Consultation Response to
Equality and Social Justice Committee
Disability and Employment Inquiry
About Disability Wales
Disability Wales (DW) is the national association of Disabled People’s Organisations (DPO) striving to achieve the rights and equality of all disabled people.
DW’s core role is to represent the views and priorities of our members to government with the aim of informing and influencing policy.
DW actively promotes the adoption and implementation of the Social Model of Disability in society including in employment policy and practice.
DW is an organisation run and controlled by disabled people. This includes a constitutional requirement for all members of its Board of Directors to identify as disabled people. Full voting members of DW must be DPOs with committee and general membership comprising a minimum 51% of disabled people.
DW’s policy on recruitment requires that as the national DPO all externally facing roles are open only to disabled people.
DW’s consultation submission draws on the 53 responses to our online survey designed around the Inquiry questions.
DW liaised with the Senedd Citizen Engagement Manager in circulating information to members about the opportunity to participate in the Inquiry focus groups aimed at working age disabled people.
What progress has been made to deliver the recommendations set out in the ‘Locked Out’ report and to reduce and remove barriers faced by disabled people who want to access Wales’s labour market. Why progress to reduce the employment and pay disability gap has been so difficult to achieve.
Disability Wales was actively involved in establishing the Disability Equality Forum Steering Group, which coproduced the report Locked-Out: liberating the lives and rights of disabled people in Wales beyond Covid-19. DW’s Chief Executive chaired the group, which consisted of nine disabled people and liaised with members, Welsh Government officials and report author Professor Debbie Foster in researching, producing and disseminating the report.
The Locked-Out Report is the only document of its kind commissioned by a jurisdiction in the UK to represent the experiences of disabled people during the Covid-19 pandemic. The report depicts the stark reality of life for disabled people during Lockdown which exposed and exacerbated inequalities imposed by the previous decade of austerity. The reference to ‘liberating’ in the full report title emphasised the steering groups’ hope and ambition for a transformation in society’s response to disabled people.
Following publication of the Locked-Out Report Welsh Government recommitted itself to the Social Model of Disability as the organising principle for action, as well as to incorporate the UN Convention on the Rights of Disabled People in Welsh law and establish a Ministerial Disability Rights Taskforce.
The Taskforce first met in November 2021 and held its final meeting in July 2024. Ten working groups relating to themes outlined in the Report were set up to consider report findings and recommendations in depth and report to the Taskforce. More than 300 people were involved including Welsh Government policy leads, DPO representatives and individual disabled people. The Social Model of Disability and coproduction with disabled people provided the underpinning principles.
DW was actively involved in the process including contributing to drafting the Terms of Reference, representation on the Taskforce and all its working groups, and delivering Social Model training to all participants.
To date Welsh Government has yet to publish for consultation the draft Action Plan based on Taskforce proposals and recommendations.
Given the time commitment and contribution of so many disabled people to the process, the high expectations generated and in the context of further hardship created by the cost-of-living crisis, we call on Welsh Government to publish the draft Action Plan as a matter of urgency.
The recent initiatives introduced by Welsh Government aimed at tackling barriers to disabled people in the workforce and reducing the employment gap were not directly related to recommendations in Locked-Out. Some, such as the appointment of Disabled People’s Employment Champions were commitments in the Action on Disability Framework (2019). The publication A More Equal Wales: A practical guide for employers to employing disabled people was already in progress prior to publication of the Report. The Stronger, Fairer, Greener Wales, Employability and Skills Plan (2022) sets out Welsh Government’s approach to ensuring a wide range of people excluded from the economy can work. While the plan references Locked-Out, the focus of action on people with ‘long term health conditions’ and creating a ‘healthy’ working Wales appears to indicate a Medical Model approach.
This default position may help explain the lack of progress made by all governments in reducing the employment and pay disability gaps. Without acknowledging the historic and deep-seated institutional ableism in society and formulating and resourcing a cross-cutting long-term plan to address it, disabled people will remain economically and socially excluded.
How the social model of disability is being used to underpin employment and recruitment practices, and what barriers continue to exist throughout society that impact on access to work (i.e. transport, attitudes).
There is far greater awareness if not full understanding of the Social Model of Disability in society however it tends to be patchy in implementation. Despite comprising a fifth of the population disabled people are generally not considered in planning processes whether this relates to housing, transport, the economy or even a global health pandemic.
As a DPO and employer of disabled people, DW endeavours to create an inclusive workplace and implement the Social Model of Disability in recruitment processes.
We have hosted more than 30 disabled university students on placement, providing many with their first opportunity of work experience. They report that it has helped raise their awareness of their workplace rights including the Access to Work scheme and how to identify and request reasonable adjustments from future employers.
The following quotes from some of the students, express the value they placed on the experience:
“As a vision impaired person, it has also been nice to find myself working with people who wouldn’t bat an eyelid if work needs to be changed into a more accessible format, there’s a definite sense of inclusion even when working virtually. It’s been wonderful to work with the charity over the past five weeks and I’m so grateful to have been a small part of Disability Wales’ work during that time.”
Elin 2019 Volunteer Intern
“I feel incredibly lucky to have had this experience with Disability Wales! This placement has given me a beneficial opportunity to learn about the Social Model of Disability, the effectiveness of current legislation and the active research taking place about disabling barriers in society.”
Emily 2020 Volunteer Intern
“I have also learnt about the Social Model of Disability and the societal barriers faced by disabled people. Everyone at DW always made me feel included and that my work and ideas were valued, and were incredibly supportive of me developing my skills and increasing my confidence.”
Amy 2021 Volunteer Intern
“Many workplaces, leisure activities and heritage site’s facilities are created with an image in mind which excludes disabled people. Volunteering has taught me that a few hours a week can have a huge impact on social change.”
Haris 2022 placement through EQuip Project
With funding from Welsh Government DW has published The Social Model of Disability Toolkit (2024) co-designed with Deaf and Disabled people which includes practical examples for employers[1].
We know from feedback from members, many disabled people struggle to get reasonable adjustments approved. This includes flexible/hybrid working. They report negative attitudes from managers and colleagues and face unacceptable delays in securing support from Access to Work.
Appointing the network of five Disabled People’s Champions is a welcome initiative especially the pro-active approach to recruiting disabled people to these roles. However, survey responses indicated a lack of knowledge about them or their role. Greater visibility would enhance the initiative, however as there are only five Champions, currently, realistic expectations are required of what can be achieved.
Another notable effort by the Welsh Government is the development of apprenticeship opportunities. This is a significant move toward creating accessible career pathways and addressing the employment gap between disabled and non-disabled people. However, similar to the Disability Employment Champions, the success of such initiatives depends on adequate promotion and outreach to ensure that disabled individuals and employers are aware of and can access these opportunities with the required bespoke support (e.g. provision of job coaches).
In conclusion, while the Welsh Government’s initiatives, such as the network of Disability Employment Champions and apprenticeships, represent important steps in reducing employment barriers for disabled people, their effectiveness could be further enhanced by increasing visibility and expanding capacity. These efforts are promising but require ongoing attention to ensure they reach their full potential in reducing the employment gap.
Whether disabled people are accessing apprenticeships and if any further support is needed to ensure a schemes are inclusive.
Survey responses indicated that greater awareness of Apprenticeship schemes is required and more flexibility is needed. Age criteria was also highlighted as a barrier. Comments received included:
“This option has been considered, though I think that I would be too experienced in my chosen roles. I also would not even know/where to find apprenticeships.”
“Don't think I can apply being a disabled 44 yrs old women.”
“That’s the problem I wouldn’t know where to go to access an apprenticeship in Wales because I'm not informed or told disabled people are always put to the wayside when it comes to any type of employment we aren’t encouraged to go for these jobs or routes into employment like apprenticeships or studying they just think we can’t do anything which is a big part of the problem that we as disabled people have to face”
What further policy measures are needed to support disabled people, young disabled people and employers to increase participation rates and what can be learned from elsewhere.
Employment support must be decoupled from the benefits system which has created a toxic environment for disabled people over the last 14 years. Humiliating work capability assessments, cruel sanctions and draconian cuts to benefit have caused considerable harm to disabled people. A recently published book The Department by disabled journalist and author John Pring catalogues details related to the harrowing number of deaths amongst claimants[2].
In 2016 the UK Government was found by the UN to be in breach of three Articles of the Convention on the Rights of Disabled People on account of the impact of austerity measures in relation to rights to independent living, adequate standard of living and employment. A formal review of these findings undertaken by the UN in March 2024, in which DW participated, found that there had been “no significant progress” by UK Government in addressing the grave and systematic violations of Deaf and Disabled people’s rights that it highlighted more than seven years ago[3].
It is therefore vital that the new UK Government working in partnership with the Welsh Government takes a very different policy approach. This should include recognition of disabled people’s rights through incorporation of the UNCRDP in UK and Welsh law. Furthermore, taking a social model approach by tackling disabling barriers in society that condemn so many disabled people to poverty and lack of opportunity in education and employment.
More focus is required on challenging discrimination in the workplace with less blame on individual disabled people for being unemployed. As well as repercussions for employers who regularly breach the Equality Act (2010), there should be stronger incentives to embed good employment practice. DWP’s Disability Confident Scheme is ineffective as well as discredited among disabled people and should be scrapped. DW has long supported a ‘made in Wales’ scheme for employers which engages with DPOs as part of the quality assurance process.
Drawing on the Locked-Out Report and the outstanding work undertaken by the Taskforce, Welsh Government has a golden opportunity to develop a new long-term Action Plan that sets out a progressive direction for achieving the rights of disabled people in an inclusive Wales.
The plan should include robust and measurable objectives with clear lines of accountability for delivery at Ministerial level and across the public sector. Key to this will be a powerful voice for disabled people, whether through a Commission or an Advisory Board with support for grass roots DPOs.
What actions would support those who are currently unable to work to access voluntary opportunities (which could lead to future work opportunities).
There is more to be done in creating greater inclusion across the Third Sector which includes opportunities for disabled people to volunteer and to gain employment. There is no equivalent of Access to Work for volunteers, which could make a significant difference to funding equipment, personal assistance and communication support and other reasonable adjustments.