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DCW104-Supporting Employees with Disabilities Policy

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Registration Number: {{org_field_registration_no}}

Supporting Employees with Disabilities Policy

1. Purpose

The purpose of this policy is to ensure that {{org_field_name}} provides an inclusive, safe, supportive and accessible workplace for disabled employees, workers, job applicants, volunteers where applicable, and employees with long-term physical or mental health conditions. {{org_field_name}} is committed to preventing disability discrimination, harassment and victimisation, making reasonable adjustments, supporting staff health and well-being, and ensuring that employment practices are consistent with the Equality Act 2010, the Health and Safety at Work etc. Act 1974, the Regulation and Inspection of Social Care (Wales) Act 2016, The Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017 as amended, Welsh Government statutory guidance for domiciliary support services, Social Care Wales requirements, and CIW inspection expectations.

This policy supports safe, lawful and person-centred service delivery by ensuring that any support or adjustment for a disabled employee is considered alongside the employee’s rights, the safety and well-being of people receiving care and support, staffing continuity, the statement of purpose, and the provider’s duty to deploy sufficient numbers of suitably qualified, trained, skilled, competent and experienced staff.

Our objectives are to:

2. Scope

This policy applies to:

For the purposes of this policy, “staff” includes employees and workers employed by {{org_field_name}}, persons engaged under a contract for services, and agency staff where they are deployed to work within the service. Volunteers are not “staff” under the Regulations, but where volunteers are used, {{org_field_name}} will apply the principles of this policy as far as appropriate to their role, safety and involvement with the service.

Where agency workers or contractors are used, {{org_field_name}} will take reasonable steps to ensure that any disability-related adjustments required for safe working are considered before deployment, while maintaining confidentiality and ensuring the person remains suitable for the duties they are asked to perform.

3. Legal and Regulatory Framework

This policy aligns with the following legislation, statutory guidance and regulatory expectations:

4. Definition of Disability

According to the Equality Act 2010, a disability is a physical or mental impairment that has a substantial and long-term effect on an individual’s ability to carry out normal daily activities. This includes but is not limited to:

Disabilities may be visible, non-visible, fluctuating, progressive, temporary in presentation but long-term in effect, or related to physical health, mental health, sensory impairment, neurodivergence, cognitive functioning, chronic pain, fatigue, medication side effects, or long-term medical treatment. {{org_field_name}} will not make assumptions about a person’s disability, capability, support needs or fitness for work.

Employees and applicants are not required to disclose a disability unless they choose to do so. However, where {{org_field_name}} knows, or could reasonably be expected to know, that a person is disabled or may require support, managers must consider whether reasonable adjustments are required.

Information about disability, health, occupational health advice, Access to Work recommendations, reasonable adjustments and related correspondence will be treated as confidential special category information and handled in accordance with data protection requirements. It will only be shared with those who need the information to implement agreed support, ensure safe working, meet regulatory duties, or comply with legal obligations.

How we manage this efficiently:

5. Reasonable Adjustment Procedure

5.1 Requesting reasonable adjustments

A disabled employee, worker, job applicant or member of staff with a physical or mental health condition may request reasonable adjustments at any stage of recruitment, employment, induction, training, supervision, performance management, sickness absence management, return to work, rota planning, or career development. Requests may be made verbally or in writing to a line manager, the Registered Manager, HR or the nominated senior person.

Managers must also consider reasonable adjustments where they know, or could reasonably be expected to know, that a person may be disabled or may be experiencing a substantial disadvantage at work because of a disability or health condition.

5.2 Adjustment meeting

Where a request is made, the manager will arrange a confidential discussion with the employee or applicant as soon as reasonably practicable. The purpose of the discussion is to understand the barrier or disadvantage, the person’s views, the impact on their role, the impact on safe service delivery, and the adjustments that may remove or reduce the disadvantage. Managers must listen, avoid assumptions, consider the person’s specific circumstances, and involve the person in identifying workable options.

5.3 Examples of reasonable adjustments

Reasonable adjustments may include, but are not limited to: changes to recruitment processes; accessible application forms or interview arrangements; modified duties; adjusted working hours; amended shift patterns; additional breaks; phased return to work; changes to rota allocation; reduced or adjusted travel where this is reasonable and compatible with service need; assistive technology; adapted equipment; changes to communication methods; accessible training materials; additional supervision or mentoring; changes to trigger points in absence management where appropriate; changes to work location where feasible; reallocating non-essential duties; or temporary adjustments while specialist advice is obtained.

5.4 Occupational health, medical advice and Access to Work

Where specialist advice is needed, {{org_field_name}} may seek occupational health advice, medical advice, Access to Work advice, or advice from other relevant professionals. The employee’s consent will be obtained before medical or occupational health information is requested. Employees may also be supported to apply for Access to Work where extra help, equipment, travel support, communication support or workplace support may be available.

5.5 Decision and confirmation

The manager will confirm agreed reasonable adjustments in writing, including what has been agreed, who is responsible for implementing the adjustment, any timescale, whether the adjustment is temporary or ongoing, and the review date. Where an adjustment is not agreed, the reason must be explained in writing and alternative options must be considered wherever possible. A refusal must be based on objective reasons, such as effectiveness, practicability, health and safety, impact on regulated service delivery, impact on people receiving care and support, cost, available resources, or inability to maintain safe staffing. Legal or HR advice should be sought before refusing an adjustment.

5.6 Review

Reasonable adjustments will be reviewed at agreed intervals and sooner if the employee’s role changes, their health changes, the service need changes, there is a change in rota or location, concerns arise about safe working, the employee returns from absence, new equipment or technology is introduced, or the employee requests a review.

6. Recruitment, Selection, and Employment Adjustments

6.1 Inclusive Recruitment Practices

Recruitment decisions must be based on the applicant’s ability to meet the essential requirements of the role, with reasonable adjustments where required. Managers must not ask health or disability questions before making a job offer except where permitted by law, for example to establish whether reasonable adjustments are needed for the recruitment process, to assess whether the applicant can carry out a function intrinsic to the role with reasonable adjustments, to monitor diversity, or where there is another lawful reason.

Where an applicant discloses a disability or health condition, this information must be handled confidentially and must not be used to reject the applicant unless, after considering reasonable adjustments, the applicant cannot safely and effectively carry out duties that are intrinsic to the role.

For domiciliary care roles, recruitment and selection will consider the genuine requirements of the role, which may include lone working, travel between calls, communication with individuals, moving and handling, medication support where applicable, recording care accurately, safeguarding responsibilities, and the ability to respond to emergencies. These requirements must be assessed fairly and individually, with reasonable adjustments considered before any decision is made.

6.2 Employment Adjustments and Workplace Modifications

{{org_field_name}} will consider reasonable adjustments to remove or reduce disability-related disadvantage at work. Adjustments will be considered individually and may relate to duties, hours, shift patterns, travel, rotas, breaks, training, supervision, communication, equipment, technology, work location, phased return, sickness absence processes, performance management, or other employment arrangements.

In a domiciliary support service, any adjustment must also be considered alongside the provider’s duty to ensure safe, reliable and person-centred care; continuity of care; safe staffing; suitable deployment; staff competence; and the care and support needs of individuals receiving the service. Adjustments must not result in unsafe working, missed calls, rushed calls, unsafe medication support, unsafe moving and handling, unmanaged lone working risk, or a failure to meet personal plans. Where an adjustment affects rota planning, travel time, call allocation or continuity of care, this must be discussed with the Registered Manager before implementation.

Where an employee’s disability or health condition affects driving, travel, manual handling, lone working, medication support, personal care tasks, communication, emergency response, or any other intrinsic part of their role, {{org_field_name}} will complete an individual risk assessment and consider reasonable adjustments before deciding whether the employee can continue in that duty, requires adjusted duties, requires additional support, or should be temporarily redeployed.

6.3 Fitness of Staff and Safe Deployment

Under Regulation 35, {{org_field_name}} must ensure that staff are fit to work at the service. This includes being of suitable integrity and good character, having the qualifications, skills, competence and experience necessary for the role, and being able, by reason of their health after reasonable adjustments are made, to properly perform the tasks that are intrinsic to the work for which they are employed or engaged.

A disability or health condition does not automatically mean that a person is unfit for work. The service will first consider reasonable adjustments, risk assessment, occupational health advice where appropriate, training, supervision, equipment, redeployment options, and temporary support.

Where, after reasonable adjustments have been considered, an employee cannot safely perform duties that are intrinsic to their role, the Registered Manager and HR or nominated senior person will consider the available options. These may include adjusted duties, alternative duties, redeployment, phased return, further medical advice, capability management, or other appropriate employment action. Any decision must be documented and based on evidence, not assumptions.

Where there are concerns that an employee’s health, disability or support needs may affect safe care delivery, the Registered Manager must ensure that individuals receiving care and support are not placed at risk and that staffing arrangements remain compliant with the statement of purpose, personal plans, safe staffing requirements and CIW expectations.

7. Workplace Accessibility and Support

7.1 Physical and Environmental Adjustments

{{org_field_name}} will take reasonable steps to ensure that premises under its control, including offices, training rooms and staff facilities, are accessible and safe for disabled employees, including consideration of step-free access, accessible toilets, lighting, signage, seating, workstation layout, hearing support, visual alerts, and emergency arrangements where reasonably practicable.

Because domiciliary care is delivered in individuals’ own homes and community settings that are not fully controlled by {{org_field_name}}, the service cannot guarantee that every work location will be fully accessible. However, {{org_field_name}} will assess known access, environmental, travel, parking, lone working, infection prevention, moving and handling, and communication risks, and will make reasonable adjustments to work allocation, equipment, support arrangements or duties where required and practicable.

Where an employee may need assistance to evacuate premises controlled by {{org_field_name}}, a Personal Emergency Evacuation Plan (PEEP) will be completed with the employee and reviewed if their needs, work location or emergency arrangements change. Where staff work in individuals’ homes, relevant emergency arrangements will be considered through lone working, environmental and care delivery risk assessments.

7.2 Assistive Technology and Digital Accessibility

Where electronic care planning, rostering, medication, training, HR or communication systems are used, {{org_field_name}} will consider reasonable adjustments to enable disabled employees to use those systems effectively. This may include screen readers, voice-to-text, magnification, colour contrast, alternative input devices, accessible templates, additional training, modified notification settings, or alternative recording arrangements where safe and lawful.

Any alternative recording arrangement must still ensure accurate, timely, confidential and auditable records in line with regulatory, contractual and data protection requirements.

How we manage this efficiently:

8. Mental Health and Well-being Support

8.1 Promoting Mental Health Awareness

8.2 Managing Stress and Preventing Workplace Discrimination

Where work-related stress, anxiety, depression, trauma, burnout or another mental health concern may be linked to the employee’s work, the manager will consider whether an individual stress risk assessment is required. This may include consideration of workload, rota patterns, travel time, lone working, exposure to distressing situations, safeguarding incidents, challenging behaviour, bereavement, complaints, supervision, team support, communication, and rest breaks.

Reasonable adjustments for mental health may include changes to workload, temporary changes to rota or duties, additional supervision, debriefing after incidents, modified communication, protected breaks, phased return, mentoring, or temporary removal from particular duties where this is reasonable and compatible with safe service delivery.

How we manage this efficiently:

9. Training and Awareness for Staff and Managers

9.1 Disability Awareness Training

All staff will receive information appropriate to their role on equality, diversity, inclusion, disability awareness, respectful communication, anti-discriminatory practice, confidentiality, and the importance of reasonable adjustments. Managers will receive additional guidance on identifying and responding to reasonable adjustment requests, avoiding assumptions, recording decisions, reviewing adjustments, managing disability-related absence, supporting neurodivergent staff, and balancing adjustments with safe staffing and regulated service delivery.

Training and guidance will reflect current law, Welsh domiciliary care regulatory expectations, Social Care Wales Codes of Professional Practice where applicable, and the organisation’s statement of purpose.

9.2 Staff Responsibilities in Supporting Colleagues with Disabilities

All employees are expected to foster an inclusive and supportive environment.

Employees should respect colleagues’ privacy and must not ask intrusive questions, disclose another person’s disability or health information, or undermine agreed reasonable adjustments. Concerns about discrimination, harassment, bullying, victimisation, unsafe working, failure to implement agreed adjustments, or barriers affecting a colleague’s ability to work safely should be raised with the line manager, Registered Manager, HR or nominated senior person. Where the concern relates to unsafe care, safeguarding, whistleblowing or fitness to practise, the relevant safeguarding, whistleblowing, disciplinary or professional referral procedure must also be followed.

How we manage this efficiently:

10. Social Care Wales Registration and Professional Responsibilities

Where an employee is required to register with Social Care Wales or another professional regulator, {{org_field_name}} will provide reasonable support to help the employee maintain registration, meet continuing professional development requirements, and practise in accordance with the relevant Code of Professional Practice.

Reasonable adjustments may be considered to support training, supervision, assessment, written work, reflective practice, communication, and access to learning. However, adjustments must not remove essential professional standards, registration requirements, safe practice requirements, safeguarding duties, medication safety, moving and handling safety, record keeping accuracy, or the employee’s responsibility to work within their competence.

Where disability, health, conduct, competence or practice concerns may affect safe practice, the Registered Manager will consider support, supervision, training, occupational health advice, reasonable adjustments, capability processes, disciplinary processes, safeguarding duties, and whether referral to Social Care Wales or another professional body is required.

11. Career Progression and Equal Opportunities

11.1 Development and Promotion Opportunities

Reasonable adjustments will be considered for training, qualifications, supervision, appraisals, competency assessments, interviews, promotion processes, leadership development, meetings and work-related events. Disabled employees must not be disadvantaged because a process, format, location, assessment method, communication method or timetable is inaccessible where a reasonable adjustment could remove or reduce the disadvantage.

11.2 Support in Returning to Work After Absence

Employees returning from disability-related absence, long-term sickness absence, injury, mental health absence, treatment, surgery, relapse or a change in condition will be offered a return-to-work discussion. Where appropriate, {{org_field_name}} will consider a phased return, temporary adjustments, amended duties, amended hours, amended rota patterns, additional supervision, refresher training, occupational health advice, equipment, Access to Work support, or redeployment options.

A return-to-work plan will be agreed in writing where required. The plan will identify any temporary or permanent adjustments, review dates, any restrictions, any support required, and how safe service delivery will be maintained. Where the employee works in domiciliary care, the plan must consider travel time, lone working, manual handling, medication support, personal care duties, call duration, continuity of care, emergency response, and the needs of individuals receiving care and support.

Disability-related absence will be considered sensitively and individually. Managers must consider whether absence management triggers, performance expectations, meeting arrangements or communication methods require reasonable adjustment.

12. Reporting Concerns, Grievances and Escalation

Employees who believe they have experienced disability discrimination, harassment, victimisation, failure to make reasonable adjustments, bullying, unfair treatment, breach of confidentiality, or unsafe working arrangements may raise the matter with their line manager, Registered Manager, HR or nominated senior person. Where informal resolution is not appropriate or does not resolve the matter, the employee may use the grievance procedure.

Concerns will be handled confidentially, fairly, promptly and without victimisation. Records will be kept of the concern, actions taken, decisions made, adjustments considered, outcomes and review arrangements.

Where a concern indicates a risk to people receiving care and support, unsafe staffing, safeguarding risk, whistleblowing concern, fitness of staff issue, or potential breach of regulatory requirements, the Registered Manager and Responsible Individual must ensure that the relevant safeguarding, whistleblowing, disciplinary, notification, professional referral or quality assurance process is followed.

Employees will not be treated unfavourably for requesting reasonable adjustments, raising disability-related concerns, supporting a colleague, making a grievance, or participating in an investigation in good faith.

13. Records, Monitoring and CIW Evidence

{{org_field_name}} will keep appropriate confidential records of reasonable adjustment requests, meetings, decisions, occupational health or Access to Work recommendations, agreed adjustments, review dates, risk assessments, return-to-work plans, training adjustments, and any reasons for refusing or amending an adjustment. These records will be stored securely and accessed only by those who need the information for lawful management, safety, regulatory, HR or employment purposes.

The Registered Manager will monitor implementation of agreed adjustments through supervision, return-to-work reviews, appraisal, rota review, incident review, sickness absence review, staff feedback and quality assurance processes.

The Responsible Individual will maintain oversight of how the service supports disabled staff and how staffing arrangements continue to meet regulatory requirements. Evidence may be considered within governance, quality assurance and leadership and management review processes, while preserving individual confidentiality.

Where disability-related adjustments affect staffing levels, deployment, travel time, continuity of care, staff competence, training, supervision or service delivery, the impact must be assessed and documented to demonstrate that individuals receiving care and support remain safe and that the service continues to operate in accordance with its statement of purpose.

14. Domiciliary Care Specific Considerations

Because domiciliary care is delivered in individuals’ homes and community settings, reasonable adjustments for staff must be considered alongside the safety, rights and preferences of individuals receiving care and support. Adjustments must be planned so that care visits are not rushed, missed, shortened inappropriately, or delivered by staff who do not have the required competence, training or support.

Where an employee’s disability or health condition affects their ability to travel, drive, walk distances, climb stairs, work alone, use equipment, complete moving and handling tasks, provide personal care, support medication, communicate effectively, manage emergencies, or complete electronic or written records, the manager will consider reasonable adjustments and risk controls. These may include changes to call allocation, pairing arrangements, equipment, route planning, travel time, temporary changes to duties, additional training, alternative communication methods, or referral for specialist advice.

Any adjustment that changes a staff member’s availability, travel pattern, call allocation or duty range must be considered by the Registered Manager so that the service continues to meet Regulation 34 staffing requirements and Regulation 41 requirements on care time, travel time and schedules of visits.

15. Related Policies

This policy aligns with:

16. Policy Review

This policy will be reviewed at least annually, or sooner where there are changes to legislation, Welsh Government statutory guidance, CIW inspection or rating requirements, Social Care Wales requirements, employment law, health and safety guidance, the statement of purpose, service delivery model, staffing arrangements, or learning from complaints, grievances, incidents, safeguarding concerns, staff feedback, inspection findings or quality assurance activity.

The Registered Manager is responsible for day-to-day implementation of this policy. The Responsible Individual is responsible for maintaining oversight of its effective operation and ensuring that any impact on safe staffing, staff support, service quality and regulatory compliance is considered through governance and quality assurance arrangements.

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}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.

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