Weekly Poll – Public Sector Equality Duty: Inclusive Communication (Week Beginning 7 March 2022)

Each week Disability Equality Scotland send out a poll question to our members on a topical issue. For the week beginning 7 March 2022, we asked a question about the review of the Public Sector Equality Duty in Scotland.

Results

Question. Do you support the actions that are being proposed to support public bodies with a new duty to embed inclusive communication across their work?

  • Yes – 98% (206 respondents)
  • No – 2% (4 respondents)

Comments

We provide verbatim comments where appropriate to illustrate strength of feeling or personal experience.

Inclusive Communication

Within the Equality Act 2010 sits the Public Sector Equality Duty (PSED), which is a duty on public authorities such as an NHS hospital, a state school or the police to embed and promote equality throughout their processes. The Scottish Government is currently reviewing the PSED in Scotland.

One of the key proposals featured in the review of the PSED is to create a new duty to ensure that inclusive communication is embedded across the work of public authorities when they are communicating with the public. Inclusive communication means recognising, respecting and using all forms of communication – not just the written and spoken word.  For example,

  • Some people may require the support of a British Sign Language interpreter or an electronic note taker
  • Some people may require information in alternative formats, such as audio, Easy Read or large print

An overwhelming 98% (206 respondents), agree with the proposed actions to support public bodies in meeting a duty on inclusive communication. Respondents commented on the importance of receiving information and communication support in a format that matches their communication strengths and preferences. By doing so, this can ensure that disabled people are not excluded.

“All forms of communication should be equal, whether it be BSL or braille or Easy Read, or opening-up email consultation for people who struggle to make phone calls. Far too many local services still respond to emails with ‘could you please call (phone number) so we can follow up and sort out this issue’ or similar sentiment. The spoken word is still very much privileged over alternatives currently.”

“A requirement to provide clear and multi format communication is long overdue. How can we leave no one behind is we don’t use inclusive communication to keep everyone informed?”

“Public bodies have been providing information in different languages for some time now and have been able to access interpreters via telephone links when talking to people who don’t understand English. At the same time however, many other people have been overlooked or forgotten about or they may think that way. An example of this people who are deaf and use BSL often find they can’t actually access an interpreter when they are in places like hospital, council offices or trying to talk to elected officials.”

“I have been fighting my local authority for the last 20 years to receive correspondence in an accessible format with no success, so I welcome this.”

“It helps to have everything in ‘plain speak’ rather than jargon used internally by departments. What seems easy to the writers is not necessarily easy for the reader, such as coloured printing and dyslexia!”

Easy Read

Respondents shared specific comments on the importance of providing information in Easy Read, an accessible format that makes written information easier to understand because it uses simple, jargon-free language, shorter sentences and supporting images.

“This is so badly needed – I need Easy Read just to be able to function. Not being able to get it affects every aspect of my life.”

“I often feel excluded because I rely on Easy Read, which is not always available. I need Easy Read.”

“I want to see all government consultations and publications made available in Easy Read versions for all formats. How can we call this a truly democratic process when policy is decided by a privileged few.”

“Accessible information must include Easy Read documents, especially, in legal and threat of liberty cases. Police (especially arrest, where rowdiness of someone with learning difficulties is an issue), Courts, Mental Health, Social Work etc”

“I need Easy Read and when I ask it’s not always available. It should be available as standard.”

At Disability Equality Scotland, we have the expertise to convert information into Easy Read. Our professional and efficient Easy Read service is delivered to all sectors as part of our commitment towards improving access to information for all. In addition, we deliver an Easy Read training course which aims to give individuals and organisations the skills and knowledge to produce basic Easy Read documents. The course is delivered through a series of online modules designed to allow participants the opportunity to challenge existing knowledge, to explore practical examples, to experience converting complex document content and to reflect upon and evaluate the process. Further details of the Disability Easy Read translation service and Easy Read training course, can be found at: www.disabilityequality.scot/easy-read

Support

In the consultation, the Scottish Government outline the following actions to support public bodies with embedding inclusive communication in their processes.

  • Provide a clear definition of what communicating in an inclusive way means
  • Work in partnership with other public bodies, stakeholders and people with lived experience, to co-produce a set of national standards
  • Assist public authorities to prepare for the proposed new duty on inclusive communication coming into force by developing best practice guidance and shared resources for public bodies on inclusive communication
  • Require public authorities to report on how they have met this duty

 

Education

Some respondents questioned the existing levels of knowledge and awareness of inclusive communication amongst public bodies, therefore highlighting the importance of developing a widely recognised definition and set of standards. In addition, it is vital that best practice guidance and resources are shared with public bodies to assist with meeting the requirements of the proposed duty.

“Clear guidance for public bodies is key here, in terms of what constitutes inclusive communication and what communications / publications etc should be issued in these formats (i.e. should it be every publication, or just certain ones? How is this decided?).”

“Yes, I do support this proposal in principle, but it has one major flaw, emission and serious blockage to effective communication by any means – that of education! Unless the referred to public bodies are educated in the nature of disabilities and effects of disability on people both physically and mentally there is no point in improvements in any kind of communication! Also, people in the so-called public bodies need to be educated in order to be aware of the impacts and consequences of their communication and essentially their miscommunication and the barriers that they consequently create, not to mention the unnecessary stress and distress that their lack of knowledge and education creates.”

“There are plenty resources out there already, so these must be highlighted with public bodies.”

At Disability Equality Scotland, we host the Inclusive Communication Hub, (www.inclusivecommunication.scot), a website that features resources, and good practice guidance to help improve knowledge and awareness of inclusive communication across Scotland. The Hub also features a series of case studies, which provide practical examples of how organisations can adopt inclusive communication in their ways of working and general day-to-day communications. An up-to-date blog signposts to the latest inclusive communication news, events, and training. The Hub is a vital resource that can be utilised by public authorities to educate staff and assist with embedding inclusive communication in their processes.

Staff Capacity

A portion of respondents believed that public bodies would require additional staff resources in order to meet the new duty in inclusive communication. There was also recognition that the duty may result in increased demand on third sector organisations who provide communication support services, including converting information into various accessible formats, such as Braille, British Sign Language and Easy Read.

“Public bodies will need to increase staff capacity (i.e. hire new staff) in order to meet these obligations, as producing multiple versions of publications is beyond the current workload capacity for many teams. The requirement will be placed on already overloaded staff teams and individuals.”

As a disabled person who manages a team in a public body (a Scottish university), I foresee many quality and compliance issues relating to the provision of inclusive communication if public bodies (such as universities) do not commit significant resource to meet this requirement.”

“I’m not so sure about how support will be resourced.”

“Charities are an important third sector resource that the government uses to back-fill gaps in service provision. These also need to be included in this and receive proper funding and training to do so.”

Compliance

Respondents commented on the need for effective monitoring procedures to ensure that public bodies are compliant with a new duty on inclusive communication.

“Hopefully it will be fully implemented and audited to make sure public bodies comply with this area of the PSED.”

“If inclusive communication is to be introduced, enforcement is also going to be one of the most important factors to ensure compliance.”

“I’ve long been a public sector worker and trade union rep, and have fought many a case, including my own as a disabled worker, to ask for rights that ought to be there all the time because of the PSED. It’s often a box-ticking exercise rather than a genuine intent to make access and inclusion a reality.”

“It will be the same old story, more and more disability equality law, but no enforcement. All laws of this kind are useless if they cannot be enforced in the courts. A much better way to tackle inequality is for legal aid to be available for enforcing present laws.”

Some respondents believed that public bodies should already be meeting various requirements related to inclusive communication under existing equality law.

“I’m not sure if it will work as the Equality Act says a lot of this should be done anyway but there is a lack of knowledge about accessible communication across all government organisations. Another set of procedures and guidance isn’t going to make people comply when they don’t anyway.”

“When the basic equalities act isn’t followed why will this?”

“I noticed in the consultation that even with this proposal the implementation is still 3 years away. This needs to be happening now. Communication needs to be inclusive for all.”

Conclusion

The vast majority of respondents (98%) fully support proposals to embed inclusive communication across the public sector in Scotland. Disabled people reflected on the importance of receiving information and communication support in a format that matches their strengths and preferences. There was recognition of the need for public bodies to be provided with clear a definitions, standards and guidance on how to help meet a new duty on inclusive communication. At Disability Equality Scotland we host the Inclusive Communication Hub (www.inclusivecommunication.scot) a website that can be utilised by public bodies to raise awareness of relevant information and best practice guidance. We also provide an Easy Read translation service and deliver an Easy Read training course, both of which can assist public bodies with meeting the requirements of the new duty on inclusive communication. In order for a new duty on inclusive communication to be effective, there must be clear procedures in place to monitor compliance. Some respondents believed that inclusive communication procedures should already be implemented based on existing equality law.