Response to the Terms of Reference Consultation

Introduction

On 3 December 2009, the International Day of Disabled People, the Equality and Human Rights Commission (the Commission) announced its intention to conduct a formal Inquiry into the actions of public authorities to eliminate disability-related harassment and its causes.

On 18 February 2010 the Commission published the draft ‘terms of reference’. The terms of reference set out what the Commission proposed to look at in the Inquiry. The Commission then consulted with disabled people and other stakeholders to check that the Inquiry was focusing on the right areas. The consultation closed on 26 March 2010.

Who responded to the consultation?

The Commission received 68 online responses, 26 emailed responses, 8 postal responses and 1 telephone response from a wide range of individuals and organisations. More than 100 people attended one of four consultation events held in Swansea, Llandudno, Manchester and London.

What did individuals and organisations tell us?

The terms of reference were broadly supported by most people. There were a number of issues raised that the Commission needed to address, either through changes to the terms of reference or in other ways. The main findings were:

  • Most respondents agreed with the definition of disability-related harassment. Some people suggested changes to make it clearer what is covered, who might experience it and where.
  • Some respondents wanted a more ‘social model’ definition of disability to be used as the basis for the Inquiry.
  • Other respondents wanted recognition that some groups may not see themselves as disabled, such as Deaf people and people with mental health conditions.
  • Many respondents wanted the Inquiry to address issues of domestic violence, including that experienced by disabled men, either in the Inquiry or in other work by the Commission.
  • Many respondents wanted the Inquiry to address issues of workplace harassment, either in the Inquiry or in other work by the Commission.
  • Most respondents wanted the focus to be on the public sector. Many people thought that the role of the voluntary sector and, to a lesser extent, the private sector should be looked at too.
  • Some respondents wanted the terms of reference to be made clearer and more understandable using plain English.

What is different as a result of your input, and why?

Explanatory notes and examples have been provided to support the definition of disability-related harassment. The terms of reference now state that the scope of the Inquiry covers harassment by strangers, neighbours, acquaintances, friends, family, relatives and partners. Harassment may occur in public places, such as streets, parks, schools and leisure facilities. It also happens in private, such as in the home. Examples have been provided of the kind of incidents that would constitute disability-related harassment. This might be verbal abuse, such as derogatory, demeaning or humiliating remarks and name-calling, or physical assaults and murder. The Commission recognises that different groups of people will often use different language to describe an incident, including ‘bullying’ and ‘hate crime’. The terms of reference now explicitly state that bullying and hate crime come within the scope of the Inquiry.

There was overwhelming support for including the harassment of family, friends and associates of disabled people as well as conduct against a person who is perceived to be disabled. This will be included but disabled people’s experiences will be the main focus of the Inquiry’s attention.

Harassment by relatives, family and partners will be considered within the Inquiry. Many respondents to the consultation disagreed with the proposed exclusion of domestic violence from the scope of the Inquiry and pointed to the high incidence of violence experienced in the home by both disabled women and men. We thought you were right, so we will now cover this (see explanatory notes and examples above). In addition, the Commission’s strategy on tackling violence against women and girls may also address domestic violence against disabled women.

The diverse experiences and needs of disabled people related to their age, race or ethnicity, gender, religion or belief, gender identity, sexual orientation and impairment type will also be looked at within the Inquiry. This is now covered in an additional term of reference.

The Inquiry’s focus on public authorities remains in place. The Commission will also look at private and voluntary sector organisations operating in the public sphere, for example a charity or business that runs services for a local authority. It will inquire into the steps taken by public authorities to prevent as well as eliminate disability-related harassment, and look at whether public authorities work together to do this. Police, schools, local councils, social housing providers and health providers were seen as some of the most important public bodies to focus on, though many thought that all public authorities were equally important.

Public transport was identified as a ‘hot spot’ for disability-related harassment. An additional term of reference will look at the steps taken by public transport operators to prevent and eliminate disability-related harassment on or around public transport.

Plain English, as far as possible, has been and will be used throughout. Examples are also provided where helpful.

What has not changed and why?

The Disability Discrimination Act and its definition of disability remains the basis for the Inquiry. We understand the importance of the social model of disability, but we are using the DDA definition to ensure we can hold public bodies to account in relation to their legal responsibilities. The law was changed in 2005 so that the legal definition of disability includes people with recurring or fluctuating conditions such as HIV, cancer and multiple sclerosis from the point of diagnosis. It also includes people who may not define themselves as disabled, including Deaf people and people with mental health conditions.

The Commission recognises that workplace harassment is an important issue and it is one that we take very seriously. We have taken the very difficult decision to exclude workplace harassment from the Inquiry. This is most certainly NOT because we do not think it is important. We know it is, not least because stakeholders told us so. But the decision was taken ultimately for the following reasons:

  • the original purpose of the inquiry is to find out what public authorities are doing to eliminate prevent harassment. Different laws apply to public authorities in respect of this general responsibility;
  • the EHRC has limited resources, and that also means that this formal inquiry has a fixed budget. We want to make sure that this inquiry delivers meaningful results, and makes a real impact, on the issues it is trying to address. If we included employment as well, that would significantly extend the scope of the inquiry and increase the risk that we could not deliver properly;
  • people experiencing harassment in the workplace already have special laws and protections against such treatment, and clear avenues for redress if they are not treated fairly. We would be happy to work with others to promote understanding and awareness of these rights;
  • ultimately employment is just one specific place where disability related harassment can occur. The purpose of this Inquiry is to help identify some of the fundamental reasons why disability related harassment happens in the first place, and seek to eliminate it. If we can change society's attitudes generally, that will help disabled people in all settings.

In addition, during 2010/11 the Working Better programme will review the evidence around workplace harassment of disabled people. On the basis of the Working Better review and emerging lessons from the Disability Harassment Inquiry, the Commission will scope what further action to take to address workplace harassment.

Discrimination by public bodies, such as a refusal to provide services or inadequate service provision, will not be covered in this Inquiry. It will be dealt with by the Commission’s work on the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD).

You can find out more about the Commission’s work on the UNCRPD by visiting our website

www.equalityhumanrights.com/UNCRPD
 

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