Reasonable adjustments policy
1. Overview
We are committed to taking action to ensure that the way we work does not place people with disabilities at a disadvantage when accessing our service and making complaints.
2. Scope
This policy is for service users and summarises:
- our legal duties
- how we consider requests for reasonable adjustments, and the factors we will take into account
- the types of adjustment we will generally be able to make
3. Our legal duties
The Equality Act 2010 requires us to provide reasonable adjustments for people who are disabled. Under the Act this means they have a physical or mental impairment which has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities.
The duty is to make reasonable adjustments if the way that we carry out our functions places a disabled person at a substantial disadvantage compared to someone who does not have a disability. A substantial disadvantage is one which is more than minor or trivial.
The Equality Act 2010 doesn’t describe what is reasonable, but a Code of Practice published by the Equality and Human Rights Commission makes clear that it depends on factors such as:
- the effectiveness of the adjustment in preventing the disadvantage
- the extent to which it is practical to make the adjustment
- the cost of the adjustment and availability of resources, including external
assistance and finance - the extent of any disruption which the adjustment would cause
The Equality Act 2010 also doesn’t provide a set list of reasonable adjustments, as the adjustment will depend on the needs of different customers and the nature of the service provider. However, the Code of Practice explains the kind of adjustments that could be made. This is about making sure our service is accessible for customers with disabilities. However, it does not affect our duty to make decisions which are fair to all parties.
The duty is anticipatory. This means a service provider cannot wait until a person with a disability wants to use the service. They must think in advance (and on an ongoing basis) about what people with a range of impairments (such as people who have a visual or hearing impairment, a mobility impairment or a learning disability) might reasonably need.
We will do our best accommodate requests from customers, even if you do not have a disability as defined by the Equality Act 2010.
4. Requesting a reasonable adjustment
When you contact us, we will ask you if you might need an adjustment to help you use our service. We will record this information on our systems. But you can also ask for a reasonable adjustment at any time during our management of your complaint.
We will also suggest alternative or additional adjustments if we feel it might help you continue to make the best use of our service.
5. Our response to reasonable adjustment requests
Before agreeing an adjustment, we will consider factors which can include:
- what the disadvantage would be if the adjustment was not made
- whether the adjustment will be effective in reducing the disadvantage
- how practical it is to make it
- whether it would disrupt our other activities unreasonably
- the cost of making it and availability of resources, including external help and
finance - any other relevant factors, information
We will try to agree a reasonable adjustment with minimal delay. In some cases, we may need to consider the request in more detail.
We will look at each request individually and we will aim to agree any adjustments with you to avoid us making incorrect assumptions about your needs. Where we do not agree an adjustment, we will explain why. When we agree a reasonable adjustment, we will let you know using your preferred or agreed contact method. We will record the agreed adjustments on our systems; these will be visible to all customer-facing Housing Ombudsman Service staff.
6. Examples of adjustments we offer
Depending on the circumstances, reasonable adjustments we make could include:
- providing documents or correspondence in larger print, or with a specific colour contrast (which may help people with conditions such as dyslexia)
- contact by telephone rather than written communication
- translating documents or correspondence into Braille
- communicating with you through your representative or advocate
- arranging for a direct point of contact at the service
- providing access to ‘Easy Read’ versions of key documents
- if you use British Sign Language (BSL) we might provide you with an interpreter
- giving you more time than would usually be allowed to provide further information or comments on the complaint
7. Other actions we take
Other actions we take include:
- we publish this policy on our website
- we make published documents available in an alternative format on request
- we make sure that our staff are aware of their responsibilities
- we regularly review our casework to see if we are putting our commitments as set out in this policy into practice
8. Complaints about failure to provide reasonable adjustments
We hope that users of our service will be happy with the actions we take to make sure our service is accessible to all. But if you are unhappy with our response to any request for a reasonable adjustment, or with the reasonable adjustment provided, you can complain to us about this.
You can find out more about how to make a complaint online.
Revisions to the policy
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October 2024
Revised following external review
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August 2024
Removal of subjects not to be considered under Reasonable Adjustment policy
Revised due to complexity of previous version
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March 2024
ELT consultation
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Feb 2024
Additional consultation DMT (QED & DS/DR)
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Jan 2024
Amendments following consultation
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Dec 2023
Revised approach to reasonable adjustments
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May 2021
New policy published