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{{org_field_name}}

Registration Number: {{org_field_registration_no}}


Supporting Employees with Disabilities Policy

1. Purpose and Commitment

The purpose of this policy is to outline how {{org_field_name}} supports employees with disabilities, ensuring they are treated fairly, provided with equal opportunities, and empowered to perform their roles effectively. Our commitment is to foster an inclusive workplace culture where employees with disabilities can thrive while contributing meaningfully to our organisation.

{{org_field_name}} will comply with the Equality Act 2010, the Health and Safety at Work etc. Act 1974, the Management of Health and Safety at Work Regulations 1999, the Employment Rights Act 1996, the UK General Data Protection Regulation, the Data Protection Act 2018 and other applicable employment legislation. As a provider of regulated adult social care, we will also operate this policy consistently with the Health and Social Care Act 2008, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 and relevant Care Quality Commission guidance.

We are committed to preventing disability discrimination, removing or reducing workplace disadvantages, making reasonable adjustments and enabling disabled employees to contribute safely and effectively. This commitment applies throughout recruitment, employment, training, promotion, performance management, sickness absence, disciplinary and capability procedures, organisational change and termination of employment.

2. Scope

This policy applies to all employees of {{org_field_name}}, including care workers, office-based staff, managers, apprentices, temporary employees and employees working remotely or within people’s homes.

The principles of dignity, inclusion, accessibility and non-discrimination also apply, where relevant, to job applicants, workers, agency staff, volunteers, contractors and self-employed persons. However, the precise statutory rights, duties and contractual arrangements applying to these groups may differ. Agency workers’ employment-related requests may need to be addressed jointly with the supplying employment business.

It covers:

The policy applies across all settings, including office environments, service users’ homes, and remote working arrangements.

3. Definitions

3.1 Disability

For the purposes of this policy, a person is disabled where they have a physical or mental impairment that has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities, as defined by the Equality Act 2010.

“Substantial” means more than minor or trivial. “Long-term” generally means that the effect has lasted, or is likely to last, for at least 12 months or for the remainder of the person’s life. Some conditions are treated as disabilities from diagnosis, including cancer, HIV infection and multiple sclerosis. A person may also be protected where the effects of an impairment are controlled by medication, treatment, aids or other measures.

3.2 Disabled employee

In this policy, “disabled employee” includes an employee who meets the Equality Act 2010 definition of disability. It may also include a person with a long-term physical or mental health condition where the organisation considers that support or workplace adjustments would be appropriate, even where the statutory definition has not yet been established.

3.3 Reasonable adjustment

A reasonable adjustment is a change made to remove or reduce a substantial disadvantage experienced by a disabled person in comparison with a person who is not disabled. Adjustments may relate to a workplace provision, criterion or practice; a physical feature; or the provision of an auxiliary aid, equipment, information or support.

3.4 Neurodiversity

Neurodiversity describes natural differences in how people think, learn, communicate and process information. Neurodivergent conditions may include autism, attention deficit hyperactivity disorder, dyslexia, dyspraxia, dyscalculia and Tourette syndrome. A neurodivergent person may be disabled under the Equality Act 2010, depending on the effect of their condition.

4. Policy Statement

{{org_field_name}} is committed to:

We believe that a diverse workforce enhances our ability to provide compassionate, person-centred care while reflecting the communities we serve.

5. Legal Framework and Responsibilities

5.1 Equality Act 2010

{{org_field_name}} will not unlawfully discriminate against a person because of disability. Prohibited conduct may include:

Protection applies to recruitment, terms and conditions, pay, allocation of work, working patterns, training, development, promotion, benefits, performance management, absence management, disciplinary and capability proceedings, dismissal and other detriment.

The organisation will also take reasonable steps to prevent disability-related harassment by colleagues, managers, contractors, people receiving care or other third parties encountered during work.

5.2 Health and Safety at Work Act 1974

We are committed to ensuring a safe working environment for employees with disabilities by conducting regular risk assessments and implementing appropriate safety measures.

5.3 Employer Responsibilities

{{org_field_name}} is responsible for:

5.4 Employee Responsibilities

Employees are encouraged to:

Employees are not required to disclose a diagnosis merely because they have a disability. However, the organisation may be unable to provide particular support where it has not been informed of the relevant workplace disadvantage or support need.

6. Inclusive Recruitment and Onboarding

6.1 Accessible Recruitment Practices

We promote fair and inclusive recruitment by:

Vacancy information will explain how applicants can request reasonable adjustments to the recruitment process and will provide an accessible contact route.

Except where permitted by law, the organisation will not ask an applicant questions about their health or disability before making a job offer or before placing them in a pool of applicants from whom a successful candidate will be selected.

Permitted questions may include questions that are necessary to:

Recruitment decisions will be based on the applicant’s ability to perform the essential requirements of the role with reasonable adjustments where required. Information provided solely for equality monitoring will not be available to the selection panel.

6.2 Reasonable Adjustments During Onboarding

Following a conditional job offer, the organisation will invite the successful applicant to identify any workplace barriers or adjustments they may require. An individual workplace assessment or occupational health assessment will be arranged only where it is necessary, proportionate and relevant to the role or the person’s support needs.

Onboarding information and mandatory training will be made available in an accessible format where required. The organisation will agree the relevant format with the employee rather than assuming that every disabled employee requires the same form of communication.

7. Reasonable Adjustments in the Workplace

7.1 Identifying Reasonable Adjustments

Reasonable adjustments are changes made to support employees with disabilities in performing their roles effectively. These may include:

7.2 Requesting, Considering and Implementing Adjustments

A request may be made verbally or in writing to a line manager, Human Resources or another appropriate manager. No particular form of words is required, and the employee does not need to refer expressly to the Equality Act 2010.

The manager will arrange a private discussion with the employee as soon as reasonably practicable. The discussion will consider:

The organisation will respond promptly and will confirm agreed adjustments in writing. The written record will identify:

Adjustments will be reviewed at agreed intervals and whenever the employee’s role, health, work location, duties or circumstances change.

Where a requested adjustment cannot be agreed, the organisation will explain its reasons in writing, identify the factors considered and discuss suitable alternatives. The employee may request a review by a manager who was not responsible for the original decision. The employee may also use the grievance procedure.

7.3 Reasonableness, Cost and Access to Work

An employee or applicant will not be required to pay for a reasonable adjustment.

In determining whether an adjustment is reasonable, the organisation may consider:

These factors will be considered objectively and on the facts of the individual case. General inconvenience, assumptions, custom and practice, or an unsupported reference to “operational requirements” will not be treated as sufficient reasons to refuse an adjustment.

Access to Work may provide advice or financial assistance for support beyond the adjustments that the employer is legally required to make. The organisation will support an employee with an Access to Work application where appropriate. Access to Work funding will not be used as a reason to delay an adjustment that the organisation is legally required to provide.

7.4 Workplace Adjustment Record

With the employee’s agreement, the organisation may maintain a workplace adjustment record or adjustment passport. Its purpose is to:

The record will not contain more medical information than is necessary. It will be stored securely and accessed only by authorised persons with a genuine need to know. The employee will be involved in deciding what information may be shared.

8. Training, Career Development, and Progression

8.1 Inclusive Training

We ensure all training programmes are accessible, including:

Managers responsible for recruitment, supervision, absence, performance, disciplinary or capability decisions will receive appropriate training on disability discrimination, reasonable adjustments, accessible communication, confidentiality, neurodiversity and disability-related absence. Training will be refreshed periodically and when relevant legislation, guidance or organisational procedures change.

8.2 Career Development and Mentorship

Employees with disabilities are supported in their career development through:

8.3 Performance, Conduct and Capability

Disabled employees are required to meet the legitimate and essential standards of their role. Before beginning or progressing formal performance, conduct or capability action, the manager will consider whether:

Reasonable adjustments do not require the organisation to remove an essential function of a role or accept unsafe care. However, the organisation will consider adjustments, additional support, retraining, redeployment and suitable alternative employment before deciding that an employee cannot continue in their role.

Records will show that disability and reasonable adjustments were properly considered before any formal outcome was reached.

9. Health, Safety, and Well-Being

9.1 Health and Safety Risk Assessment

{{org_field_name}} will make suitable and sufficient assessments of risks arising from its work activities and will review those assessments where circumstances change.

A separate risk assessment will not be carried out automatically merely because a person is disabled. Where the organisation becomes aware that a disability or health condition may affect an existing workplace risk, it will review the relevant assessment in consultation with the employee.

Risk assessments will:

Health and safety requirements will not be used as an unsupported reason to reject a disabled person, remove duties or refuse an adjustment. Where a significant residual risk remains, the organisation will document the evidence, advice, alternatives considered and reasons for its decision.

9.2 Emergency and Evacuation Arrangements

Where an employee may require assistance during an emergency, the organisation will consult the employee and develop appropriate emergency arrangements. Depending on the workplace and role, this may include a personal emergency evacuation plan, alternative communication arrangements, nominated assistance, accessible alarms, evacuation equipment or arrangements for remote and community working.

Emergency information will be shared only with those who need it to protect the employee or others. Arrangements will be tested and reviewed periodically and whenever relevant circumstances change.

9.3 Mental Health and Well-Being

Supporting mental health is integral to our approach. We provide:

Mental health conditions will be treated with the same seriousness and confidentiality as physical health conditions. Managers will avoid requiring an employee to provide a particular diagnosis before discussing workplace barriers or possible support.

Support may include a wellness action plan, predictable communication, adjusted supervision, agreed methods for giving feedback, temporary workload changes, adjusted hours, time for treatment or a phased return to work.

The organisation will monitor staff wellbeing, sickness, turnover, workload and feedback to identify organisational risks and opportunities for improvement.

9.4 Sickness Absence, Disability-Related Absence and Return to Work

Disability-related absence will be managed fairly, consistently and sensitively. The organisation will consider whether an absence, lateness or reduced attendance is related to disability before applying absence triggers, warnings or formal action.

Reasonable adjustments may include:

Adjusting an absence trigger does not necessarily mean disregarding all disability-related absence. Decisions will be based on the individual circumstances, the effectiveness of available adjustments, the needs of the service and the requirement to provide safe and reliable care.

Before formal capability action or dismissal is considered, the organisation will review reasonable adjustments, obtain appropriate medical or occupational health advice where necessary, consult the employee and consider suitable alternative work or redeployment.

Employees will be informed of their right to be accompanied at formal meetings in accordance with the organisation’s procedures and applicable law.

10. Confidentiality and Data Protection

10.1 Confidentiality and Sharing of Disability Information

Information about an employee’s disability or health is confidential and will not be shared merely because it may be useful or interesting to others.

Information will be shared only where there is a lawful, necessary and proportionate reason, including:

Wherever reasonably practicable, the organisation will discuss with the employee what information needs to be shared, why it must be shared, with whom and for how long. In most cases, managers and colleagues need to know the adjustment or action required rather than the employee’s diagnosis.

Confidentiality may be overridden where disclosure is required by law or is necessary to protect life or prevent serious harm. Any disclosure will be limited to the minimum necessary information.

10.2 UK GDPR and Data Protection Act 2018

Disability and health information is personal data and will usually constitute special category personal data. {{org_field_name}} will process such information in accordance with the UK General Data Protection Regulation, the Data Protection Act 2018 and the organisation’s privacy notices and data protection policies.

Before processing health or disability information, the organisation will identify:

The organisation will:

Consent will not automatically be relied upon as the lawful basis for routine employment processing because consent may not always be freely given within an employment relationship.

11. Addressing Discrimination and Harassment

11.1 Prohibition of Discrimination, Harassment and Victimisation

{{org_field_name}} prohibits unlawful discrimination, harassment and victimisation. All concerns will be taken seriously and addressed fairly and proportionately.

Disability-related harassment may include:

This prohibition applies to conduct by employees, managers, agency workers, contractors and, where reasonably preventable, third parties such as people receiving care, relatives or visitors.

11.2 Reporting and Investigation

Employees can report concerns through:

All reports are investigated promptly, and appropriate action is taken.

An employee will not be subjected to victimisation for raising a concern in good faith, requesting an adjustment, supporting another person’s complaint or participating in an investigation.

Concerns will be considered under the grievance, dignity at work, whistleblowing or safeguarding procedure, depending on the nature of the matter. Where alleged conduct by a person receiving care or a relative affects an employee, the organisation will assess risks, support the employee and take reasonable steps consistent with its duties to both the employee and the person receiving care.

12. Communication and Awareness

12.1 Promoting Disability Awareness

 We promote disability awareness through:

12.2 Inclusive Communication

We ensure all communication is accessible, including:

The employee will be consulted about their preferred communication method. Family members, colleagues or people receiving care will not normally be used as interpreters for confidential or formal employment discussions.

13. Monitoring and Continuous Improvement

13.1 Regular Reviews

We regularly review policies and practices to identify:

Monitoring may include anonymised information concerning:

Monitoring information will be used to identify disproportionate outcomes, barriers, delays or recurring failures to implement adjustments. Reports will normally use aggregated or anonymised information to protect confidentiality.

13.2 Feedback and Engagement

Employee feedback informs continuous improvement. We encourage employees to share experiences, suggestions, and concerns through:

13.3 Records and Accountability

The Registered Manager has overall responsibility for ensuring that this policy is implemented within the service. Line managers are responsible for identifying concerns, responding to adjustment requests, maintaining appropriate records and obtaining advice where necessary.

Human Resources, or the person carrying out that function, is responsible for providing procedural advice, monitoring consistency and supporting compliance with employment and equality law.

Records relating to an individual employee may include:

These records will be maintained in accordance with the organisation’s retention schedule and data protection requirements.

14. Disability-Related Leave

Disability-related leave is time away from work for a reason connected with disability. It may include time for:

Disability-related leave is not automatically additional paid leave. The organisation will consider whether paid leave, unpaid leave, adjusted hours, flexible working, annual leave or another arrangement is reasonable in the individual circumstances.

The employee and manager should agree, where practicable, how planned disability-related leave will be requested, authorised and recorded. Recording arrangements must not result in unlawful disadvantage.

15. Occupational Health and Medical Advice

The organisation may seek occupational health or other specialist advice where reasonably necessary to understand:

Occupational health advice supports but does not replace consultation with the employee or management decision-making. Managers remain responsible for deciding what adjustments are reasonable.

The organisation will explain the purpose of a referral, the questions to be asked and how the resulting information will be used. Medical reports and occupational health information will be obtained and processed in accordance with applicable law, confidentiality requirements and the organisation’s data protection procedures.

Where an employee does not agree to provide relevant information or participate in an assessment, the organisation will make decisions on the information reasonably available. No adverse inference will be automatic, and the employee will be given an opportunity to explain their concerns.

16. Redeployment and Alternative Employment

Where an employee cannot continue in their substantive role even after reasonable adjustments have been considered, the organisation will consider whether redeployment to a suitable vacant role would be a reasonable adjustment.

The organisation will:

The organisation is not required to create a role where no suitable work exists, displace another employee or appoint a person who cannot perform the essential requirements of the alternative role after reasonable adjustments.

Redeployment considerations and outcomes will be documented before employment is terminated on capability grounds.

17. Compliance and Policy Review

17.1 Legal and Regulatory Framework

This policy will be implemented with reference to applicable legislation and guidance, including:

In relation to regulated care, this policy particularly supports:

17.2 Policy Review

This policy will be reviewed at least annually and sooner where:

The review will consider both the wording of the policy and evidence of its implementation. Material changes will be communicated to employees and managers, and relevant training will be updated.


Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on:
{{last_update_date}}
Next Review Date:
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Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.

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