This policy explains how we make sure our services fair and accessible for everyone. It explains what reasonable adjustments are, which are changes we can make to help people access our services more easily, especially if they are disabled or have additional needs.
We aim to remove barriers and support people in a way that works for them. An easy read version of this policy is available. Our customer care standards explain how we aim to treat people and the service you can expect from us.
What are reasonable adjustments?
Reasonable adjustments are not defined by the Act. The intent of a reasonable adjustment would be to place a disabled person to the same level of opportunity and access as possible as others. Cambridgeshire County Council will consider reasonable adjustment requests from our customers on a case-by-case basis. What is a reasonable step for a particular service provider to have to take depends on all the circumstances of the case. It will vary according to:
- the type of service being provided,
- the nature of the service provider and its size and resources, and
- the effect of the disability on the individual disabled person.
The Equality Act 2010 Code of Practice gives guidance as to the kind of adjustments that could be made. Depending on an individual’s needs, this could include:
- Providing documents or correspondence in larger print, or with a specific colour contrast (which may help people with conditions such as dyslexia).
- Giving you more time than would usually be allowed to provide further information or comments on their query/complaint.
- Using the telephone rather than written communication (e.g. if you have a visual disability).
- Translating documents or correspondence into Braille.
- Providing reserved parking or a quiet room.
- Communicating through your representative or advocate.
- Providing access to an ‘Easy Read’ version of key documents for those with a learning disability.
- Providing access to a “Reader Friendly” version of key documents for those with dyslexia or other reading difficulties.
- Providing a British Sign Language (BSL) interpreter.
- Accessibility tools are built into online software and products so content must comply with the Web Content Accessibility Guidelines (WCAG) 2.2. WCAG is an internationally recognised set of recommendations for improving web accessibility.
Examples of accessibility tools include:
- Operating systems - Microsoft Windows has 'Ease of use' settings. ‘Ease of use’ includes; display, pointers, magnifier, colours, high contrast, narrator(text to speech), speech to text, audio, captioning, keyboard controls, touch controls, language settings.
- Software - A web browser (Edge, Chrome), a document reader (adobe reader, doc viewer) or Microsoft 365. These include similar options to the operating system above.
- Hardware - some users may have very specific software, hardware or addons that meet their needs. For example, Jaws screen reader, eye motion controls, dragon voice command software, Sip and Puff switches, braille Customer handling policy translators, pointing wands.
- Further reading on web accessibility and making documents accessible and advice is available on the County Council website.
Service providers should bear in mind that there are no hard and fast solutions. Action which may result in reasonable access to services being achieved for some disabled people may not necessarily do so for others.
When can a reasonable adjustment be requested?
A reasonable adjustment can be requested as part of any interaction with the Council regardless of how you corresponding, for example in person, by telephone, by email or by completing an online form.
Policy scope
We are committed to ensure the people who use our services and residents have good quality public services that meet the diverse needs of our communities. We want to ensure that the way we work does not disadvantage customers, including if you are disabled*, neurodivergent, or have a physical or mental health condition. We want to remove the barriers some of our customers have in accessing our services and making complaints.
The aims of this policy are:
- To define our legal obligations to consider adjustments and to make adjustments where reasonable.
- To provide our employees with information so that they can ensure that working practices eliminate unfair discrimination and recognise the ways in which we can make it easier for disabled people to access our services.
This policy does not cover the legal responsibilities for how we monitor our work force or meet our duties as an employer.
*For the purposes of the Equality Act 2010, a disability is defined as a substantial and long-term adverse effect on your ability to carry out normal day to day activities which has lasted or is likely to last for 12 months or more. This includes fluctuating conditions, including mental health problems, and includes HIV, cancer and MS from the point of diagnosis. We are keen to remove all barriers and support customers, where reasonable, irrespective of whether they meet the criteria under the Equality Act 2010.
Our legal duties
The Equality Act 2010 provides a legal framework to protect the rights of individuals and advance equality of opportunity for all. Part of the Equality Act 2010, the Public Sector Equality Duty (PSED), places a proactive duty on councils to have due regard to eliminate discrimination, advance equality of opportunity and foster good relations between different people when carrying out their activities.
In practice, this means councils must be able to demonstrate how they have thought about equality and fairness when they design and deliver services. Importantly, they should evidence how they have done this and keep policies and practices under review. One way to do this is by conducting Equality Impact Assessments that demonstrate the council’s regard to relevant issues.
The PSED applies to all council services. Whilst in some areas, like Children’s Social Care, it is often clearer that decisions will have equality implications, councils must have similar regard to this duty in areas where this is not so immediately apparent. While the legal duty imposed on the council is to provide reasonable adjustments to disabled persons who meet the eligible definition, anyone can request reasonable adjustments from the council.
Duty to make reasonable adjustments
Local services must think about how invisible or hidden disabilities might affect people who need to access their service. These might be because of their mental health or because of less immediately obvious physical illnesses, learning difficulties, and disabilities.
The legal duty to make reasonable adjustments comprises three requirements. For service providers and those exercising public functions, these requirements are:
- Where a provision, criterion or practice puts disabled people at a substantial disadvantage compared with those who are not disabled, to take reasonable steps to avoid that disadvantage.
- Where a physical feature puts disabled people at a substantial disadvantage compared with people who are not disabled to avoid that disadvantage or adopt a reasonable alternative method of providing the service or exercising the function.
- Where not providing an auxiliary aid puts disabled people at a substantial disadvantage compared with people who are not disabled, to provide that auxiliary aid.
The duty is ‘anticipatory’. This means a service provider cannot wait until a disabled person wants to use the service. They must think in advance (and on an ongoing basis)about what a range of diverse people (such as people who are deaf, are neurodivergent, or a learning disability) might reasonably need. Whilst we aim to anticipate adjustments, our communications will invite people to tell us if they require any reasonable adjustments.
Our process
Requesting a reasonable adjustment
Individuals can raise a request with any of our customer facing employees or services. We will also suggest new or additional adjustments if we feel it might help you continue to make the best use of our service.
Our response to requests
Before agreeing an adjustment, we will consider:
- What the disadvantage would be if the adjustment were 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 and availability of resources, including external help and finance.
We will try to agree a reasonable adjustment with a minimum of delay, but in some cases, we may need to consider the request in more detail.
There may be circumstances where we decide not to meet the request. The law states that an adjustment need only be made if it is “reasonable.” We need to take account of the cost or resource implications of making the adjustment, whether the request itself is reasonable and whether there is a less expensive way of meeting the request. Where it is very difficult to provide the adjustment or meeting it would interfere with our ability to meet our legal obligations, we may decide it is not “reasonable”.
We will look at each request individually and 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 in writing.
Reasonable adjustments during the complaints process
We want to remove the barriers some of our complainants have in accessing our service and making complaints. You can ask for a reasonable adjustment at any time during our consideration of your complaint.
Complaints about failure to provide reasonable adjustments
We are committed to providing a high standard of service, dealing with everyone in away that is fair, and free from discrimination.
If someone is dissatisfied with our response to any requests for reasonable adjustment, or with the reasonable adjustment provided, they have the right to provide feedback to aid our organisational learning. We will respond in accordance with our Feedback Policy.
Our Customer handling policy outlines our approach to unreasonable behaviours from customers, including:
- Behaving in a way that has a significant and disproportionately adverse effect on Cambridgeshire County Council’s resources, its staff and other members of the public.
- Making excessive demands on the time and resources of staff and members with lengthy and/or repeated telephone calls, emails to numerous council officers, or detailed letters expecting an immediate response.
- Expecting a response that is disproportionate, or we are unable to achieve.
When a customer is regularly displaying unreasonable and / or persistent behaviour, the nature of the customer’s contact will be reviewed. If it is concluded that the behaviour is unacceptable and/or unreasonable, the council will write to tell the customer why we find the behaviour unreasonable and/or unacceptable and ask them to modify their behaviour.
Other actions
- For transparency, we publish this policy on our website.
- We make sure that our employees are aware of their responsibilities.
- We include a statement in our leaflets and communication that invites people to contact us if they need us to adapt the way we communicate.
Further information and resources
The below resources can provide helpful information and guidance around reasonable adjustments:
