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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Accessible Information Standard Policy

1. Purpose

At {{org_field_name}}, we are committed to ensuring that people using our supported living service, and where relevant their carers, representatives and family members involved in their care, can access, understand and use information in a way that meets their individual communication needs.

This policy sets out how {{org_field_name}} will comply with and have regard to the Accessible Information Standard, currently DAPB1605, issued under section 250 of the Health and Social Care Act 2012. The Accessible Information Standard requires health and adult social care organisations to identify, record, flag, share, meet and review the information and communication support needs of people who have a disability, impairment or sensory loss.

This policy supports compliance with the Health and Social Care Act 2008, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, the CQC Fundamental Standards, the CQC Single Assessment Framework, the Equality Act 2010, the Care Act 2014, the Mental Capacity Act 2005, the Human Rights Act 1998, UK GDPR and the Data Protection Act 2018.

The aim of this policy is to ensure that people are not placed at a disadvantage because information is inaccessible or because communication support is not provided. This includes ensuring that people can make informed decisions, give or withhold consent, access services, understand care and support information, raise concerns or complaints, and participate fully in decisions about their care and support.

2. Scope

This policy applies to all staff, including permanent, temporary, agency, bank and volunteer workers, and to contractors or external professionals acting on behalf of {{org_field_name}}.

This policy applies to all people using the supported living service who have information or communication support needs because of a disability, impairment or sensory loss. It also applies to carers, family members, advocates or representatives involved in a person’s care where they themselves have information or communication support needs related to disability, impairment or sensory loss.

This policy applies to all forms of communication used by the service, including verbal communication, written information, care and support planning documents, consent forms, complaints information, safeguarding information, medication information, risk assessments, appointment information, digital communication, email, text message, video calls, online forms and emergency information.

The Accessible Information Standard does not cover spoken language interpretation or translation needs where these are unrelated to disability, impairment or sensory loss. However, {{org_field_name}} will still identify, record and meet spoken language interpretation or translation needs where required under person-centred care, consent, safety, safeguarding, equality, human rights or contractual requirements.

3. Related Policies

• SL07 – Person-Centred Care Policy
• SL08 – Dignity and Respect Policy
• SL34 – Confidentiality and Data Protection (GDPR) Policy
• SL39 – Mental Capacity and Deprivation of Liberty Safeguards Policy
• SL42 – Communication and Engagement with Service Users and Families Policy
• SL13 – Safeguarding Adults from Abuse and Improper Treatment Policy

4. Accessible Information Standard Requirements: Identify, Record, Flag, Share, Meet and Review

4.1 Identifying Information and Communication Needs

Staff must identify whether a person has information or communication support needs because of a disability, impairment or sensory loss. This must be considered at the earliest opportunity, including during initial enquiry, assessment, commencement of support, care and support planning, reviews, safeguarding concerns, complaints, hospital admissions or discharges, and whenever the person’s needs appear to change.

Staff must ask the person, in a respectful and person-centred way, whether they need information in a different format or need support to communicate. Staff must not make assumptions based only on diagnosis, appearance, age, behaviour, speech or previous records.

Staff must identify and record whether the person needs, for example:

• information in large print, braille, audio, easy read, electronic format, pictorial format or another accessible format;
• support from a British Sign Language interpreter, deafblind interpreter, speech-to-text reporter, communication professional, advocate or other communication support worker;
• support to use hearing aids, glasses, communication aids, objects of reference, pictures, symbols, Makaton, Talking Mats, communication passports, health passports or assistive technology;
• correspondence by a preferred method, such as email, text message, telephone, video call, letter, audio message or communication through a nominated representative where lawful and appropriate;
• more time, a quiet environment, repetition, simplified language, visual prompts or support to check understanding.

Where a person lacks capacity to make a specific decision about communication or information sharing, staff must follow the Mental Capacity Act 2005 and act in the person’s best interests, involving those who know the person well where appropriate and lawful.

4.2 Record information and communication needs

All identified information and communication support needs must be recorded clearly, accurately and consistently in the person’s care and support records. This must include:

• the person’s specific need;
• the accessible format or communication support required;
• the person’s preferred contact method;
• any equipment, communication aid, professional support or environmental adjustment required;
• whether the need applies to all communication or only to specific circumstances;
• whether information can be shared with family, carers, advocates or professionals, and the legal basis for doing so;
• the date the need was identified or reviewed;
• the name and role of the staff member who recorded or updated the information.

Where records are paper-based, the information must be recorded in a consistent and easily visible place in the person’s file and care plan. Where records are electronic, the information must be recorded in the designated section for communication needs, accessibility needs or reasonable adjustments.

Staff must ensure that records are accurate, kept up to date and reviewed whenever the person’s communication needs change, when care plans are reviewed, when demographic information is checked, following incidents or complaints involving communication, and at least annually.

4.3 Flag information and communication needs

Staff must make sure that recorded information and communication support needs are clearly flagged so that all relevant staff can see them quickly and act on them. Flags may include alerts on electronic care records, clearly marked communication sections in care plans, front-sheet prompts, handover notes, communication passports or other approved systems.

A flag must not contain unnecessary sensitive information. It must tell staff what action is required, for example: “Provide information in easy read”, “Use BSL interpreter for formal meetings”, “Contact by text message”, or “Allow extra time and use picture prompts”.

Where electronic systems are used, the system should prompt staff to take appropriate action and should prevent standard-format correspondence being sent where an alternative format is recorded as required.

4.4 Share information and communication needs

Information about a person’s communication and information needs must be shared with relevant staff and, where appropriate, with other health and social care professionals involved in the person’s care so that the person receives consistent communication support.

Information must only be shared where there is a lawful basis to do so. Wherever possible, the person’s consent must be sought and recorded before sharing information with external professionals, family members, representatives or advocates. Where the person lacks capacity to consent to sharing, staff must follow the Mental Capacity Act 2005 and make a best interests decision where required.

Staff must share communication needs when this is necessary for safe and effective care, including during referrals, hospital admissions, hospital discharges, safeguarding enquiries, emergency situations, appointments, reviews, transitions between services and changes in support arrangements.

When sharing information, staff must include the practical actions required to meet the person’s needs, not just the diagnosis or impairment. For example, staff must record “requires information in easy read and needs time to process information” rather than only “learning disability”.

4.5 Meet identified information and communication needs

{{org_field_name}} must take reasonable and timely steps to ensure that people receive information in a format they can access and understand and receive the communication support they need.

Staff must not rely only on standard written information where this does not meet the person’s needs. Staff must provide or arrange appropriate support, which may include:

• easy read information using plain language, images and accessible layout;
• large print, braille, audio or electronic documents;
• information compatible with screen readers or other assistive technology;
• British Sign Language interpreters or other qualified communication professionals;
• speech-to-text reporting, video relay services or text relay services;
• communication aids, pictures, symbols, objects of reference, Makaton, Talking Mats or communication passports;
• support to use hearing aids, glasses or other assistive equipment;
• additional time for discussions, reviews, complaints, consent discussions and appointments;
• quiet spaces, reduced distractions or familiar staff support where this helps the person communicate;
• support from an advocate where required.

Staff must check that the person has understood important information, especially information about consent, care and support arrangements, risk, safeguarding, medication, complaints, tenancy-related support, finances, restrictions, changes to care, emergency procedures or health appointments.

Family members, friends or other people close to the person must not be used as interpreters or communication support for formal, sensitive, safeguarding, complaints, consent or legal discussions unless this is the person’s informed choice, it is appropriate, there is no conflict of interest, and the arrangement does not compromise confidentiality, safety or accuracy.

Communication support must also be provided in urgent or emergency situations as soon as reasonably practicable, taking account of the person’s immediate safety and wellbeing.

4.6 Review information and communication needs

Information and communication support needs must be reviewed regularly to ensure they remain accurate and are being met. Reviews must take place:

• during scheduled care and support plan reviews;
• when the person’s needs, diagnosis, impairment, sensory loss or circumstances change;
• after hospital admission or discharge;
• after a safeguarding concern, complaint, incident or near miss involving communication;
• when the person, family member, advocate, staff member or professional raises a concern about communication;
• when demographic or personal information is checked or updated;
• at least annually.

The review must consider whether:

• the recorded need is still accurate;
• the flag or alert is visible and effective;
• staff are consistently meeting the person’s needs;
• external professionals are being informed where appropriate;
• accessible formats and communication support are being provided in a timely way;
• the person is satisfied with how information is provided and how communication is supported;
• any further reasonable adjustments are required.

Any changes must be updated immediately in the person’s care records and communicated to relevant staff.

4.7 Staff training and responsibilities

All staff must receive training and guidance appropriate to their role so they can identify, record, flag, share, meet and review people’s information and communication support needs.

Training must include:

• the Accessible Information Standard and how it applies to supported living;
• how to ask people about communication needs in a respectful and person-centred way;
• how to record and flag needs accurately;
• how to provide information in accessible formats;
• how to arrange communication support, including BSL interpreters or other communication professionals where required;
• how to check understanding without patronising or disempowering the person;
• confidentiality, consent, UK GDPR and Data Protection Act 2018 requirements;
• Equality Act 2010 reasonable adjustments;
• Mental Capacity Act 2005 requirements where a person may lack capacity for a specific decision;
• how communication failures can create safeguarding, consent, medication, complaints or safety risks.

All staff must also receive learning disability and autism training appropriate to their role, in line with the statutory requirement introduced by the Health and Care Act 2022 and the Oliver McGowan code of practice where applicable.

The Registered Manager is responsible for ensuring that staff understand and implement this policy. {{org_field_name}} will nominate an Accessible Information Standard lead who will monitor implementation, support staff practice, review audits and ensure action is taken where improvements are required.

4.8 Digital, online and written accessibility

Where {{org_field_name}} uses websites, online forms, digital care systems, email, text messaging, video calls, portals, apps or electronic documents to communicate with people, these must be as accessible as reasonably practicable and must not create barriers for people with disability-related information or communication needs.

The Accessible Information Standard does not directly cover websites. However, where staff direct a person to online information as part of their care or support, staff must check whether the person can access and understand that information. If the person cannot access the online information because of disability, impairment or sensory loss, staff must provide the information in another accessible format.

Digital information and documents must be designed so that they are compatible with assistive technology where reasonably practicable. This includes using accessible document formats, clear headings, readable fonts, meaningful links, appropriate colour contrast, alt text for meaningful images, plain language and accessible PDFs or alternatives to PDFs.

Where the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 apply, websites and mobile applications must meet the applicable accessibility requirements, including WCAG 2.2 AA unless a lawful exemption or disproportionate burden applies.

People must always be offered a non-digital communication option where digital communication does not meet their needs.

4.9 Monitoring, audit and quality assurance

{{org_field_name}} will monitor compliance with this policy through regular quality assurance checks, care record audits, staff supervision, feedback from people using the service, complaints analysis, incident reviews, safeguarding reviews and service improvement planning.

Audits must check whether:

• communication and information needs have been identified;
• needs are recorded clearly and consistently;
• needs are flagged so staff can see and act on them;
• information is shared lawfully and appropriately;
• accessible formats and communication support are provided in practice;
• staff know how to meet the person’s needs;
• the person, and where appropriate their representative, confirms that communication support is effective;
• needs have been reviewed and updated;
• complaints, incidents or safeguarding concerns show any communication-related learning.

{{org_field_name}} will use the Accessible Information Standard self-assessment framework, or an equivalent internal assurance process, to assess compliance, identify gaps, develop improvement actions and monitor progress.

Where audits identify non-compliance, the Registered Manager must ensure that corrective action is taken. This may include updating records, arranging communication support, revising care plans, providing staff supervision, arranging additional training, changing systems or escalating risks to senior management.

5. Confidentiality, consent and data protection

Information about a person’s communication and information support needs is personal data and must be handled in line with UK GDPR, the Data Protection Act 2018, confidentiality requirements and {{org_field_name}}’s data protection policies.

Staff must record and share information about communication needs only where there is a lawful basis to do so. Where information is shared with external professionals, family members, advocates or representatives, staff must ensure that consent has been obtained where required and that the sharing is necessary, proportionate and in the person’s interests.

People must be told what information is recorded about their communication needs and, where possible, must be supported to check that the information is accurate. Where a person has access to their own records, they must be supported to request corrections if their communication or information needs are wrong or out of date.

Where a person lacks capacity to make a specific decision about sharing information, staff must follow the Mental Capacity Act 2005 and make a best interests decision where required. Records must clearly explain the decision, who was involved and why the information was shared.

Information about communication needs must be shared securely and only with people who need it to provide safe, effective, person-centred care and support.

6. Reasonable adjustments, consent and mental capacity

{{org_field_name}} will make reasonable adjustments to ensure that people are not substantially disadvantaged because of disability, impairment or sensory loss. Reasonable adjustments may include changes to communication methods, accessible information formats, additional time, communication aids, environmental adjustments, staff support, advocacy or professional communication support.

Accessible information and communication support must be provided before asking a person to make a decision, give consent, agree to care or support, sign documents, take part in reviews, respond to safeguarding concerns, make a complaint or understand changes to their support.

Where there is doubt about a person’s capacity to make a specific decision, staff must not assume incapacity because the person communicates differently or needs information in an accessible format. Staff must first provide all practicable support to help the person understand, retain, use or weigh the relevant information and communicate their decision.

Where the person lacks capacity for the specific decision, staff must follow the Mental Capacity Act 2005, act in the person’s best interests and use the least restrictive option. Communication needs and reasonable adjustments must still be identified, recorded, flagged, shared, met and reviewed.

7. Complaints, safeguarding and emergency communication

People must be able to raise concerns, make complaints and take part in safeguarding processes in a way that is accessible to them. Complaints information, safeguarding information and feedback processes must be available in accessible formats or with communication support where required.

Staff must ensure that communication support is provided where a person needs to understand or participate in:

• safeguarding enquiries or meetings;
• complaints or investigations;
• best interests meetings;
• risk management discussions;
• medication discussions;
• tenancy-related support discussions;
• hospital admission or discharge planning;
• emergency planning;
• changes to care or support.

Where there is an urgent risk to the person’s safety or wellbeing, staff must take immediate action to keep the person safe while arranging communication support as soon as reasonably practicable. Any communication barriers that affected safety, consent, safeguarding, complaints or care delivery must be recorded, reviewed and used to improve practice.

8. Policy review

This policy will be reviewed at least annually or sooner where there are changes to legislation, statutory guidance, NHS England Accessible Information Standard requirements, CQC guidance, CQC assessment expectations, organisational systems, audit findings, complaints, incidents, safeguarding concerns or feedback from people using the service.

The review must consider whether the policy remains effective in ensuring that information and communication needs are identified, recorded, flagged, shared, met and reviewed in line with the Accessible Information Standard and CQC expectations.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
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