Table of contents
- Principles
- Definitions
- Recruitment
- Retention
- Inclusive Culture
- Responsibilities
- Available Resources
- Relevant Policies
1. Principles
The Department of Families, Housing, Community Services and Indigenous Affairs (FaHCSIA) is committed to ensuring an inclusive work environment enabling people with disability to fully participate in all aspects of employment. This policy provides a framework for increasing the recruitment and retention of people with disability within FaHCSIA.
The Department recognises that the representation of people with disability as employees of FaHCSIA falls short of the representation of people with disability in Australia. By increasing the proportion of people with disability employed within FaHCSIA, the Department believes it will benefit from the increased innovation of a more diverse workforce and will be better equipped to meet the needs of service users with disability.
FaHCSIA's principles, policies, and resources relating to people with disability are never about 'special treatment.' They are about ensuring merit and equity based access to jobs, resources, and benefits for all employees.
Objectives of this policy:
- To ensure that job applicants with disability receive fair treatment and are considered on the basis of their job-relevant skills and experiences.
- To promote a positive work environment so that people with disability are fully included in the workplace.
- To retain employees with disability by putting in place systems and processes that assist and support them.
- To increase the number of people with disability in the Department's workforce.
- To raise awareness and understanding of disability issues amongst staff through training and information dissemination.
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2. Definitions
Disability - this policy adopts the broad definition of disability used in the Disability Discrimination Act (1992), which, in the context of employment, can be summed up as a condition either caused by accident, trauma, injury, genetics or disease that may restrict a person's mental, sensory or mobility functions to undertake or perform a job in the same way as a person who does not have disability. This includes physical, sensory, intellectual, psychiatric, neurological and learning disabilities, as well as physical disfigurement and serious illnesses. Disability may be temporary or permanent, total or partial, lifelong or acquired.
Disclosure refers to a personal decision to tell a person or institution about one's disability. There is no legal obligation for a job applicant or employee to disclose their disability, unless it is likely to affect their performance to meet the inherent requirements of the job (including ensuring the safety of themselves and others).
Discrimination - the Disability Discrimination Act (1992) identifies two types of discrimination in relation to people with disability. Direct Discrimination is when someone with disability receives less favourable treatment than a person without disability in the same circumstances. Indirect Discrimination is when a policy, practice or requirement is applied equally but has a discriminatory effect on people with disability.
Inherent Requirements are the essential activities and tasks that must be carried out in order to get a job done. Inherent requirements relate to achieving the necessary outcomes, or what must be accomplished, rather than the means, or how it is accomplished.
Merit Principle means the selection and advancement of employees according to their relative abilities, knowledge, and skills under fair and open competition.
Reasonable Adjustment refers to the administrative, environmental or procedural alterations required to enable a person with disability to work effectively and enjoy equal opportunity with others. By law, employers are required to provide reasonable adjustments whenever it is necessary, reasonable and possible to do so (i.e., when a reasonable adjustment does not constitute an unjustifiable hardship for the employer).
Unjustifiable Hardship - employers are obligated to provide reasonable adjustments unless such an adjustment would result in unjustifiable hardship to the employer. It is difficult to define unjustifiable hardship because each circumstance and organisation is unique and is determined on a case-by-case basis. However, unjustifiable hardship is generally determined by considering:
- The cost of the adjustment required in light of the organisation's financial situation, and
- The extent to which the adjustment will result in substantial benefits or detriments to other employees, including those who do not have disability.
"Reasonable" is defined by whether or not the adjustment would create "unjustifiable hardship" to the whole organization; it is never defined by a particular manager's opinion of what is reasonable.
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3. Recruitment
We aim to be an employer of choice for people with disability through our attraction and recruitment initiatives and practices.
We will use positive recruitment initiatives to attract people with disability to apply for positions within FaHCSIA. In order to accomplish this, we will:
3.1 Recruitment and Employment
- Establish links with universities to make graduates with disability aware of opportunities in FaHCSIA.
- Identify and participate in events and celebrations relevant to people with disability (including career expos, International Day of People with Disability and other events targeted at people with disability).
- Have People Branch and the Disability Access Coordinator (DAC) develop close contacts with disability community and peak bodies to raise the profile of the Department as an employer of choice.
- Explain in our recruitment literature that support is available to all candidates with disabilities when applying for positions, for example, providing for access, communication or other requirements.
- Ensure that promotional material reflects the diversity of FaCSIA's workforce, particularly in relation to people with disability. Contact the DAC on (02) 62009512 email DAC (diversity@fahcsia.gov.au) for for further information.
3.2 Vacancy Advertisements
- Submit vacancy listings to Disability Works.
- Include positive statements on position advertisements to encourage applications by people with disability (e.g., Equal Opportunity Employer, reasonable adjustments available).
- Write vacancy advertisements and application materials using inclusive language (e.g. with reference to inherent requirements).
- Ensure that vacancy advertisements list methods for contacting the DAC.
- Where applicable, encourage the involvement of Disability Employment Assistance agents or Job network specialist providers who have identified as working with applicants with disability.
- Use the disability press where resources permit. This includes Link Magazine and other publications by disability peak bodies and organisations.
- All materials related to advertisement and application will be made available in alternative formats and timeframes will be extended to accommodate time taken in providing such formats.
3.3 Position Descriptions
- Position descriptions will be developed in a non-discriminatory way by focusing on the core duties or inherent requirements of the job and what is to be achieved rather than how it is to be achieved.
- In particular, position descriptions will not impose rigid requirements for jobs that may exclude suitable candidates and can indirectly discriminate against people with disability. For example, stating that applicants must have a driver's license when not completely necessary for the role could discriminate against candidates who cannot drive due to their disability or who can only drive modified vehicles.
- Managers will have access to information sheets about developing inclusive, non-discriminatory position descriptions. As positions are advertised People Branch will review position descriptions to ensure they focus on inherent requirements only.
3.4 Interviews
Individuals from People Branch and all employees involved in employment interviewing:
- Will have access to disability awareness resources.
- Will be familiar with the reasonable adjustments that can be provided during the interview process. This information can be obtained from the Reasonable Adjustment Policy and the Reasonable Adjustment and Interviewing Fact Sheets available through People Branch and on FaHCSIA's intranet.
- Advice on and assistance with interview arrangements for a candidate with disability will also be available from the Disability Access Coordinator.
FaHCSIA will aim to remove all potential barriers during the interview stage by:
- Requiring staff who are arranging interviews to ask candidates who have disclosed their disability whether they require any particular adjustments to participate equitably (e.g., Auslan interpreter, assistive technology, disabled parking space, modification of testing procedures).
- Considering whether selection tests should be adjusted in order to take account the needs of any person with disability and to ensure that such exams do not unlawfully discriminate. For information on how to arrange accommodations, see the Reasonable Adjustment Policy and applicant's flow-chart.
- Providing all selection panels with a the Reasonable Adjustment Fact Sheet explaining reasonable adjustment principles.
- Requiring selection panels assessing candidates for a job to review and understand the inherent requirements of the job.
- Doing assessments on a case by case basis and not assuming that a specific disability or medical condition prohibits a person from performing a particular function.
- Drafting interview questions that are non-discriminatory:
- Questions or statements are to be based solely on assessing the person's skills and ability to perform the inherent requirements of the job.
- If necessary, giving consideration to any reasonable adjustments such as altering the duties of the post or purchasing assistive technology before the selection decision is made.
3.5 External Recruitment Providers
- When external recruitment providers (including employment agencies and assessment centres) are used, FaHCSIA will ensure that providers are aware of FaHCSIA's diversity commitments and policies.
- Each recruiting branch is responsible for ensuring that any external recruitment provider they engage understands reasonable adjustment requirements and is experienced in the applications of such requirements.
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4. Retention
FaHCSIA aims to cumulatively and pre-emptively remove barriers to the retention of people with disability. Every effort will be made to ensure that staff with disability are treated in a non-discriminatory way and that they are provided with the same opportunities for promotion, career development and training as other staff.
4.1 Disclosure
- All employees will be informed about the purposes and processes for disclosing disability before job commencement.
- Information about disclosure and processes for disclosing will be available to all employees (e.g., Disclosure Benefits and Resources Fact Sheet, in pamphlets distributed in work areas, etc).
- When a person has disclosed to FaHCSIA a non-obvious disability, privacy policies shall be upheld and the individual will be asked if he/she wishes for their colleagues to be informed of his/her disability.
4.2 Induction
- Induction and support for all new members of staff with disabilities will be provided. This may mean that adjustments are made to the usual induction programme so that a person with disability is introduced to the organisation in a clearly supported and structured way.
- Information about disability resources, policies and procedures will be provided and explained to all new employees as part of the induction process.
4.3 Reasonable Adjustment
- When the Department is aware that a new employee has disability, all efforts will be made to put in place relevant reasonable adjustments prior to job commencement (see the Reasonable Adjustment Policy for further details).
- Reasonable adjustment policies and procedures are provided and explained to all new employees as part of the induction process.
- Monitoring and evaluation of adjustments will be ongoing, if appropriate.
- The views of an individual with disability will be taken into account at all times when adjustments are being assessed.
- In cases where a reasonable adjustment has implications for co-workers or managers, those affected will be consulted and educated about proposed changes (while adhering to privacy principles).
4.4 Consideration
- Consideration of people with disability will be made in facilities upgrades, allocations or parking facilities and health and safety issues such as fire alarms and procedures.
- Where appropriate, staff with disabilities will be consulted about FaHCSIA's disability initiatives.
- Where general meetings of staff are held, these should be held in accessible venues with facilities for people with visual and hearing impairments.
- Social events will be arranged in accessible venues and, where off-site, easy to reach by transportation.
4.5 Support Services and Networks
- FaHCSIA will promote internal and external employment support services that are available to employees with disability (e.g., IPS Worldwide Employee Assistance Program).
- All employees will be informed of the FaHCSIA Leadership disABILITY Group, the Assistive Technology Operations Group, and the Assistive Technology Management Advisory Group and their eligibility to participate.
4.6 Performance Management
- The same performance standards are applied to employees with disabilities as to all employees. If a position has been redefined as part of a reasonable adjustment, an employee with disability should only be evaluated on the tasks he or she is expected to perform.
4.7 Service Providers
- FaHCSIA will communicate its commitment to people with disability to all external service providers.
- Recognising vicarious liability, FaHCSIA will require external service providers to take into consideration the access requirements of employees with disability. Services need to be accessible to people with a range of disabilities and service providers need to consider how they will provide alternative formats when requested by people with disability.
4.8 Professional Development
FaHCSIA aims to ensure that employees with disability have the same opportunity as other employees to participate in career development programs and opportunities.
- FaHCSIA will encourage and support people with disability to take up opportunities to act in higher positions.
- All materials related to promotion opportunities will include information about reasonable adjustments and related processes.
- All materials related to promotion opportunities are promptly made available in preferred formats on request.
- FaHCSIA will encourage and support people with disability to participate in professional development opportunities.
- Where a person with disability participates in a professional development activity, materials are provided in alternative formats.
4.9 Learning and Development
- All learning and development programs are promoted so as to ensure that people with disability are informed of their eligibility and access to such programs.
- The design and delivery of learning and development programs takes into account the accessibility needs of employees with disability.
- Where possible, training materials are provided in advance to a person with a hearing impairment so they can read prior to activity.
- Training classes will be held in accessible facilities.
4.10 Exit Surveys
- FaHCSIA will develop a process for and conduct exit surveys to examine why people with disability leave the organisation. Recognising that some employees with disability may not have disclosed their disability while working at FaHCSIA, this survey will be provided to all employees who exit the organization. These surveys will allow FaHCSIA to uncover any systemic or organisational practices contributing to their leaving.
4.11 Monitoring
FaHCSIA will collect information to monitor the representation of people with disability in the following areas:
- Shortlisting and interview decisions
- Job application numbers
- External recruitment agency rates of engagement of persons with disability
- Successful selection numbers for appointment, promotion and transfer
- Composition of the workforce, broken down into work group, band and pay scale
- Access to training
- Harassment and discrimination complaints
- Grievances
- Reasons for exit (i.e., dismissals, resignations, redundancies and retirements)
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5. Inclusive Culture
To develop an inclusive culture where people with disability are valued and treated equitably, FaHCSIA will arrange awareness raising programs and training for all staff.
- Managers and staff will be provided with information, training (including some face to face training), support, and advice about disability in the workplace.
- All employees will be informed about the role of the Disability Access Coordinator and will have access to the DAC's services, where appropriate.
- Managers will be made aware of FaHCSIA's Disability Fact Sheets about disability in the workplace.
- Information about disability will be disseminated via the intranet, "The FaHCSIA Weekly Newsletter" and other publications.
- Mental health issues or other non-obvious disabilities will be explicitly included in FaHCSIA's disability initiatives.
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6. Responsibilities
All staff are responsible for the fair and equitable treatment of coworkers with disability. Managers should actively promote the employment and retention of people with disability. People Branch is responsible for making the necessary resources available to support this objective wherever possible.
Disability Access Coordinator Role (DAC):
The DAC (currently Robyn Forester on 62009512) is a position identified in the FaHCSIA Collective Agreement. The DAC is responsible for influencing the development of corporate policies so that issues affecting employees with an injury, illness or disability are addressed. The DAC also works with managers, employees and service providers to ensure that the principles of reasonable adjustment, and access and equity are upheld. This is done by providing advice and guidance to managers and employees on:
- Supporting and managing injury, illness or disability in the workplace; and
- Workplace modifications, assistive technology, adaptive equipment and physical access.
FaHCSIA Leadership disAbility Group (FLAG)
FLAG’s Vision is to:
Advance the status of employees with disability across the whole Department and build FaHCSIA’s leadership in this area.
FLAG is a staff group that was established in late 2008 to identify and address workplace issues that affect employees with an injury, illness or disabilty.
Supported by the Department and the Senior Level Advocate for FaHCSIA Employees with Disability, Deputy Secretary Geoff Leeper, FLAG has identified the need to raise the profile and visability of disability issues with the department.
FLAG aims to:
- Make a difference on stategic issues and overcome systemic barriers
- Focus on attracting, recruiting and retaining staff with disability
- Work on disability issues in positive and constructive ways through the encouragement of best-practice approaches to accomodation and recruitment, including through peer support, buddying, coaching and mentoring.
Becoming a Member
Membership of FLAG is open to interested staff members, with or without disability, who would like to assist FaHCSIA as an employer of choice.
Assistive Technology
FaHCSIA supports the importance of people having what they need to do their job to the best of their abilities.
Assistive Technology Operations Group (ATOG)
The Assistive Technology Operations Group will provide a forum to ensure maximum participation, opportunity and contribution of employees who use Assistive Technology in FaHCSIA.
The group will achieve this by:
- investigating and considering best-practice assistive technology solutions;
- anticipating future needs of assistive technology users;
- consulting with assistive technology users;
- planning effectively to ensure the needs of assistive technology users are met.
This group will provide recommendations and information to the Assistive Technology Management Advisory Group (ATMAG). The group will meet when necessary.
Assistive Technology Management Advisory Group (ATMAG)
The Assistive Technology Management Group will provide a forum for the provision of strategic advice and recommendations on assistive technology solutions to maximize the participation, opportunity and contribution of staff who use assistive technology in FaHCSIA.
This will be achieved through:
- consideration of assistive technology issues within the strategic direction of IT in FaHCSIA
- consideration of funding for assistive technology within FaHCSIA
- effective planning to meet the needs of assistive technology users;
- monitoring and evaluating the success of assistive technology solutions both internal and external to FaHCSIA.
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7. Available Resources
- DAC, 6200 9512
- Employee Assistance Program - Davidson Trahaire corpsych 1300 360 364
- FaHCSIA Leadership disABILITY Group
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8. Relevant Policies
- Reasonable Adjustment Policy
- Privacy Policy
- Good Health Policy and Guide
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