Written evidence from National Association of Disabled Staff Networks (NADSN) [NDS0011]

The National Association of Disabled Staff Networks (NADSN) is a super-network that serves to connect and represent disabled staff networks. We are an unincorporated association, non-governmental, independent, and self-determining. Members have worked to develop a set of recommendations to remove and ameliorate barriers faced by those who are marginalised due to disability. We currently have over 350 members representing over 150 organisations, predominantly in the U.K. The National Association of Disabled Staff Networks welcomes a greater focus on the structural inequalities and discrimination experienced by disabled people. As outlined below, we do however, have concerns in relation to the approaches to disability taken and specific aspects of the Strategy.

Overall Comments

Throughout the Strategy, disability and disabled people are discussed collectively. Though we take great strength and pride in our community and shared experiences, it is important to acknowledge both the hierarchy of disability that impacts on perceptions of different conditions (e.g., Thomas, 2000) and the importance of intersectionality (e.g., Shaw et al. 2012). We further note that claims such as ‘there have been profound changes in public attitudes towards disability, captured and catalysed by national moments such as the 2012 Paralympic Games’ do not represent the experiences of disabled people, especially in relation to discrimination and inequality. For example, there has been widespread discussion of the value of disabled and non-disabled lives during the COVID-19 pandemic (Williamson, 2020).

Importantly, the strategy recognises the inclusion of those with both visible and invisible disabilities (e.g., p17) and the value of a national campaign to increase awareness and understanding of disability and dispel current stereotypes (p29). Education focused on invisible conditions and fluctuating conditions etc is essential, with people with an invisible disability more likely to have their need for accommodations questioned. (e.g., Mills, 2017). Without this understanding, many disabled people will remain reluctant to use accommodations, fearing judgment and abuse. Similarly, the success of such educational campaigns will be limited without addressing harmful rhetoric elsewhere. For example, where disabled people are discussed in reference to benefit fraud or malingering rather than the difficulties accessing support and where discussions of COVID-19 strategy have repeated de-valued disabled lives.

We welcome discussions re the support available to disabled people but wish to emphasise the difficulties many people experience actually accessing this support (Roulestone, 2015). It is essential that systemic and structural issues are addressed in relation to the assessment of disability and that provision is available for those without diagnoses given that many disabled people may wait years for a medical diagnosis (e.g., Zwaigenbaum & Penner, 2018). Intersectionality and the additional barriers experienced by women, people of colour, and members of the LGBTQI community should also be addressed in relation to both experiences of disability and access to support (e.g., Mizock & Russinova, 2015).

Throughout the Strategy, a more systematic comparison between regions would be beneficial and facilitate sharing of best practice. For example, issues highlighted in relation to housing would benefit from a review of The Housing (Scotland) Act 2006 which enables local authorities to provide grants, loans, assistance etc to homeowners for improvements and adaptations etc. Further, the Strategy contains a large number of aims or targets and more detail re how these will be operationalised and evaluated is required. Without this detail, action will be limited. For example, we note that whilst this Strategy is available, the website states that the ‘Easy Read’, ‘large print’, and ‘Welsh translation’ versions of the Strategy ‘may not be suitable for users of assistive technology’ with people reliant on requesting the Strategy in an accessible format.

Housing

There is an emphasis on new housing, renting, and purchasing a first home. Given the relationship between age and disability, more attention is required focusing on adaptation of existing homes. Similarly, the review of housing must extend to other sectors ensuring that accessible accommodation is available at Universities, military bases, domestic violence shelters etc. Where new housing is built, all homes should be adaptable and accessible in order to create a fully inclusive environment.

The Strategy (p39) states ‘Landlords will be allowed to get tenants to pay for the work, in line with the Equality Act existing legislation. Tenants and residents, including those on low incomes or with disabled children, will be able to apply for a Disabled Facilities Grant.’ This approach could result in disabled people being required to pay for work without knowing if the grant will be approved. Similarly, it is unrealistic to expect disabled people to pay for work and then receive a grant at a later date given the financial difficulties experienced by many disabled people. 

Transport

The transport section does not cover accessibility at airports or underground railways. Additional issues such as pavement parking, the availability of public seating and toilet facilities, and the difficulties disabled people may experience (especially those with energy limiting conditions) when queuing or waiting should be also addressed.

Jobs

The Strategy does not discuss or reference the importance of Disabled Staff Networks, which provide social and practical support to members, advocate for organisational change, and provide opportunities to share good practice. The National Association of Disabled Staff Networks provide support for those wishing to establish or develop a Disabled Staff Network.

The Strategy discusses Disability Workforce Reporting, a Voluntary Reporting Framework including the potential utility of using a standardised question when asking employees about their disability status (p56). When formulating such questions, it is important to recognise that many disabled people do not identify as disabled (e.g., EDIS, 2022). This may reflect the belief that a condition is a different way of experiencing the world rather than an impairment, the stigma associated with the term disability, or the belief that one is not disabled enough or does not comply with the standard representation of disability which typically focuses on mobility or sensory impairments. It is important, therefore, that questions used to report disability are sensitive to these issues and that the large-scale underreporting of disability and the consequences of this are recognised. Further, we note that reporting is often the focus of initiatives, either in order to monitor the experiences of disabled people or to facilitate workplace accommodations. There is a substantial body of evidence which documents the inequalities and discrimination experienced by disabled people and action rather than reporting should be the focus. Similarly, whilst disclosure can facilitate workplace accommodations, embracing inclusive design ensures a more accessible environment regardless of disclosure and minimises the need for individual accommodations.

The role of Jobcentres is discussed in the Strategy together with the support available to those wishing to gain employment. At present there is a focus on the proportion of disabled people in paid employment. Greater support is required for disabled people in specific professions and there are opportunities for greater liaison with professional bodies. Ensuring opportunities are available for disabled people commensurate with their expertise and experience is of benefit both for the wider economy and also to challenge negative stereotypes that disabled people are less capable or competent than their non-disabled peers.

Issues such as flexible working and working from home are acknowledged. This flexibility is welcome, especially given the improved infrastructure (created during the pandemic) now available to support this type of working. This flexibility benefits a range of employees including disabled people and those with caring responsibilities. However, it is important to note that has been undermined by Government rhetoric elsewhere which emphasises a ‘return to the office’ and a consistent approach is required.

The Strategy plans to make ‘Jobcentres are engaging, welcoming, and expert’. It is unclear whether disability specialists will be available to deliver training and support (on both visible and invisible conditions) to ensure this occurs. Here (and elsewhere) it is essential that disabled people themselves are involved. We emphasise that for all aspects of the Strategy, there should be ‘Nothing About Us Without Us.’

For both Access to Work and Disability Confident, there should be greater recognition of the limitations of these schemes (e.g., awareness of Access to Work amongst employers and problematic timelines). Self-regulation of Disability Confident is especially problematic and consultation focusing on disabled peoples’ experiences of these schemes is essential.

For all areas of employment, the specific barriers experienced by those with different disability types should be recognised and addressed.

Education

With regards to Education, the need for additional SEND funding is acknowledged (p64). It is essential that Child and Adolescent Mental Health Services are also appropriately resourced to ensure that children, adolescents, and their carers are supported.

There is an emphasis on children and adolescents though disabled undergraduate and postgraduate students require support. Failure to consider disability in the context of Higher Education feeds into widespread assumptions that disabled people do not and cannot attend University (as a student or academic). Greater liaison with Higher Education Institutions and student led organisations (e.g., Disabled Students UK) would identify good practice within the sector and identify areas that require improvement. We also note that in academia, whilst Charters are available in relation to other protected characteristics (e.g., Athena Swan) no such Charter exists to monitor the experiences of disabled students, academia, and professional services staff. A specific disabled Charter is required to ensure parity with other protected characteristics and raise the profile of disability.

Shopping

Appointed by the Minister for Disabled People, Disability and Access Ambassadors are to “use their influence in business to encourage and support changes in access for both disabled consumers and employees.” (p77). This is clearly an important undertaking. It is, however, disappointing that these appointments are on a voluntary basis. Equality, Diversity, and Inclusion roles are often voluntary and in addition to a lack of financial compensation, such activity is not valued for career progression. As those engaged in Equality, Diversity, and Inclusion work are often from the marginalized groups they represent, voluntary roles can further hinder disabled people. Ambassadorial roles should be valued and appropriately compensated.

Gayle Brewer, Margaret Callander, and Emma Nadin on behalf of the National Association of Disabled Staff Networks

References

Equality, Diversity and Inclusion in Science and Health (2022). Diversity and Inclusion Survey (DAISY) Question Guidance – working draft (v2). Available at https://edisgroup.org/wp-content/uploads/2022/05/DAISY-guidance-current-upated-May-2022-V2.pdf

Mills, M. L. (2017). Invisible disabilities, visible service dogs: The discrimination of service dog handlers. Disability & Society, 32(5), 635-656. https://doi.org/10.1080/09687599.2017.1307718

Mizock, L., & Russinova, Z. (2015). Intersectional stigma and the acceptance process of women with mental illness. Women & Therapy, 38(2), 14-20. https://doi.org/10.1080/02703179.2014.978211

Roulestone, A. (2015). Personal Independence Payments, welfare reform and the shrinking disability category. Disability & Society, 30(5), 673-688. https://doi.org/10.1080/09687599.2015.1021759

Shaw, L. R., Chan, F., & McMahon, B. T. (2012). Intersectionality and disability harassment: The interactive effects of disability, race, age, and gender. Rehabilitation Counseling Bulletin, 55(2), 82-91. https://doi.org/10.1177/0034355211431167

Thomas, A. (2000). Stability of Tringo’s hierarchy of preference toward disability groups: 30 years later. Psychological Reports, 86(3), 1155-1156. https://doi.org/10.1177/003329410008600315.2

Williamson, H. (2020). Politicians are writing off disabled lives amid the pandemic. Foreign Policy, Available at https://foreignpolicy.com/2020/06/25/disabled-lives-coronavirus-pandemic-ableism/

Zwaigenbaum, L., & Penner, M. (2018). Autism spectrum disorder: Advances in diagnosis and evaluation. BMJ, 361. https://doi.org/10.1136/bmj.k1674

July 2022