Written evidence from the Royal Association for Deaf people (RAD) (DEG0100)

About us

Since 1841, the Royal Association for Deaf people (RAD) has worked to ensure that deaf people have access to services in British Sign Language (BSL).

Through our Deaf Advance programme, we provide career advancement and training for deaf people, breaking down barriers to employment and career progression. This includes careers advice and support, employment information, management training and employer engagement. We also provide deaf awareness training for employers and businesses.

Summary of key recommendations

• There is a desperate need for appropriate and tailored careers advice for young deaf people, which should be provided by specialist organisations, in BSL.

• Greater deaf awareness training is needed for employers of all sizes, and Jobcentre Plus staff.

• The Office for National Statistics (ONS), together with national and regional employment bodies, must look at ways of adequately capturing employment data on deaf BSL users specifically.

Progress so far and impact

What progress has been made, especially since 2015, on closing the disability employment gap? How has this progress been made?

1.1.            According to the National Deaf Children’s Society (NDCS), deaf people are twice as likely to be out of work as their hearing peers.[1]

1.2.            Data from the same report also shows that young deaf people are particularly affected, with 18-year-old college students in England 30% less likely to move into employment compared with young people without a disability. Moreover, this research has highlighted a lack of appropriate support for young deaf students, including the absence of specialist careers advice, in BSL.

1.3.            Our own research supports these findings, and we concur that deaf people’s experiences of employment is generally a negative one. For example, according to a recent survey of ours:

• Only a quarter (25%) of deaf people said they had access to careers advice in BSL when they were at school

• Over half (60%) said they had not been given progression opportunities during their career

• Nearly two-thirds (63%) said they had encountered barriers to career progression

• 63% also felt they had not been given equal opportunities in the workplace

• Just over half (53%) did not feel supported at work[2]

Lack of deaf awareness amongst employers, and low expectations of deaf employees, were also cited as key barriers to securing, and thriving in, employment.

1.4.            This, together with other data from the sector, suggests there remain significant barriers for deaf people with regards to employment; both in terms of seeking, and progressing in, work.

1.5.            More and better careers advice and guidance is needed for deaf people of all ages, but particularly young deaf people; and this advice needs to be provided by specialist organisations, in BSL.

1.6.            Greater deaf awareness training is needed for employers of all sizes, but especially larger employers and businesses that should set an example to others. More examples of best practice are needed to show how employers can meet the needs of deaf employees, and the requirements of the Equality Act 2010.

1.7.            Better promotion and awareness raising of Access to Work is needed amongst employers, careers advisors and young deaf people.

1.8.            There is a significant lack of data on the employment experiences of deaf BSL users specifically. The Office for National Statistics (ONS), together with national and regional employment bodies, must look at ways of adequately capturing such data in future.

What is the economic impact of low employment and high economic inactivity rates for disabled people? Are some disabled people (for example, young disabled people or people with different health conditions) more at risk of unemployment or economic activity than others?

2.1.              We are not aware of any statistical information that suggests deaf people are more likely to be at risk of unemployment than other communities, or disabled people in general. However, there is significant evidence that shows deaf people are at a particular disadvantage in terms of accessing the labour market in the first place (which could in turn increase the likelihood of unemployment or economic inactivity). For instance:

• The reading age of deaf students leaving school is below the national average[3]

• On average, deaf children have achieved an entire grade less than their hearing peers at GCSE level for at least the past 5 years[4]

• Deaf people whose main language is BSL are more likely to have no qualifications[5]

2.2.              The combination of poor literacy rates and under-qualification, in addition to the absence of appropriate careers advice, creates a perfect storm for deaf people trying to access the labour market.

2.3              Anecdotally, we have seen the impact that this has on deaf people. The combined effect of leaving school with poor literacy rates, a lack of careers advice and few qualifications often results in many deaf people struggling to find work until they are well into their 20s or 30s. We have witnessed this first-hand through our employability services, where it is not uncommon for us to support deaf clients in their early 30s to secure their first job. This late entry to the labour market is a direct result of deaf people being held back at school and means that, for many, their employment journey begins much later in life.

2.4.              The economic costs of deaf people’s challenges with labour market access are unknown, but likely to be significant. The health and wellbeing impact that this has on deaf people, and the associated costs for the NHS and wider economy, however, is clearer. For instance, we know that deaf people are twice as likely to experience mental health difficulties,[6] and that disabled people are more likely to experience loneliness than non-disabled people.[7] With the negative impact of loneliness calculated at £9,900 per year per each afflicted person[8] – and the established links between unemployment and poor mental health – it would be reasonable to assume that the economic and health costs of deaf people being excluded from the labour market for longer are likely to be sizeable.

2.5.              We recommend that basic BSL courses be made available to all deaf people from a young age, and that pupils have access to specialist careers advice, in BSL.

What has been the impact of the coronavirus pandemic on disabled peoples’ employment rates?

3.1.              We are not aware of any figures for deaf people specifically. However, in general terms, it has been our experience that the DWP has altered its commissioning behaviour in response to the pandemic, with contracts for employability support programmes more likely to be commissioned to ‘primes’, with smaller, specialist organisations missing out. Additionally, as a result of the pandemic a number of specialist support programmes have been put on hold, adding to the detriment of deaf people who urgently need employment support.

Providing support

Where should lead responsibility for improving disabled peoples’ employment rates sit (for example, DWP; Business, Energy and Industrial Strategy; Health and Social Care)?

4.1.              As the main provider of employment support schemes and programmes for deaf and disabled people, the DWP is well placed to deliver and implement this policy on the ground. However, employment is a cross-cutting issue, with education, higher education, health, and wellbeing all playing a part: the domains of various different government departments. We would therefore suggest that, as a cross-departmental issue, responsibility for improving disabled peoples’ employment rates should ultimately sit within the Cabinet Office (specifically, the new Disability Unit) – who should have strategic oversight of this objective – and that this policy forms a central tenet of the upcoming National Strategy for Disabled People.

How can DWP better support employers to take on and retain disabled employees, and to help them progress in work? How effective is the Disability Confident scheme?

5.1.              “Greater deaf awareness amongst employers” was one of the central messages to come out of our survey. Having staff, at all levels of an organisation, who are educated and knowledgeable about deaf culture, is of critical importance to deaf employees. It follows that staff who have had deaf awareness training are likely to be more understanding, positive and encouraging towards deaf colleagues, which is important given that many deaf employees suffer from low self-confidence.

5.2.              Employers must also ensure that their policies and practices are accessible. For example, many of our survey respondents said that a failure to make reasonable adjustments (e.g. a prospective deaf employee not being able to call up an employer to ask for further information regarding a role) – and a lack of awareness of a deaf employees’ communication needs (e.g. not providing a BSL interpreter for a meeting, or being unaware of the Access to Work scheme) – created the most significant barriers to career progression.

5.3.              Some respondents also highlighted the inaccessibility of networking and socialising events as a key barrier to progression; aspects that they deemed instrumental to the success of hearing peers who had managed to climb the ladder.

5.4.              Deaf people also cited a lack of deaf role models in work, and the absence of peer mentoring schemes, as obstacles to in-work progression.

5.5.              Support for deaf employees must not cease, or ease off, upon employment: a pathway and package of support must be provided throughout a deaf employees’ journey.

5.6.              The Disability Confident scheme is a welcome initiative, and it has led to many improvements in the accessibility of employment practices: to this end, it should be commended. That said, we believe much more needs to be done to ensure the scheme does not fall into the trap of becoming a ‘tick box exercise’, devoid of meaning. There is also a question mark over the extent to which small employers, and the private sector, are aware and able to access the scheme (e.g. our own internal analysis of the Government’s list of approved Disability Confident employers suggests that take-up is high in the public and voluntary sectors, but less so in the private sector). Further, we would like to see a greater emphasis placed on deafness in future, and for the needs of deaf employees to be made more explicit.

What improvements should DWP make to the support it offers to unemployed disabled people via Jobcentre Plus?

6.1.              In our extensive experience of dealing with Jobcentre Plus, we continually come across two main barriers:

• A lack of deaf awareness amongst work coaches (and an almost total absence of specialist deaf advisors).

• A frequent failure to provide BSL interpreters for meetings with deaf clients, and to record a deaf clients’ communication needs.

6.2.              Greater deaf awareness training is urgently needed for Jobcentre Plus work coaches – many of whom appear to be totally unaware of deaf people’s communication needs. Furthermore, Jobcentre Plus need to employ more specialist deaf advisors and/or outsource this work to specialist deaf organisations, in order to achieve positive employment outcomes for deaf people.

The coronavirus pandemic continues to make it difficult to offer in-person support. What evidence is there of “best practice” in supporting disabled people remotely—either in or out of work?

7.1.              Like many organisations, our employment support offer has switched to remote delivery during the pandemic. This has had some notable benefits, such as the ability to provide advice and support at short notice, and to respond to last-minute requests.

7.2.              However, there remain many challenges with the switch to remote delivery, which does not work for everyone. For instance, those furthest from the labour market are also likely to be those who lack IT competencies and access to remote technology. For deaf people, in particular, there are also barriers when it comes to attending a remote job interview, for instance (e.g. employers failing to provide a remote BSL interpreter).

7.3.              Whilst there are some clear benefits to remote services, it is crucial that remote delivery does not replace face-to-face provision, upon which many deaf people heavily rely.

How can DWP put this into practice in services such as Access to Work and the Work and Health Programme?

8.1.              There have been significant problems with the switch to remote DWP services (e.g. Access to Work claim forms initially requiring a wet signature from a deaf employee/their employer, despite employees being asked to work from home).

8.2              The advent of remote working provides an opportunity for DWP to improve some of its existing policies and practices, including the development of a centralised, online system for Access to Work applications.

Enforcement and next steps

Are “reasonable adjustments” for disabled people consistently applied? How might enforcement be improved?

9.1.              As mentioned, there are many examples of deaf people being let down by an employer failing to make reasonable adjustments. We have already provided some solutions, including deaf awareness training. Employers should also be reminded of the ‘anticipatory’ element of the Equality Act 2010, which requires employers to anticipate any reasonable adjustments that might need to be made (rather than considering this at a later stage, or worse, as an afterthought).

9.2              Employers must be responsible for adhering to the Equality Act at all times and making reasonable adjustments where needed. However, self-regulation/enforcement is not enough on its own, and so we recommend that a review/auditing process be built into the Access to Work scheme, either provided by Access to Work/DWP itself, or outsourced to a professional equalities auditor.

What would you hope to see in the Government’s National Strategy for Disabled People?

10.1              All of our above recommendations are issues that we would like to see raised in the forthcoming National Strategy for Disabled People. We would also, more specifically, like to see the Government move away from talking about “disabled people”, which assumes disabled people to be a homogenous group, and to look at the needs of specific groups and communities e.g. the deaf community.

How should DWP look to engage disabled people and the organisations that represent them in formulating the Strategy?

11.1              There are several ways in which the DWP can engage disabled people successfully. Our suggestions (though not exhaustive) include:

• Engaging with smaller, grassroots and specialist organisations;
• Ensuring any consultation process, or event (e.g. roundtable/focus group), is accessible to all groups e.g. BSL provision for deaf individuals;
• That the DWP taskforce/steering group responsible for overseeing this engagement process is representative of disabled people from all communities;
• That the DWP places emphasis on the importance of capturing lived experience;
• That the process be co-produced, with deaf people directly informing and feeding into the strategy (and included at the very beginning of the process)

December 2020