate planning cycle with the intention that this will take place on a 3 year cycle.

We welcome the Assembly’s intention to establish an informal group to consider public life positions.

The Northern Ireland Assembly Commission does not have any control over public life positions. We will however, be establishing an informal group to assist us in furthering the objectives of the Equality Scheme and the Disability Action Plan.

Although we realise that the Commission has taken the Equality Commission’s advice in including a list of previous measures, Disability Action believes that Disability Action Plan’s should be looking forward and that many previous measures were already requirements under the Disability Discrimination Act.

Due to the prolonged period of suspension with devolution only restored since 8 th May 2007 previous measures will remain within the Plan to allow for staff and the public to become familiar with its contents. Such information will be updated following the first review of the Plan.

We would advise that the term “disabled egress” should be replaced by “egress for disabled people”. (Section 7.1 Training and Guidance for Staff)

Noted. Amendments have been made.

Disability Action would advise that the disability monitoring audit would be improved by enlisting the assistance of a competent disability organisation in encouraging staff to declare a disability. (Section 7.1 Monitoring)

With the establishment of our internal and external fora it is hoped that all staff will be further encouraged to declare disabilities through the annual audit. The internal and external fora will consider this issue further and will consider initiatives to further raise the profile of disability issues in general.

Commitment 8.1.1

Disabled people and their representative organisations should advise on the Consultation Strategy.

This measure will be amended to reflect that all future consultations undertaken will be carried out and developed in conjunction with the External Forum.

Commitment 8.2.3

We welcome this positive action

Noted.

Commitment 8.2.5

See our comments at bullet point 1 (8.1.1) above

This measure will be amended to reflect that all future consultations undertaken will be carried out and developed in conjunction with the External Forum.

Commitment 8.3.5 and relevant others

Timescales should never be “as appropriate” or “ongoing”. The target in this commitment could for example be every second issue.

Noted. We will aim to include an article on health/disability awareness matters in every second issue of the magazine.

Commitment 8.4.1

This target should be – annually, six-monthly or quarterly

The use of the term “as appropriate” in this commitment is intended to reflect that this will be considered for every recruitment drive.

Commitment 8.4.2

This target should be – every recruitment drive

Noted. The use of the term “as appropriate” in this commitment is intended to reflect that this will be considered for every recruitment drive.

Commitment 8.4.3

This, like 8.4.1 & 8.4.2, are already requirements under Part II of the Disability Discrimination Act

We accept that these are already requirements under the legislation but in order for the NI Assembly Commission to reaffirm its commitment to mainstreaming its obligations under the duties it is important that these commitments are retained within the Plan.

Commitment 8.5.1

“Ongoing” should be changed to quarterly, bi-monthly or monthly

The use of the term “ongoing” in this measure is intended to ensure that this commitment is adopted and maintained for every visit/visitor to Parliament Buildings.

Commitment 8.5.2

Timescales must be identified for the production of accessible forms of corporate literature

The NI Assembly will ensure that all corporate literature will be made available in suitable alternative formats on request.

Commitment 8.5.3

This is already a requirement under the Disability Discrimination Act.

We accept that these are already requirements under the legislation but in order for the NI Assembly Commission to reaffirm its commitment to mainstreaming its obligations under the duties it is important that these commitments are retained within the Plan.

Commitment 8.6.5

We would ask the Commission to look at the Equality Commission’s recent Review of s75 in relation to timescales for Equality Schemes and Disability Action Plans.

Noted. The Assembly Commission will take into consideration the findings of the Review of Section 75. We will align the review of the Scheme to coincide with our business /corporate planning cycle with the intention that this will take place on a 3 year cycle.

We are pleased to note that the Plan has been made available on the Commission's web site in a format other than pdf. This is an example which other public bodies should follow.

Noted.

We are very disappointed that our requests for braille and large print copies of the Plan have not been fulfilled. We very much hope this is an individual glitch, since it does not correspond to the policy proclaimed in the Action Plan.

Noted. Documents were posted as requested but unfortunately not received by RNIB. As soon as this came to light further documents were issued.

Epilepsy Action welcomes the attempts to increase awareness of disability issues and promote positive attitudes towards disabled people through the Disability Action Plan.

Noted.

Epilepsy Action has identified the following measures as having the greatest impact:

• Identifying measures to promote positive attitudes for people with disabilities
• Providing specialist training for staff
• Ensuring that job opportunities are available to applicants with disabilities
• Reviewing the operation of existing services in conjunction with people with disabilities and their representatives to identify any barriers to access for this group

Noted.

7.1 Promoting positive attitudes towards disabled people

Review Team

This seems to be made up from members of staff and it would be interesting to find out if anyone with a disability is involved on the team, if not then the Review Team should consider co-opting a member from an NGO with an expertise in disability.

This is an internal group for staff within the NI Assembly Secretariat. We intend establishing an informal group of practitioners from disability organisations.

Education and Training

If there are no members of the NIA with disabilities then again an NGO with expertise should be engaged to discuss and assist in planning education and training programmes

We intend establishing an external forum under the auspices of the Equality Scheme where representatives of Section 75 and disability organisations will be invited to form this group.

The aims of the Plan are most commendable and must be achieved by the intended timescale.

Noted.

Obviously a good beginning. The achieving of performance targets will be all important. The involvement of disabled persons and/or their representatives and carers in future planning is vital. Their motivation is especially valuable and needs to be harnessed

Noted.

Commitment 8.1.1

Establishment of External Working Group

Within the Action Plan there is a commitment to establish an informal working group representative of people with disabilities. Will the group have an opportunity to come back to the Commission and identify what has and has not been achieved to date?

The rationale for the establishment of this group is to provide a guidance and monitoring role for the Commission in the implementation of the Equality Scheme and Disability Action Plan.

Commitment 8.1.1

Establishment of External Working Group

Could such opportunities not be rolled out to all Government Departments?

The NI Assembly is a separate body from the 11 Government Departments and has no control over the structures developed by the Departments in relation to this area.

There is a stigma attached to disability and the declaration of disabilities. We are trying to promote that people don’t have to be afraid to declare this. Public organisations just need to be aware that these people are there.

With the implementation of our Equality Scheme and Disability Action Plan, the NI Assembly recognises that there are difficulties experienced by people with disabilities and the Assembly Commission hopes that the introduction of these policies and the actions contained therein will, in some way, help to alleviate such stigma.

We would further advise that small but significant accessibility issues still need to be addressed by the Assembly Commission to ensure that disabled people have full use of the buildings. (Section 7.2 Access to Parliament Buildings)

The NI Assembly Commission Office would be happy to discuss any specific areas of concern and will contact you to discuss these issues further.

Commitment 8.2 part 2

This measure needs to be rewritten to clearly indicate its meaning to consultees and a fixed timescale should be included

This measure intended to provide for active consideration of any new duties that may arise following changes or amendments to legislation. We have amended our Section 75 policy screening proforma to specifically identify and promulgate disability issues. This we hope will assist in a greater focus afforded to disability issues in the development of policies within the NI Assembly.

Commitment 8.3.3

This is another example of proposed good practice. Disability Action is currently developing an e-learning programme on diversity and would be happy to talk to the Commission about this work

Noted.

Commitment 8.5.3

The target should be to reach AAA standard and a timescale should replace “ongoing”

Within our current set up the Assembly cannot claim anymore than A rating due the historical information held on the website - documents submitted contain tables and there are images in committee reports that are unsearchable and cannot be browsed.

We have just published a new Corporate Plan for the period 2008-2011 and this contains a commitment to complete a review of the website by March 2009. Any recommendations arising from that review will be implemented by March 2010.

RNID welcomes the proposals outlined in the Disability Action Plan, particularly 8.1.1 which proposed to establish an informal group of disabled ‘advisors’. It is important that all other actions are carried out in consultation with this group. We also recommend that the Assembly Commission includes capacity-building measures in the set up of this group to enable full and proper consultation, and to make provisions for reasonable adjustments to enable member to participate fully, e.g., procedures for booking communication support (i.e. lip speakers, electronic notetakers and sign language interpreters).

The NI Assembly Commission Office intend establishing an informal group of practitioners who would be willing to guide us in the implementation of the action plan. Through this vehicle we hope to identify best practice standards and any additional facilities that are required in support of this group will be provided.

Commitment 8.5.6

A timescale should be added

This has been amended to read March 2009.

Commitment 8.2.6

To ensure that educational programmes are fully accessible e.g., provision of tours of the Assembly in sign language, information resources to be provided in Plain English, and DVDs to be fully subtitled, and signed where necessary.

Should a sign language interpreter be required the Assembly will make arrangements to provide this service. Current information resources are provided in Plain English and subtitled DVDs will be considered.

The Education Service is happy to work with relevant organisations in order to design suitable resources and programmes.

Measure 8.2.7

To ensure customer feedback system is fully accessible to deaf and hard of hearing people.

We have just published a new Corporate Plan for the period 2008-2011 and this contains a commitment to establish customer service standards during 2008/2009. Any such recommendations will be considered as part of that process.

Measure 8.3.1

To provide further training on disability equality – not just duties and responsibilities but to include attitudes, respect and human rights.

We will develop a training programme that will address such issues.

Measure 8.3.3

To create links from the Intranet system to external disability organisations’ websites.

We will be further exploring the use of our intranet facilities and in particular using this facility to highlight key developments in this area to our staff and Members.

Measure 8.4.2

To liaise with voluntary sector experts in disability and employment issues re: best practice standards.

We will be looking at best practice approaches to recruitment and personnel in the development of new policies.

To consider RNID “Louder Than Words” charter mark status re: best practice standards.

We will be looking at best practice approaches to recruitment and personnel in the development of new policies.

To further clarify that interpretation facilities are promoted to the deaf community and that only fully qualified, registered interpreters are used. Further information on this is available from RNID.

Noted. We will liaise with practitioners in this field and ensure that any service developed will be appropriate to meet identified needs.

8.5.4

RNID is happy to facilitate an information session for deaf and hard of hearing people.

Noted. We are grateful for the offer of this service.

8.6.1

To monitor and evaluate the customer feedback system and general accessibility and attitudinal issues through a ‘mystery shopper’ exercise by disabled people.

Noted. We have just published a new Corporate Plan for the period 2008-2011 and this contains a commitment to establish customer service standards during 2008/2009. Any such recommendations will be considered as part of that process.

8.1.1 / 8.2.4

We feel that involving disabled people in service planning from the very beginning is the only way of giving due recognition of the importance of these issues, and embedding equality in the work of the Assembly Commission.

We intend establishing an informal group of practitioners who would be willing to guide us in the implementation of the action plan. Through this vehicle we hope to identify best practice standards in the development and implementation of all policies.

8.3.1

Staff training is very important but must go beyond the ‘letter of the law’ training and include attitude and human rights issues.

We will be undertaking a comprehensive training programme for all staff over the next 12 months and such training will address these issues.

8.5.9

Working in partnership with the voluntary sector in promotion these messages is key.

Noted. See response below.

RNID welcomes the Assembly Commission’s Disability Action Plan and commend the Commission’s thorough approach to involving disabled people in the planning, delivery and evaluation of Assembly services. We would encourage the Commission to explore best practice standards, rather than simply adhering to duties imposed at a basic level.

We intend establishing an informal group of practitioners who would be willing to guide us in the implementation of the action plan. Through this vehicle we hope to identify best practice standards in the development and implementation of all policies.

In general, this Plan is thorough and comprehensive. It contains many commendable elements. We do feel that the Plan could be read as if the process were more important than the outcome, but we also recognise that this probably arises more from the format than the intention.

The NI Assembly Commission is committed to the delivery of this plan in the hope that the outcomes go some way to achieving the stated objectives.

In Section 7.1, under the heading "Communication and Education", there is reference to achieving Web Access Initiative A level compliance. We wonder if this is a misprint, since reference is made elsewhere in the document to AA Level. Certainly, we would urge all organisations to achieve at least AA standard

This is a misprint and it should refer to WAI level A compliance.

We have just published a new Corporate Plan for the period 2008-2011 and this contains a commitment to complete a review of the website by March 2009. Any recommendations arising from that review will be implemented by March 2010.

Under the same heading, we are pleased to note that arrangements have been made to ensure that all publications can be made available in large print, audio and braille. It is of course important that these versions are available as promptly as the print versions. We should also like to enquire whether this policy applies to short term documentation such as order papers, agendas and so on.

Alternative formats will be organised as soon as possible following a request. This policy can also be applied to short term documents.

In Section 7.2, under the heading "Access to Parliament Buildings", references to lifts speak only of access by people using wheelchairs. The requirements of visually impaired users also need to be met. This could be done through measures such as:

- control buttons which are identified by large, raised and clearly contrasting figures and letters, and which are also identified in braille;

- speech announcements telling users which floor they have reached;

- good lighting, an absence of glare and good colour contrast between doors and surrounds, control panels and walls, etc.

All of the lifts in Parliament Buildings have been adapted to incorporate raised buttons, contrasting figures and letters and speech announcements telling users which floor they are at.

The lift cars have also been re-fitted to help achieve improved colour contrast, good lighting and absence of glare.

We wonder if the Commission would make guides available to escort visually impaired visitors around the buildings?

The Engagement Directorate will consider all improvements to our services that will enable all sections of our community to participate in the operations within Parliament Buildings.

Section 8.4. needs to take greater account of ensuring that vacancies are advertised in ways which do not discriminate against people who cannot read newspapers or other printed advertisements. This might be achieved through co-operation with the Disability Advisory Service within the Department for Employment and Learning and through partnerships with agencies such as RNIB.

Our recruitment team will explore further ways in which to address this important issue.

Section 8.5.3 refers to the acquisition of appropriate technology for disabled employees. However, it may not be adequate merely to approach this on a case by case basis. Timely and adequate provision for disabled employees links in with a corporate procurement policy which insists on accessibility and a corporate publications policy which already has mechanisms in place to produce accessible material as soon as it is needed.

The procedures currently in operation allow for the provision of appropriate technology and accessible material as soon as a need has been identified.

Employment

Many disabled people may not have the academic qualifications due to their early experience which may have hindered them from formal testing. Many disabled people although have gained skills and knowledge throughout their working career. The NIA should consider innovative methods of engaging all sections of the community in Northern Ireland including positive action to increase disabled.

The Northern Ireland Assembly Commission is currently reviewing its Recruitment and Personnel policies. There will be opportunities for interested organisations to comment on any new policy that may be developed and we will actively engage with the relevant organisations in this process.

7.2 Encouraging the participation of disabled people in public life

Access to Parliament Buildings

It is not acceptable that because of their disability someone cannot have access to the building through front door. In delivering equality for everyone a person having to leave their tour / party in order to be taken to another entrance does not embrace this ethos. Furthermore, this becomes an issue if the person is a member of staff.

The accommodation needs of the Assembly are currently being reviewed and we will further consider the provision of ramp access at the front door.

Signage

If we can have expertise in Irish and Ulster Scots signage should be accessible at any time within the NI Assembly this may require training a Secretariat to learn.

Noted.

Recruitment and Selection – 8.4

Greater awareness among disabled people that they will have access to any posts, provided the posts will not be harmful to them in spite of available safety measures and support mechanisms, or the objectives of the post are not significantly disadvantaged by the person’s disability – these are probably occupational health issues.

Noted.

Establishment of External Working Group

The NI Assembly is now best placed as an organisation that should adopt best practice in this area.

Noted.

Establishment of External Working Group

Representation of the external group should be afforded to representatives of all 5 disability groupings. It is usual that the Chief Executives/ Heads of the larger formal organisations are invited to represent the groups. It is essential that smaller groups have the opportunity to engage and have their voice heard.

We intend establishing an informal group of practitioners who would be willing to guide us in the implementation of the action plan. We hope that the group will be representative of and provide for an opportunity for smaller groups to become involved.

Training

In reference to the commitment to undertake formal training and general awareness raising for staff of the issues, it is crucial that all such training should involve people with disabilities directly in the delivery. There should also be some level of training/awareness raising for MLAs and/or parties.

Noted.

Establishment of External Working Group

In establishing the external forum, cognisance needs to be taken of the issue surrounding remuneration and/or expenses to be paid to members. Most people with disabilities cannot apply for remunerated positions as they would then have to forfeit any benefits which they are in receipt. If appointments are remunerated or fees paid, regard must be taken on the impact any payment may have on benefits.

We will be asking groups to engage with us on a voluntary basis but we will ensure that all steps are taken that will allow for those who wish to engage with us that they can be facilitated in some way. Any necessary expenses incurred will be reimbursed.

Parking

Disabled parking bays at Parliament buildings do not conform with legislation.

The disabled parking bays have now been brought into line with current legislation.

Access

There is no front door access to Parliament Buildings for people with disabilities.

The accommodation needs of the Assembly are currently being reviewed and we will further consider the provision of ramp access at the front door.

Access

It is usual for buildings and adaptations to buildings to be architect designed. Generally these designs are developed to meet the minimum requirements under the legislation. Such minimum requirements do not always meet needs of users e.g. Would toilets facilitate a wheelchair user and two carers? If a ramp is accessible for wheelchair users then it will be accessible for mothers with prams.

Where possible, within the constraints of a listed building, adaptations meet the legislative requirement as a minimum.

In relation to accessible toilets, the main toilets on the Ground Floor do have adequate space for a wheelchair user and 2 carers.

Access

Many of the standards are now very old and don’t accommodate the more recent advances in technology. It is important to note that issues for people with disabilities change over time and organisations need to keep up to date.

Every effort is made to keep the facilities up to date wherever reasonably practicable.

It is important that organisations carefully consider language used when dealing with people with disabilities. They don’t want to be placated. Some language can be too politically correct and some offensive.

Noted. The Northern Ireland Assembly Commission will carefully consider and ensure that any language used is appropriate.

Recruitment and Selection

When organising recruitment campaigns there is no clear definition of what would be acceptable for people with hidden disabilities who want to apply for employment. An example would be difficulties in completing tests or indeed where this is possible no additional time would be allowed.

Where a need has been identified, we ensure that all requirements are facilitated to allow for inclusion in recruitment campaigns.

The Northern Ireland Assembly Commission is currently reviewing its Recruitment and Personnel policies and there will be opportunities for interested organisations to comment on any new policy that may be developed and will actively.

Consultations

Consultation events generally take place in the greater Belfast area and there is a need to address this issue and engage directly within communities.

We will continue to offer the opportunity to engage with organisations and/or individuals at various locations within Northern Ireland.

Consultations

There is a need to identify and engage with groups working on the ground who are not directly affiliated to umbrella organisations such as Disability Action, RNID, RNIB etc.

Any further consultations or developments in this area will be openly publicised and any group or organisation is welcome to engage with us at any time. We currently have a list of organisations with whom we have consulted in the past and if anyone wishes to be included they can contact us.

Consultations

Consideration needs to be taken in relation to the costs involved in attendance at consultations. Many of the groups are voluntary whilst many want to actively engage with the public sector it is not always possible due to costs involved in transport etc.

We will ensure that all groups are given the opportunity to engage during any consultation or other events. Staff are available and will meet with those groups or individuals who wish to engage with us.

Consultations

There is a perception that policies adopted and consultations are not “real” or implemented to the letter. Many are considered as a verbal commitment and not always acted upon.

The Northern Ireland Assembly Commission is committed to the full and effective implementation of policies in line with current equality guidelines.

Inclusion

A main consideration is the issue of inclusion. One in 5 people in NI have a disability. 80% of the Arts and Disability Forum Board would have a disability.

There is a need to set specific targets in order to increase inclusion.

The Assembly Commission are committed to inclusive practices and will consider this further in the course of the ongoing review of our procedures.

Membership of Committees and Public Life Positions

In order to facilitate people with disabilities accepting remunerated positions on committees etc, a facility should exist whereby benefits can be set aside for the period of the appointment and reinstated without having to reapply. Once you come off the benefit system it is increasingly difficult to get back on the system.

The Northern Ireland Assembly Commission has no control over the benefit system within NI. The Commission will not be in a position to offer remuneration to members of any forum established by it.

Access

Is there disabled access to Assembly chambers? Is there a provision for signing and interpretation available both within the Assembly chambers and the secretariat?

There is disabled access to the floor of both chambers. We have plans to improve the access to the Assembly Chamber and galleries including the provision of 4 additional wheelchair spaces, a platform lift, accessible toilet facilities together with a level entrance to the floor of the Chamber through the main entrance.

Signing and interpretation services can be provided during debates. We will undertake a pilot project within the Chamber commencing in September. The pilot will run for 3 months.

Training

The Commission should consider offering training on sign language and interpretation to staff within the secretariat and this would increase the availability of this service.

We currently have 2 members of staff, with sign language skills. These staff are engaged within the Events Office and currently facilitate tours within parliament buildings.

Our training unit will provide assistance for any member of staff who wishes to undertake such training.

Publications

Some organisations when printing reports and documents to highlight work carried out on equality/disability issues tend to use photography as a means to highlighting the “good work” that they do in this area. Sometimes the use of photographs can be considered offensive.

The Northern Ireland Assembly Commission will ensure that all such sensitivities will be taken into consideration prior to the publication of any documents or reports.

Procurement

The NI Assembly will, in the normal course of its business, engage/procure outside contractors to undertake certain roles. It will be important for the Assembly to consider the needs and sensitivities of people with disabilities and provide additional training or awareness in this area.

Procurement is largely dealt with in NI Assembly contracts through the use of an equality of opportunity clause that provides for an obligation, on the part of the contractor to take all reasonable steps to ensure observance of the legislation.