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Disability action plan

24 August 2018

Introduction

This Disability Action Plan (DAP) represents the Tertiary Education Quality and Standards Agency’s (TEQSA’s) commitment to the inclusion, support and engagement of people with a disability. The DAP aims to promote the equitable participation of our staff with a disability in the workplace and to remove barriers and provide improved access and services to people with a disability.

TEQSA’s Disability Action Plan will focus on the following four key priority areas:

  • Physical Accessibility
  • Technological Accessibility
  • Employment
  • Communication and Community Engagement

This DAP has been developed in accordance with the provisions of the Disability Discrimination Act 1992 (the DDA) and is informed by the National Disability Strategy 2010–2020. 

Who we are and what we do

TEQSA is Australia’s independent national regulator of the higher education sector. The Australian higher education sector comprises both public and private universities, Australian branches of overseas universities, and other higher education providers with and without self-accrediting authority.

Under the TEQSA Act, the functions and powers of TEQSA include:

  • registering regulated entities as registered higher education providers
  • accrediting courses of study
  • investigating whether the TEQSA Act or its associated provisions have been or are being complied with, including by:
    • conducting compliance assessments and quality assessments
    • conducting accreditation assessments of accredited courses.

Our values

TEQSA exercises its functions in line with the following values:

Professional

  • we take pride in the nature and quality of our work
  • our actions and decisions are considered and evidence-based
  • we acknowledge our three basic principles of regulation and work with providers based on necessity, proportionality and reflected risk 
  • we act with integrity and are open and transparent.

Enterprising

  • we are innovative in our work and seek continual improvement
  • we collaborate and engage with stakeholders to achieve positive outcomes
  • we are forward thinking in our work as we identify opportunities and risks and take appropriate action
  • we achieve consistent, practical and timely results.

Accountable

  • we take responsibility for our actions and the results of our actions
  • we are prepared to make difficult decisions when required
  • we respect and care for our colleagues and work together as one TEQSA
  • we are consistent, we understand the role, value and importance of the Higher Education sector.

Knowledgeable 

  • we are at the forefront of our field and aim to exceed expectations
  • we provide leadership and encourage continual learning and development of our people 
  • we capture and share our personal expertise, knowledge and experiences
  • we are building productive relationships both within and outside Australia with the aim of becoming a global leader in Higher Education regulation.

Legal and policy context

Disability Discrimination Act 1992 (DDA)

The Commonwealth DDA makes discrimination against people with a disability unlawful in particular areas of public life, including employment, the administration of Commonwealth laws and programs, provision of goods, services and facilities, and access to premises.

Section 4 of the Act provides a definition of disability as:

  • total or partial loss of a person’s bodily or mental functions; or
  • total or partial loss of a part of the body; or
  • presence in the body of organisms causing disease or illness; or
  • presence in the body of organisms capable of causing disease or illness; or
  • a disorder or malfunction that results in the person learning differently from a person without the disorder or malfunction; or
  • a disorder, illness or disease that affects a person’s thought processes, perception of reality, emotions or judgement or that results in disturbed behaviour;

and includes a disability that:

  • presently exists; or
  • previously existed but no longer exists; or
  • may exist in the future (including because of a genetic predisposition to that disability); or
  • is imputed to a person.

All disabilities are covered whether they are categorised as physical, intellectual, psychiatric, sensory, neurological or learning disabilities.

Under the DDA disability discrimination can be both direct and indirect.

Direct disability discrimination occurs when, because of a person’s disability, another person treats or proposes to treat the person with a disability less favourably than in circumstances that are the same or are not materially different than they treat or would treat a person without a disability.

Indirect disability discrimination occurs if a person with a disability is required to comply with a requirement or condition:

  • with which a substantially higher proportion of persons without a disability comply or are able to comply
  • which is not reasonable having regard to the circumstances of the case
  • with which the aggrieved person does not or is not able to comply.

Disability action plans 

The DDA states that departments/agencies/service providers may develop action plans to eliminate discriminatory practices (Part 3 s60).

Sections 60 and 61 of the DDA set out provisions for the completion of Disability Action Plans. The DDA specifies that an action plan must include:

  • the creation of policies and programs that are consistent with the objects of the DDA; and
  • a process for communicating these policies and programs to persons within the agency; and
  • the review of practices by the service provider with a view to the identification of any discriminatory practices; and
  • the setting of goals and targets by which the success of the plan in achieving the objects of the DDA can be assessed; and
  • an evaluation approach; and
  • a nominated person/s responsible for implementation of the plan.

National Disability Strategy

The National Disability Strategy 2010-2020 was developed by the Commonwealth, State and Territory Governments in partnership through the Council of Australian Governments. The Strategy represents a unified national approach with a shared vision for “an inclusive Australian society that enables people with disability to fulfil their potential as equal citizens.” It sets out a ten-year plan for improving the lives of people living with disability, their families and carers. Importantly, the Strategy will guide public policy across governments so that people with disability can participate as equal citizens in all areas of Australian life.

United Nations Convention on the Rights of Persons with Disabilities

In 2008, Australia ratified the United Nations Convention on the Rights of Persons with Disabilities. The Convention aims to enhance opportunities for people with a disability to participate in all aspects of social and political life including access to employment, education, health care, information, justice, public transport and the built environment.

Development and implementation

TEQSA’s Disability Action Plan has been developed by a working group within TEQSA in consultation with staff and management. The DAP has been informed by the DDA, the National Disability Strategy 2010-2010 and the United Nations Convention on the Rights of Persons with Disabilities. 

Once approved, the revised DAP will be made available on TEQSA’s intranet and external website. Information about the DAP will also be incorporated into the induction training for new staff.

The DAP will be reported in TEQSA’s annual report and registered with the Human Rights and Equal Opportunity Commission. It will also be made available to interested parties on request.

Monitoring and review

The Senior Management Team (SMT) will monitor the progress of the DAP against the performance measures every six months. Results will be reported in TEQSA’s annual report. The plan will also be reviewed every three years, or earlier if required, to set new action measures where appropriate.

Document information
 

Title

Disability Action Plan

Category

Operational policy

Audience

Staff and visitors to TEQSA and the TEQSA website

Policy owner

People and Capability

Version

2

Effective date

August 2018

Review date

2020 (in conjunction with the National Disability Strategy)

Approval

Anthony McClaran on 8 August 2018

TEQSA’S action measures

Physical accessibility

TEQSA aims to ensure that people with a disability have access to TEQSA premises.2

What we will do

Who will do it

Timeframe

Measure

  • Conduct audit to identify any physical and infrastructural barriers to accessing TEQSA’s office for people with disabilities
  • Work Health and Safety Committee
  • August 2018
  • Physical and infrastructural barriers identified and Management notified
  • Develop information sheet for visitors about access to TEQSA
  • People and Capability
  • August 2018
  • Access Information Sheet developed
  • On request, provide Access Information Sheet to visitors prior to arrival
  • All staff
  • Ongoing
  • Access Information Sheet provided to visitors prior to arrival on request
  • Develop Emergency Procedures Information Leaflet which includes information for visitors with disabilities
  • TEQSA Floor Warden
  • Completed December 2013
  • Emergency Procedures Information Leaflet developed, which includes information for visitors with disabilities

Technological accessibility

TEQSA aims to ensure that all its technological information is accessible to people with a disability.

What we will do

Who will do it

Timeframe

Measure

  • Investigate, in consultation with the Department of Industry, Innovation, Climate Change, Science, Research and Tertiary Education and other Commonwealth agencies, approaches to assessing and complying with Web Content Accessibility Guidelines (WCAG) 2.0
  • Engagement Group
  • Completed November 2017
  • Investigations completed and recommendations made to Senior Management Team
  • TEQSA website meets Level AA (WCAG) 2.0 compliance
  • Engagement Group
  • Completed November 2017
  • TEQSA meets WCAG 2.0 Level AA

Employment

TEQSA aims to foster a workplace that is inclusive of people with a disability and promotes equitable participation.

What we will do

Who will do it

Timeframe

Measure

  • Promote the Disability Action Plan on intranet and in staff induction
  • Engagement Group and People and Capability
  • In practice and ongoing
  • Disability Action Plan available on intranet and included in staff induction sessions
  • New starters provided with a copy of the Disability Action Plan
  • People and Capability
  • Ongoing
  • New starters provided with a copy of Plan
  • Promote principle of reasonable adjustment within office as a way of meeting needs of employees with disabilities
  • People and Capability
  • Ongoing
  • Advice provided to Senior Management Team about principles of reasonable adjustment for employees with disability
  • Ensure all staff with disability or mobility impairment have a Personal Emergency Evacuation Plan in place
  • Floor Warden
  • In practice since 2012 and ongoing
  • Emergency procedures include procedures for staff with disability or mobility impairment
  • Support employees returning to work after illness or injury with appropriate specialist assistance where necessary
  • People and Capability
  • In practice since 2012 and ongoing
  • Staff provided with assistance in returning to work from illness or injury
  • Provide staff with information about and access to Employee Assistance Program (EAP)
  • People and Capability
  • In practice since 2012 and ongoing
  • Staff advised of EAP at induction.
  • Details available on intranet.
  • Review recruitment practices to identify and remove any unintended barriers to people with disabilities
  • People and Capability
  • In practice since 2012 and ongoing
  • Any recruitment barriers for people with disabilities identified and removed where appropriate
  • Recruitment advertising includes a disability statement to encourage people with disabilities to apply for vacancies at TEQSA
  • People and Capability
  • In practice since July 2013 and ongoing
  • Disability statement included in recruitment advertising
  • Recruitment process to include reasonable adjustments where appropriate
  • People and Capability
  • In practice since 2012 and ongoing
  • Reasonable adjustments incorporated into recruitment processes
  • Provide staff with disability appropriate support and reasonable adjustments to their work environment where appropriate
  • People and Capability
  • In practice since 2012 and ongoing
  • All staff with a disability are provided with necessary support and reasonable adjustments where appropriate

Communication and community engagement

TEQSA aims to actively engage and support people with a disability to participate in TEQSA consultations, briefings and other events.

What we will do

Who will do it

Timeframe

Measure

  • Provide all publications in alternative formats upon request
  • Engagement Group
  • In practice since November 2017 and ongoing
  • Documents made available in alternative formats upon request
  • Provider briefing and other event invitations to provide information about accessibility to event and inform invitees that support for people with disabilities will be provided, on request, where possible
  • Engagement Group
  • In practice since March 2017 and ongoing
  • Information provided in event invitations about accessibility
  • Provider briefings and other events to be held at accessible venues and with accessible parking
  • Engagement Group
  • In practice since March 2017 and ongoing
  • People with disability are able to access venues and parking at TEQSA events
  • Auslan Interpreter available on request by prior arrangement
  • Engagement Group
  • In practice since March 2017 and ongoing
  • Auslan Interpreter provided where requested
  • Develop guidelines/checklist to assist reception/enquiries line to respond to enquiries from people with disability wanting to access services or attend events
  • Governance Team
  • Sept 2018
  • Checklist developed to assist reception to respond to queries
  • Encourage and support people with disabilities to participate on TEQSA Reference Groups
  • Engagement Group
  • Ongoing
  • Statement included on TEQSA website encouraging people with disabilities to participate

1. National Disability Strategy 2010-2020 p.8.

2. This section focuses on visitors to TEQSA. For staff-related accessibility, see the Employment section.