In accordance with the requirements of the Disability Inclusion Regulations 2019, DIT released for public consultation a draft Framework for our Disability Access and Inclusion Plan by Public Notice in the South Australian Advertiser newspaper on Saturday 18 April 2020, inviting “people with disability, their carers, family, organisations and other interested parties to provide feedback”. The consultation period extended to 15 May 2020. Requests for extension of the consultation period were received and late submissions were accepted.
The draft Framework and feedback submission form were made available as advertised on the Department’s website, and submissions were invited to be submitted via email or phone. Additionally, community members were invited to contact the Disability Access and Inclusion Team if they wanted to discuss alternative avenues of consultation, or desired to receive the DAIP in an alternative version such as Easy Read.
The public consultation was also announced to all staff, and the draft Framework disseminated to all staff inviting feedback, via broadcast email on Friday 17 April 2020.
In addition to the advertised Public Notice, the draft framework was provided to the Department of Human Services to invite feedback from the Disability Engagement Group, as well as distributed to various other stakeholders known to the Department from across the disability sector and community, including all organisational members of the DAIC for provision to their communities.
Key findings and amendments arising from consultation
Public and internal consultation on the draft DAIP Framework resulted in twenty submissions. This included Departmental employees and directorates, members of the community with lived experience of disability, colleagues from other State authorities, and leaders from the disability advocacy and community services sectors, both in their capacity as individuals and representing organisations.
All submissions were of a very high quality and the Department would like to thank respondents for participating in the consultation process, and thereby assisting DIT to ensure that the Department’s first Disability Access and Inclusion Plan under the Disability Inclusion Act 2018 is informed by insightful and broad ranging contributions from a diverse group of stakeholders.
The key issues raised through consultation submissions, and how the Department incorporated that feedback in the DAIP Action Plan, are detailed below.
Community engagement, communications and feedback
The importance of genuine community engagement, greater communication of Departmental services and changes to service delivery, and timely responsiveness to customer feedback were highlighted through consultation, and are priority areas for the Department. A key goal of the DAIP and other Departmental strategies is to ensure that we are communicating clearly and keeping our customers and the community informed, and that we are meeting the expectations of the community in the way we undertake community engagement.
In support of this priority, DIT announced the creation of a new Division of Public Affairs in August 2020, to renew and strengthen the functions of community consultation and engagement, customer service and stakeholder relations, and public communications. Within the DAIP Action Plan, this includes commitments to ensure:
- Communications are available in a range of accessible formats.
- Department websites and online services are fully compliant with the State Government’s Online Accessibility Policy.
- Staff have tools and resources to ensure that community engagement, consultation and communications are inclusive and accessible to all.
- Complaints and feedback systems are accessible, responsive and consistent, and feedback is reaching the right people and informing the development and review of Departmental policy, programs and services.
The DAIP Action Plan has also been amended following consultation to incorporate feedback that measurable targets could be clearer in some cases to ensure greater accountability.
Public transport services
Some respondents were concerned with ensuring that people living with disability are informed about the relative accessibility of elements of the public transport system and the Department will continue to investigate opportunities for improvement in this area. The DAIP includes commitments to develop an access guide and to expand the availability and accessibility of information about our services.
As the Department’s complaints and feedback systems get better at capturing and analysing real-time information from the community, this data will inform our priorities for ongoing improvement works to infrastructure across the road network and the Adelaide Metropolitan Passenger Rail Network (AMPRN).
Additionally, we acknowledge feedback related to the provision of accessible parking at public transport nodes and commit to ensuring that all new and significantly upgraded public transport premises meet or exceed the Disability (Access to Premises – Buildings) Standards, including through the provision of accessible parking spaces.
Consultation also highlighted the need for Aboriginal people with disability to feel culturally safe on public transport services, particularly in relation to interactions with staff. Our Department has been a leader within State Government in this area with the implementation of the WHS Framework for Cultural Safety in 2019.
The DIT Cultural Safety Procedure supports our commitment to treating all cultural safety issues seriously, and provides for culturally appropriate reporting of incidents. The Procedure also ensures that our longstanding Aboriginal Engagement and Inclusion Team will be engaged as a key stakeholder on all cultural safety issues, whether the impact is to a member of staff or the community.
A part of how we achieve these goals will be improving disability awareness and understanding for staff including on public transport services.
Consultation feedback included concerns regarding ongoing accessibility issues for pedestrians, in particular related to paths of travel along main roads and intersections. This feedback informed the development of DAIP commitments relating to the road network. Our Road and Marine Services and Public Affairs Divisions will collaborate with our Disability Access and Inclusion Team on strategies to improve how community feedback informs investment priorities in this area. The DAIP also reflects our ongoing commitment for the Disability Access and Inclusion Committee to be consulted on a range of accessibility matters and concerns.
Training and Awareness
The need to improve understanding and awareness of the rights and diverse needs of people living with disability was raised through consultation and is a priority area in the DAIP Action Plan. Disability awareness training for customer service staff, and people managing civil construction works impacting pedestrian accessibility were particularly highlighted by respondents, and these will be priority focus areas for the Department in our research and development of targeted disability awareness training packages for staff. The Department will also implement a recommendation from consultation to work collaboratively across government and in particular in partnership with the Office of the Commissioner for Public Sector Employment (OCPSE) in our review of disability awareness training.