Memoranda submitted by the Royal National Institute for the Deaf


About RNID

1. RNID is the largest charity dedicated to the UK's 9 million deaf and hard of hearing people. Our vision is of a world where deafness or hearing loss do not limit or determine opportunity, and where people value their hearing.


2. We aim to achieve this vision by campaigning and lobbying vigorously, by raising awareness of deafness and hearing loss, by providing services and support, and through social, medical and technical research.


3. We welcome the opportunity to feed into the Work and Pensions Committee's inquiry into the Equality Bill and what steps the Department for Work and Pensions should take to achieve greater equality. We use the term 'deaf people' to refer to deaf, deafened and hard of hearing people throughout.


Executive summary

4. RNID welcomes the Equality Bill as an opportunity to streamline discrimination legislation, ensure comprehensive rights, remove disparity between strands and strengthen enforcement.


5. RNID is part of the Disability Charities Consortium (DCC), whose priorities for the Bill include: a comprehensive definition of discrimination; extension of protection to people who experience discrimination and/or harassment because of association with a disabled person; retain the key principles of the disability equality duty; strengthen the enforcement of equality legislation.


6. The Equality Bill must anticipate the new obligations that will be laid out in the EU Equality Directive, which RNID welcomes for the comprehensive and enforceable minimum standards it will provide for protection against discrimination in non-employment areas across Europe.


7. RNID calls on the Government to ratify the UN Disability Convention without undue delay and without reservations or interpretative declarations.


8. There are many positive actions that the DWP has taken to help protect deaf people from discrimination, such as the Access to Work programme, but there is more that the Department can do to promote what is already in place and further mechanisms that can be introduced to ensure greater equality for deaf people.


Equality in employment

9. The introduction of the Disability Discrimination Act 1995 was welcomed as a positive step for the UK's 9 million deaf people, providing deaf people with enforceable human rights. Other Government actions, such as the introduction of the Access to Work scheme, have had a positive impact on deaf people in employment.


10. However, deaf people still face barriers to gaining and retaining employment. Deaf people have experienced higher rates of worklessness and for lengthier times than the general population, over an extended period of economic prosperity, and the employment rate for deaf people has not changed significantly since the introduction of the DDA despite a strong desire to find paid work.


11. RNID research shows that 63% of deaf people are currently in employment[1] compared to 75% of the general population[2]. 57% of deaf people had been looking for work for more than twelve months, this compared to only 20% of the total of unemployed people at the time[3].


12. This is partly due to the fact that statutory employment service provision has proved largely ineffective for deaf people. We are therefore concerned that the Government's plans for helping disabled people into work will not work for deaf people, and that they will be left behind. Supporting a profoundly deaf person into work takes a great deal of investment that some providers may not be prepared to meet.  The situation could be improved if the Government measured the outcomes of its employment programmes to show how people with different impairments and conditions fare on them. We believe that only those service providers who manage to succeed across the board should be rewarded with further contracts. 


13. The voluntary sector can play a pivotal role in ending inequality for disabled people in employment. RNID is keen to play our part in enabling deaf people into work, but the current arrangements mean that we are not being offered a fair price for success, and are asked by prime contractors to run our services at a loss.  We need a funding model that takes account not only of the actual costs to get someone into work, but of the need to invest and expand. We need a model that goes beyond full cost recovery. Deaf people need to have access to employment-related training that is accessible and viable in order to gain equality in employment. The Pathways to Work scheme, within which any provider must work, places smaller specialist providers such as RNID at a potential disadvantage.


14. Where successful Government initiatives to end inequality in employment are in place, there are issues around the promotion of them. For example, little awareness raising work amongst groups that stand to benefit most from the Access to Work scheme has been undertaken by the Government. It is hoped that the ongoing review of the scheme will see greater emphasis on targeting those (employers and employees) with the greatest need. A similar review of Remploy (which has few deaf employees) has freed up funding from sheltered employment to be invested in moving those with more complex barriers towards the open labour market.


15. We would also like to see Access to Work funding made available to volunteers, as volunteering is an important route into employment for deaf people, but many are blocked form this route as neither they nor the employer they are volunteering with can fund an auxiliary service such as a British Sign Language/English interpreter. It is also important that volunteers are protected against unfair treatment in light of Government proposals for 'community service' and requirements for British citizenship.


16. Additionally, we would like to see the Access to Work scheme opened up to all claimants of Employment and Support Allowance, with everyone entitled to a basic Access to Work assessment as part of their claim. This could occur at the time of the first mandatory Work-Focused Interview and would form a key part of the claimant's action plan. This would also allow for ESA claimants to experience the kinds of adjustments that Access to Work can provide as part of any vocational or training schemes that they may be part of.


16. It is also vital that employers are challenged about their attitudes towards deaf people and their abilities. Unless they change their practices and procedures, even the most highly trained and skilled deaf people will continue to be turned away. The Government's proposals for reforming the welfare system place the onus of responsibility for finding work on the individual working with private or voluntary employment service providers. However, there has been little or no comparable work with employers to improve recruitment or awareness of deaf or disabled people on the part of a Government that is very reluctant to add to the regulatory burden for business.


The public sector equality duty

17. The introduction of the Disability Equality Duty has ensured that public authorities must take action to promote equality and to eliminate discrimination and harassment, at the same time promoting positive attitudes towards deaf people and encouraging participation in public life.


18. RNID welcomes a single public sector equality duty and we believe that it is possible, and indeed necessary, to retain strand-specific duties, for instance the need to take into account a deaf person's needs, even where that involves treating a deaf person more favourably.


19. It is vital that the new equality duty is at least as effective as the existing disability equality duties.


20. We believe that a specific duty around public procurement is desirable as it would signal that public authorities can be held accountable when contracted services or publicly funded services are not compliant with disability equality. The Government's proposals on this issue outline a light-touch approach through encouraging greater transparency and improving use of purchase power but we do not believe that this goes far enough.


Social inequality

21. It is essential that anti-discrimination legislation be backed up by social policy measures that enable disabled people to live independently and enjoy the same opportunities, quality of life and respect as non-disabled people. RNID is committed to making this a reality through the supported housing we provide and our community and outreach work. We provide high quality care and support for deaf people who have additional needs. Our supported housing provides support for independent people who still need some level of assistance to live on their own and our community and outreach work allows us to support people living in their own homes who want help with daily living skills, finding work, college courses and training, accessing the deaf community, housing issues and social skills.


22. We are also working on a new community based residential care home in Derby for deaf people who have mental health support needs. The service will provide an increased level of independence for individuals who are not able to live fully indepently but who do not require institutional care.



23. On its introduction in 2005, the DDA did not cover education. This was rectified through the 2001 Special Education Needs and Disability Act (SENDA). There is strong evidence that deaf children need protection against discrimination in education. There is a wide educational attainment gap between deaf pupils and their hearing peers. In 2006, only 47% of pupils with a hearing impairment achieved level 4 or above at Key Stage 2 English, compared to 79% of all pupils[4]. In 2007 only 32.9% of hearing impaired children achieved five GCSEs at grades A to C, compared with a national average of 57.1 per cent[5]. Therefore it is important that the specific educational elements in the DDA are protected in any future legislation.



26 November 2008




[1] Opportunity Blocked, 2006 - The December 2006 Labour Force Survey estimated only 59% of those with 'difficulty in hearing', though has a high margin of error.

[2] Labour Force Survey, March 2008

[3] Extrapolation from the Labour Force Survey, March 2006

[4] Data based on Pupil Led Annual School Census Returns. The data refers only to pupils placed at School Action Plus and those with statements where hearing impairment is the prime type of special educational needs. Data on the attainment of deaf children placed at School Action of the SEN Code of Practice is unavailable as is data on children placed in independent schools.