Scottish
Disability
Team
NB This is the fourth page of the online version of the SDT Guidance Note Disability Impact Assessments: A Brief Guide, published in December 2005.
For each policy or practice, a rigorous process of assessment should be followed using all the available evidence and gathering more if it is needed. There are several stages to the process and disabled people should be involved at every stage.
For new policies and practices or individual revisions to policies and practices, this should be done at an early stage and should involve disabled people in the process of considering the questions outlined for the mapping process above. This should be built into the policy-making process and Committees should expect to see Impact Assessment reports when considering new policies or changes to policies.
For each policy or practice, in advance of checking to see what data is available, the first stage should be to consider what data would be required to adequately assess the impact of a particular policy or practice on disabled people.
Then, identify what data is available and what additional data needs to be gathered - and think about the timescale for doing this. Is it appropriate and proportionate or could reasonable decisions be made based on the data which is currently available?
Where general data is available but is not disaggregated by disability status/type of impairment, think about whether there are ways of doing this. If records are such that an individual can be identified and their disability status is held elsewhere, for example on a staff or student database, is it possible to link these records up so that disaggregated data is created? This may not be possible because of Data Protection considerations but should be explored.
Think also about qualitative data and anecdotal evidence. This is important in any case, but particularly important where quantitative data is not available.
It is important to remember that data gathering methods must be accessible to disabled people and so the methods of gathering data should also be assessed for their impact.
Detailed advice on gathering data can be found in the Equality Challenge Unit's Briefing Paper 3: Disability Equality Schemes: Collecting and improving baseline data and the importance of involving disabled people (ECU, 2005).
Example 1: A change is proposed in relation to staff recruitment processes resulting in all but the most senior posts being advertised online only and not in the Press.
The data required to determine if there is an adverse impact on disabled people is the percentage of people (both disabled and non-disabled) applying online compared to those responding to the newspaper advertisements. On examining the data, it is found that a similar high percentage of disabled people and non-disabled people apply online. However, it is not clear from these figures where people have originally seen the advert. They may have seen it originally in a newspaper but chosen to apply online. A question could be added to the Monitoring Form asking where the applicant first saw the advertisement to gather this information.
Example 2: Students are asked to complete evaluation forms at the end of each module of a course. The forms are anonymous and analysis shows that there is a fairly high level of satisfaction with the teaching. It is not possible to identify disabled students from the forms so it is impossible to ascertain whether there are any adverse impacts. There is, however, anecdotal evidence from disabled students that the lecturer's visual aids are not accessible, that she does not make lecture notes available and that they did not rate the teaching highly. Account should be taken of this qualitative evidence as part of the impact assessment and the data gathering process itself should be checked to ensure that the information can be gathered in alternative accessible ways so that disabled students are able to respond.
Once all available data has been gathered, it should be examined to check whether there is evidence of:
Where any adverse impact is discovered or suspected, there may be a need to collect further evidence to examine the cause of this.
Example 1: A University's plans to move to a new campus have resulted in a drop in the number of applications from disabled people. Further research is conducted with community organisations of disabled people and it is discovered that the new location is poorly served by accessible transport and there is limited parking.
Example 2: A popular activity during Freshers' week organised by the Students' Association involves a pub treasure hunt around many of the hostelries around the University. Several of the pubs involved are not fully accessible and disabled students feel they cannot take part. (This example may involve adverse impacts in a number of other areas e.g. gender, race, religion, sexual orientation)
Where a policy or practice has a positive impact on disability equality, this should be measured as part of the impact assessment process. If the policy or practice does not promote disability equality in its current form, it should be assessed to see if there is scope for promoting disability equality and amendments considered. The assessment of positive impact should also be included in the impact assessment report.
Example: A new policy on flexible working will benefit many employees with caring and other responsibilities. It may also have a positive impact on disability equality as it will allow people to travel on public transport at less busy times, making their journey to work easier and less stressful.
Where a potential adverse impact has been identified, an assessment should be made of the severity of the impact. Where the policy or practice would result in practice which is potentially unlawful, changes should clearly be made. The objectives of the policy or practice should be re-examined to find if there is an alternative way of meeting the desired objectives without the adverse impact. If the adverse impact is potentially unlawful and alternatives cannot be found, the policy or practice may have to be completely redesigned. The opportunity should be taken to consider whether there are ways, not just of removing the adverse impact, but of creating a positive one. Disabled people should be involved in this process.
Example: In the transport example above, the University could enter into negotiations with the local transport company to make sure that accessible transport is available. This information should be readily available to campus users. They could also designate a higher proportion of the limited parking to disabled drivers and make sure that this is also advertised widely.
Disabled people should have been involved in the impact assessment process and any changes to policies and practices which have resulted. The amended policy or practice should, therefore, reflect many of their concerns. However, it is important to consult widely before implementation.
The Act states that institutions are required to publish their Disability Equality Schemes and Action Plans, which will include the results of the impact assessment process. HEIs and Colleges will need to consider where the findings are published and make sure that they are produced in a way that is easy to access and understand. It is, therefore, important that the work done on impact assessment is systematically recorded.
The aim of this Guide is to set out brief guidance on conducting disability impact assessments. It should not be forgotten that the Race Relations (Amendment) Act 2000 also requires Universities and Colleges to conduct impact assessments as will the gender equality duty, which is planned to come into effect in April 2007. It is important, therefore, that an overarching impact assessment framework and methodology is used for all equality strands, although the actual impact assessments may be carried out separately and different people may be involved. It should also be remembered that disabled people are a diverse group and may also be affected by adverse impacts on grounds of ethnicity and gender.
Next page - 5: References and Further Resources.