SIX TOWN HOUSING, REASONABLE ADJUSTMENTS POLICY
Author: Adam Greenhalgh
Date Approved 15th December 2022
Next review: October 2025 – every 3 years
Document Reference Number NBPO005
Six Town Housing are committed to ensuring that disabled people are not disadvantaged in accessing our services.This policy is intended to provide guidance on meeting individual needs covered by the Equality Act (2010) through offering appropriate adjustments. It is also to ensure we continue to deliver high standards in customer service, meet customers’ needs and align these standards with those set out in our Equality and Diversity and Inclusion Framework.
This policy does not explain how we will approach every situation; it will do the following: -
1. Confirm our commitment to improving accessibility for all of our customers
2. Set out the principles of our commitment to provide reasonable adjustments for customers who require them
3. Details what factors we will take into account when dealing with requests for reasonable adjustments
4. Explain how customers can appeal if they do not agree with Six Town Housing’s decision relating to their circumstances
2.0 SCOPE / LEGAL REQUIREMENTS
As a provider of services to the public, Six Town Housing has a legal duty to ensure that customers are not prevented from using our services because they have a disability.
Under the Equality Act 2010, the duty to make reasonable adjustments falls into three areas:
1. When changing a policy, procedure, or any standard practices
2. Where a physical feature puts a disabled customer at a substantial disadvantage in comparison with customers who are not disabled
3. Where a disabled person, without the provision of an additional aid or service, would be put at a substantial disadvantage in comparison with customers who are not disabled
Substantial disadvantage is defined in the Equality Act 2010 s.212(1) as ‘more than minor or trivial’
3.0 WHAT IS A REASONABLE ADJUSTMENT?
A Reasonable Adjustment is a legal term described in the Equality Act (2010). It means that Six Town Housing have a duty to make reasonable adjustments where it’s working practices (including policies and procedures), or physical premises put a disabled customer at a substantial disadvantage in comparison with customers who are not disabled.
It is not possible to produce an exhaustive list of reasonable adjustments since an adjustment can only be determined as reasonable or not in relation to a specific set of circumstances.
However, the Equality Act’s Code of Practice suggests that, when deciding whether an adjustment is reasonable, the following issues should be considered:
1. The effectiveness of an adjustment in preventing or reducing the disadvantage for the disabled person – for example, the adjustment should be designed to fully address the disadvantage it is meant to overcome
2. The practicability of the adjustment – for example, it may not be necessary or practical to have a wheelchair accessible toilet on every floor of an office, providing that at least one such toilet is available to wheelchair users
3. The financial and other costs of any adjustment – for example, if a customer requests higher specification of an aid or adaptation than the standard item issued, as long as the standard item will perform the same task – it may be reasonable to refuse on grounds of cost, provided the alternative is suitable
4. The extent of the disruption caused – for example, it would not be practical for a staff member to devote all of their time to one customer, as other customers would inevitably suffer
5. The availability of financial or other assistance – for example, a grant for funding may be available to supplement any adjustment needed
4.0 ADJUSTMENTS THAT WILL BE CONSIDERED
Six Town Housing is committed to maintaining a high standard of accessibility to our services for all customers we come into contact with. We should therefore ensure our approach embraces all customers who have a mental or physical impairment as defined by the act as follows:
“If he or she has a physical or mental impairment, and the impairment has a substantial and long-term adverse effect on his or her ability to carry out normal day-to-day activities (S6(1))”
The following examples would be covered by this definition (this list is not exhaustive);
1. Providing additional support for customers with communication or learning difficulties
2. Providing additional support for customers who need it due to a physical or emotional infirmity, or those with mental health conditions
3. Providing additional support for customers with sensory impairments, such as those which affect sight or hearing
Whilst it is not possible to list all such circumstances, below is a list of some examples:
1. Providing translation or interpreting services for customers whose first language is not English.
2. Providing additional support for customers with literacy problems.
As a general rule, Six Town Housing staff should follow the following guidelines.
1. Ask – don’t assume. Remember that many disabilities or special needs are not necessarily visible or obvious. Therefore, we should ask our customers routinely whether they need additional support. We don’t need to be intrusive –we should explain how we would normally deal with an issue the person has raised and then ask: “Do you need any additional support, for example because of a disability or other special circumstance?” That leaves the way open for the person to tell you as much or as little as he or she chooses about the circumstance whilst still requesting the support they need.
2. Listen. Most customers with disabilities or special needs will know what support they need and will tell you how you can help them. Try to meet their request where it is reasonable to do so.
3. Be flexible. Customers in similar sets of circumstances may have different needs or requests – just because people have a similar disability, it does not mean that they will require the same support.
We want to learn from our customers and the service we provide, as a result where reasonable adjustments are requested or made, we will record and monitor those. This will help us to identify the effectiveness of those adjustments and whether the customer suffered any detriment because of poor considerations. This will in turn help us to review our service.
We are committed to provide a high standard of service, dealing with everyone in a way that is fair and free from discrimination. If someone is dissatisfied with the arrangements, we have made for providing reasonable adjustments, we will respond in accordance with our complaints policy.
Our Complaints policy can be viewed by visiting the ‘Complaints and Compliments’ section on our website.
If necessary, when reviewing our decision, we will seek advice from specific expert disability groups or seek legal advice.
This policy will be reviewed every 3 years unless there are changes to legislation, regulation, best practice, or a business need.