Implementation of the DDA

ps/13/06
06 March 2006
MPA briefing paper

Author: Avril Cooper, Charles Phelps, Mike O’Hanlon & Claire Hunt, MPS

This briefing paper has been prepared to inform members and staff. It is not a committee report and no decisions are required.

Introduction

1. The purpose of this paper is to describe how the MPS meets its obligations with regard to the extension of the Disability Discrimination Act to cover police officers. The report specifically looks at the MPS’ processes relating to recruitment, career development, promotion and training.

Recruitment

Standard Operating Procedures

2. There are two Standard Operating Procedures (SOP) for police officer recruitment which take into account the Disability Discrimination Act 1995 (DDA). These cover dyslexia and the process for applying medical standards for police officers. Following consultation, the SOPs have been circulated to HR managers and are published on the HR Intranet site. All new Standard Operating Procedures and policies, and their subsequent review or amendment, go through a consultation process, which includes disability advisory services and other interested parties prior to publication.

Recruitment processes

3. The application form for police officers states that the role is covered by the DDA, that the MPS welcomes applications from people with disabilities and that reasonable adjustments will be made both to the working conditions and to the selection process. The application form provides an opportunity for the applicant to state their disability and what reasonable adjustments they think should be made. These messages are repeated in the notes to accompany the application form and a separate form is included for the candidate to request adjustments be made specifically to the selection process if necessary.

4. A pamphlet is included in the application pack which clearly explains the MPS’ commitments regarding the employment, retention, training and career development of disabled employees. One of these commitments is the existence of the Strategic Disability Team, which works to support disabled staff and to develop policies that do the same. This pamphlet clarifies that the selection process for police officers checks whether the candidate meets the necessary criteria before considering if they are able to perform the role.

5. Medical selection processes have been redesigned to incorporate a social model with the focus on reasonable adjustments and with a shift from 'medical' decisions to 'managerial' decisions in the case of applicants with health issues or disabilities. The medical selection team makes an individual assessment of all candidates and if necessary makes a recommendation to the HR manager for any adjustments that would need to be made to working conditions. This recommendation is reviewed by the HR manager to decide whether or not the adjustment is in fact reasonable. This system was implemented for police officers in 2004.

Marketing and advertising and positive action recruitment activity

6. The Me+ Careers team has a permanent disability advisor to take disability issues forward for HR Recruitment. The Careers website states that the MPS welcomes applications from people with disabilities and that where possible, adjustments will be made to working arrangements. A brochure has been produced by the Marketing and Advertising department to demonstrate a positive approach to disability.

7. The close partnership between the MPS and Job Centre Plus has served to bring the message to jobseekers that the MPS welcomes applications from people with disabilities and that it is dedicated to implementing the DDA within the organisation. Job Centre Plus recruitment activity for the MPS focuses on the recruitment of incapacity benefit claimants, with two recent, successful employment events aimed specifically at incapacity benefit claimants.

Career development

8. The Career Management Unit (CMU) offers various schemes to assist police officers to develop their careers. These include the Bursary scheme, High Potential Development Scheme and access to courses for senior staff managed by CENTREX. All the schemes have open access to officers with disability but it is not known how many are on these schemes. The application processes have monitoring built in as part of the selection process, where officers can self-disclose and if necessary ask for reasonable adjustments. Additionally, the programmes allow for flexible access at home or with the use of I.T. making them more accessible.

9. The application processes and guidance for promotion for police officers requests officers who believe they may require reasonable adjustments to contact the CMU when they are applying. Each process is designed to test the appropriate managerial ability and not specific operational capability.

10. To that extent the promotion processes should not in any way disadvantage disabled officers. However, some support roles may not allow officers to gather evidence to demonstrate potential and could disadvantage officers who cannot move out of these roles. It is acknowledged that perceptions are held by some candidates and supervisors that being disabled means being non-operational. These perceptions have been challenged and indeed, in one specific example, after the intervention and a risk-assessment of the CMU, one disabled officer moved to an operational role where they have since demonstrated potential and been promoted.

11. Once a disabled officer has applied for promotion, the CMU liaises with the individual officer to determine what adjustments are proper and reasonable. At present there are two or three requests per event and adjustments have included specially designed chairs for those with back problems, additional time for officers with dyslexia or sight issues and additional breaks for officers with degenerative diseases.

12. Monitoring shows that those disabled officers we know about, who enter the processes, have as much chance of passing as those who are not. However, it is still stated by some that many would not disclose they are disabled and anecdotally, some officers are still of the belief that officers who are disabled or on recuperative or restricted duties cannot apply for promotion.

13. In response, the CMU are examining all processes and are amending documentation to reflect recommends made in a report from an external agency specialising in dyslexia issues. In addition, our guidance is being updated to make the requirements for promotion clearer so that officers are not improperly disadvantaged.

Training for managers and staff

14. In response to the full implementation of the DDA, the Diversity Directorate made a bid to the MPS Training Management Board (TMB) in December 2004 for the inclusion of mandatory disability awareness training for all MPS personnel. The TMB allocated a half-day within the 2005/2006 MPS mandatory training programme.

15. This bid and the TMB decision was made against the background knowledge that relevant training products had been commissioned by ACPO and the Home Office through Centrex and the National Centre for Applied Learning Technology (NCALT), covering both the service delivery and employment issues emanating from the DDA. The MPS was directly engaged in the development of these resources at project board level and therefore did not see the value in developing its own learning products for the DDA.

16. The Diversity and Citizen Focus Directorate developed a proposal to implement a learning programme consistent with the national Police Race and Diversity Learning and Development Programme (PRDLDP). This involves providing NCALT’s e-learning module ‘Disability and the Police’ to everyone within the MPS. This can then be ‘contextualised’ for specific groups of personnel according to their role and environment, an approach consistent with the PRDLDP.

17. There was some delay to the production of the NCALT e-learning programme but it was available to the service from April 2005. Owing to the fact that the technological and administrative infrastructure is not in place yet, implementation of this programme across the MPS as mandatory has not commenced. A key feature of MPS infrastructure must be the capacity to monitor completion of the programme. At this time NCALT is not fully compatible with the MetHR system and therefore collection and transference of data between the systems has involved a significant human resources input.

18. The e-learning programme is currently on trial with the Diversity and Citizen Focus Directorate, to better understand the challenges that will be faced in moving it to the wider organisation. The Directorate trial will conclude in early March and thereafter a strategy developed to deliver it service wide, which will include the need to extend its status as mandatory through the TMB.

19. The NCALT Disability e learning has been developed with the learning needs of all parts of the service in mind and includes a wide range of case studies. It specifically addresses supervisors’ responsibilities and the ‘Social Model’ of Disability is the ethos that underpins the programme. It is a resource that is available now for any member of the service and supports understanding of the Home Office guidance ‘Disability and the Police – the complete works’, which has also been publicised and is available to members of the MPS.

20. Pilot work is underway on the process of ‘contextualising’ the NCALT Disability e- learning in Greenwich borough. The Diversity and Citizen Focus Directorate is working with the local management and representatives of Disabled people from the community to develop a process to make the learning relevant to specific policing roles. It is anticipated that this work will be completed by late Spring 2006.

Data monitoring

21. Although there is the capability to monitor disability on MetHR, uptake of this option has been limited, especially amongst police officers. It would not be unreasonable to expect that police officers with 15 or more year’s service might develop a disability of some sort over time but possible reasons for them not declaring this might be;

• Police officers may be less willing to share information of disabilities with HR managers than police staff
• Police officers may perceive that admitting to a disability would hamper job promotion more so than police staff
• Police officers who have been diagnosed with a disability may feel that they can handle the situation, that there are no special needs and, therefore, there is no need to disclose information to HR managers

22. It is unclear why so few MPS personnel have declared themselves partially disabled, however, this may simply mean that there is some confusion as to what separates being disabled from being partially disabled. Due to the low uptake of self-declaration, the introduction of measures for disproportionality is currently meaningless. However, it is envisaged that the implementation of the self-service function on MetHR in July coupled with an appropriate marketing exercise, will go some way to addressing this issue.

23. All HR policies are compliant with legislative requirements.

Equality and diversity implications

24. Equality and diversity, specifically in relation to disability, is integral to this report. This briefing paper highlights where steps have been undertaken to comply with the extension of the DDA to police officers. However, more importantly it identifies where further work is required in order to address staff perceptions of how disability can be viewed negatively, particularly in relation to promotion processes. In addition, monitoring of disability data requires greater sophistication so that staff are encouraged to self-declare thus enabling the MPS to gain a better understanding of how disability impacts the workforce.

Financial implications

25 There may be additional costs arising from the publication and distribution of literature aimed at rising awareness of disability issues in the MPS but these have not yet been quantified. The marketing strategy will seek to encourage staff with a disability to declare it thus a rise in the number of requests for reasonable adjustments to be made to the individual’s working environment can be expected.

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