Reasonable Adjustments Protocol

A positive approach
Personal Risk Assessment
The starting point
The legal duty
Who is 'disabled'?
What are reasonable adjustments?
Why are reasonable adjustments needed?
Who has responsibility for making reasonable adjustments?
Who determines what is reasonable?
Who pays?
The duty in practice
Recruitment and selection
Workplace adjustments
Identifying needs in the workplace
Implementing reasonable adjustments
Emerging needs
Records and confidentiality
The Force Personal Emergency Evacuation Plan
Disability related leave
Paid leave
Useful contacts
Disability friendly products
Appendix One: Force Forms to record and review reasonable
Appendix Two: Examples of reasonable adjustments during the
recruitment and selection process
Appendix Three: Examples of adjustments that could be
considered in the workplace
The Equality Act 2010 requires employers to make reasonable adjustments where
the application of a provision, criterion or practice or access to premises puts people
with a disability at a substantial disadvantage to people who are not disabled. This
legislation covers police staff, police officers, special constables, trainees and any
other people working or applying to work for Wiltshire Police.
Reasonable adjustments are modifications that ensure that disabled applicants and
staff are not placed at a disadvantage and to provide equal access to opportunities in
the workplace.
Making reasonable adjustments in the workplace is a simple management function. It
makes good business sense to ensure that all our staff have everything they may
reasonably need to do their jobs well. This document is intended to provide guidance
to managers, who are responsible for making reasonable adjustments.
The Force forms for recording and monitoring reasonable adjustments are provided
at Appendix One.
For recording and monitoring purposes the form contained within Appendix 1 should
be utilised.
Please note, prior to commencing the reasonable adjustments process, a personal
risk assessment must be carried out. This requirement is in accordance with the
provisions of the Management of Health and Safety at Work Regulations 1999 which
states a risk assessment is required when an individual has notified the organisation
that they are unfit for duty or experience health changes.
Stereotypes are limited and limiting.
Here are some common assumptions, which may limit opportunities for people who
have a disability MYTH
Disability doesn’t affect that many
Over 8 million people in the UK have a
disability. It is also estimated that
disability affects one in four people
(including carers, relatives, etc)
Disability isn't a work issue
Most disabled people acquire their
disability during their working life (approx.
3% are born with their disability)
Most disabled people use a wheelchair
95% of disabled people do not use a
People with disabilities have lots of
extra needs
80% of disabled people do not require an
adjustment to their workplace
Reasonable adjustments cost too much
44% of reasonable adjustments cost less
than £50 – funding is also available from
the Jobcentre Plus via the ‘Access to
Work’ scheme
Disabled people take too much time off
80% of businesses say their disabled
staff have the same, or better attendance
records than their non-disabled
Source: Remploy & Employers' Forum on Disability
There are over 5 million disabled people of working age in the UK – this is a big
labour market we could miss out on if we fail to dispel myths and prejudice and
neglect to make reasonable adjustments where required.
It is important that decisions about reasonable adjustments are informed and not
based on assumptions about what people with a certain type of disability can or
cannot do.
The Equality Act 2010
Under the new Equality Act 2010, disabled people are protected from discrimination,
harassment and victimisation on the grounds of ‘discrimination arising from a
disability’. The Act also makes it unlawful for an employer not to make a 'reasonable'
adjustment for someone with a disability, both in the recruitment and selection
processes and in the workplace. This also includes probation, PDR, promotion
processes and career development opportunities.
Who is ‘disabled’?
Under section e of the Equality Act, a person has a disability if:
 They have a physical or mental impairment, and
 The impairment has a substantial and long-term adverse effect on their ability
to carry out normal day-to-day activities."
This is quite a broad definition, which is not limited to visible disabilities. For example,
the definition cover people with dyslexia, cancer, HIV, back problems and
What are reasonable adjustments?
Reasonable adjustments are simply modifications that take into account the effects of
an individual's disability. For example, modifications could be made to –
A selection process (i.e. providing forms in Braille)
The premises or workplace (i.e. installing a hands-free telephone)
Ways of working (i.e. colour coding a filing system)
Hours or place of work (i.e. working around medication requirements)
Leave provisions (i.e. time off for physiotherapy)
Support at work (i.e. a mentor)
Training provisions (i.e. training to use voice activated software)
Communication methods (i.e. large print manuals)
Reasonable adjustments in selection processes are intended to ensure that disabled
applicants are able to compete fairly with non-disabled applicants. They are not
intended to give an unfair advantage to disabled candidates.
Reasonable adjustments in the workplace are intended to ensure that staff with
disabilities have everything they reasonably need to perform their role effectively.
Many non-disabled people expect a suitable chair, table, lighting, stationery and
equipment to be provided so that they can perform their role; people with a disability
have the right to expect that their needs will also be met.
Why are reasonable adjustments needed?
The ‘social model’ of disability offers a different perspective to the Equality Act
definition of disability -
“‘The loss or limitation of opportunity to take part in society on an equal level with
others due to social and environmental barriers”
The social model reminds us that treating everyone the same does not always mean
treating people fairly; making reasonable adjustments recognises that each individual
has individual needs and ensures that disabled staff can access the same
opportunities as non-disabled staff.
Who has responsibility for making reasonable adjustments?
The line manager is responsible for making decisions and implementing reasonable
adjustments. However, their decisions must be informed by expert advice, for
example from the line manager, the relevant HR Partner, as well as the appropriate
specialists or approved specialist body and the disabled person. The Occupational
Health Team should also be consulted. They can obtain expert advice from the
appropriate specialist.
Jobcentre Plus also provides Disability Employment Advisors who can offer advice
on adjustments in the workplace called Access to Work. All reasonable adjustments
should be recorded using the forms in Appendix One.
Who determines what is ‘reasonable’?
It is lawful to decline a request for an ‘unreasonable adjustment’. However, only an
Employment Tribunal can decide what is reasonable in particular circumstances for
each organisation under the Equality Act, but factors such as the size and resources
of an organisation as well as health and safety considerations are likely to be taken
into account. Consideration should also be given to the likely effectiveness of the
adjustment and the practicalities of implementation.
Employers will have to provide a strong justification to defend a failure to make an
adjustment and prove that it really was ’unreasonable’. Employment Tribunals can
order organisations and individuals to make payment of unlimited compensation to
successful claimants under the Equality Act 2010.
It is important that managers consider all the options available and consult the
relevant specialists and the employee before deciding that adjustments can or cannot
be made. Decisions must be informed and not based on assumptions.
Who pays?
Where the implementation of a reasonable adjustment incurs cost, the Equality Act
2010 expects that employers will cover this.
Most reasonable adjustments, are very simple, cost effective and can be charged to
the relevant internal budget. For example, if an officer with a learning difficulty
requires blue paper to print and read from, this would come under the same budget
as any other office stationery.
Funding assistance is also available from your local Jobcentre Plus through the
‘Access to Work’ scheme. This allows the organisation to identify what an individual
requires, with the assistance of a Disability Employment Advisor, then seek approval
for funding assistance. If Jobcentre Plus agrees to provide funding assistance, you
can procure the required products and then claim back the agreed level of funding.
All applicants for police officer, special constabulary and police staff roles are asked
whether they require any reasonable adjustments on the application form and in
invitation to interview letters. The Recruitment Team will inform interview panels of
any adjustments requested; it is the responsibility of the interview panel to ensure
that reasonable adjustments are implemented.
The duty to make reasonable adjustments in selection processes doesn’t just apply
to entry-level recruitment but also to selection processes for career development,
specialist posts and promotion opportunities. In order to comply with the Equality Act,
reasonable requests should always be accommodated. Please use the forms at
Appendix One to record any adjustment requests. See Appendix 2 for examples of
reasonable adjustments.
Reasonable adjustments in the workplace vary according to individual need. All
adjustment requests should be recorded using the forms at Appendix One.
Identifying needs in the workplace
In most cases, an individual knows that they have a disability and tells the
organisation so that the necessary steps can be taken to meet their needs and
maximise their performance at work. However, there are also members of staff who
discover a learning difficulty or develop a medical condition later in their career.
Managers are advised to be proactive and seek expert advice if they notice any
trends such as behavioural differences, discrepancies between ability and
performance or recurring health issues; it may be that someone is unaware that they
have a disability. It should also be noted that some staff with disabilities might be
reluctant to disclose their disability if they fear that the organisation will not respond
Often, disabled staff will be able to identify their own needs in the workplace, but the
relevant specialists, HR Partner/OH and Line Manager should also generate ideas.
Advice is also available from your Jobcentre Plus Disability Employment Advisor.
Whilst it can be useful to consult with other colleagues who are known to have a
specific disability and are happy to share their insight and experience, every
individual’s needs are different and this should considered objectively. For example,
one officer with dyslexia may benefit from a talking calculator and another may have
no need, nor see any need, for such a tool. Ultimately, it is the employer's legal duty
to identify and make the reasonable adjustments. For examples of reasonable
adjustments, see Appendix 3 – Examples of adjustments that could be considered in
the workplace.
Implementing reasonable adjustments
Once an individual’s needs have been identified, the reasonable adjustments should
be implemented as soon as possible. If there is a delay, the individual should not be
placed at a disadvantage. Consideration should be given to providing alternative
suitable work or paid leave whilst the reasonable adjustments are awaited if
necessary. The following points are critical success factors –
Communication – involve the individual and keep them informed of progress
Timeliness - implement adjustments without undue delay
Support – ensure that the individual has the support they need
Risk assessment – ensure that new equipment or furniture has been risk
assessed to ensure no adverse impact on health & safety in the workplace
 Training & familiarisation – ensure that the individual is trained in how to use
any new equipment – they should be allowed time to adjust to new ways of
working or using new technology (this should be taken into account in any
performance reviews)
 Regular review – the line manager should meet with the individual regularly to
ensure that their needs are still being met. The Force has an obligation to review
adjustments at least annually but many adjustments will require more frequent
reviews, particularly in the initial stages.
Emerging needs
Whilst many reasonable adjustments are made as a ‘one-off’ solution to assist the
individual in their role, there may be times when additional adjustments are required.
For example –
Following a transfer or re-alignment of responsibilities
To access a training event/course
To participate in a career development scheme
Following a promotion or new role
Following an intense period of rehabilitation or treatment
To attend a regional meeting or seminar
Due to implementation of new working methods or technology
Following a change in the nature of a condition
Following a period of absence
It has been identified that an aspect of the role or workplace is exacerbating the
 During a grievance or disciplinary procedure
 Due to a change in personal circumstances
 To alleviate the impact of a period of potential stress at work (i.e. re-structures or
implementation of new IT systems)
‘Access to Work’ funding may be available from Jobcentre Plus to assist in making
such adjustments.
Records and confidentiality
Line managers must complete the forms at Appendix One and submit these to the
HR Business Centre to ensure that adjustments are recorded and monitored.
Adjustments will be recorded on the computerised HR System for monitoring
purposes; access to these records is restricted.
Details of someone's disability should only be disclosed on a 'need to know' basis.
Often, it is not the name of the disability that needs to be disclosed but the
individual's requirements or the effects of the medical condition or learning disability.
For example, if someone is going on a course, the trainer needs to know what
reasonable adjustments are required, but may not need to know what the individual's
disability is. In any case, managers should consult with the individual.
Please note that under the Equality Act 2010 if a member of staff tells a manager that
they have a disability, the organisation is considered to know about the disability and
will be expected to fulfil its legal duty to make reasonable adjustments. Therefore,
managers should explain to staff that they will need to inform the relevant specialists
(i.e. HR/OH but assure staff that details of their disability will only be shared on a
'need to know' basis.
The Force Personal Emergency Evacuation Plan (PEEP).
Where appropriate, line managers must complete the Force Personal Emergency
Evacuation Plan (PEEP) Form in consultation with the individual. This form is used
for all disabled employees and other persons who may require assistance to ensure
their safe evacuation in the event of a fire/emergency.
Disability Related Leave
Providing disability related leave may also be considered a reasonable adjustment.
Disability related leave enables a worker to adjust to changes caused by the
development of a new disability, or to manage an existing disability. This type of
leave covers time off for therapy, hospital appointments, rehabilitation, assessment,
treatment, or training, but not sickness. This type of leave plays an important part in
keeping an individual fit for their role.
Disability related leave must not be used to cover periods of sickness absence,
whether or not the sickness absence is directly related to the person’s disability.
Disability related leave is generally for a fixed period of time, whether one-off or a
regular appointment. It is usually known about in advance and arrangements should
be made with line managers to take this type of leave. See Attendance Management
Examples could include  Allowing time off work for an individual with Parkinson’s disease to undertake a
programme of physiotherapy
 Providing leave to an individual to receive treatment such as psychotherapy
 Allowing absence for a worker who is developing a hearing impairment to
undertake a British Sign Language course
 Providing leave for a worker with visual impairment to attend a four-week
residential course to be trained to use a new guide dog
 Allowing a worker with a back problem to see a physiotherapist in duty time once a
 Providing time off for a worker receiving treatment for cancer
Managers will need to consider whether each request is reasonable, and whether it is
reasonable to provide paid leave or unpaid leave. This should be done in
consultation with HR. Disability related leave should not be included in Bradford
Score calculations.
Paid leave
Please note that if someone is off work because the organisation has not yet
provided the required reasonable adjustments, this is not disability related leave or
disability related sickness. It is paid leave because the individual is willing to work,
but they are not able to, because the organisation is not fulfilling its duty to make
reasonable adjustments.
Procedures Reasonable adjustments may also be made in the following people management
procedures –
Attendance management - absence monitoring and sick pay
Probationary performance assessments
Performance & Development Reviews
Training and career development schemes
Grievance and discipline procedures
Transfer, promotion and specialist post selection processes
Allocation/accessibility of benefits and facilities
This list is not exhaustive and it is important to note that managers will have to liaise
with specialists to determine what is reasonable in each individual case.
It is also important to remember to undertake a risk assessment on any reasonable
adjustment to ensure that new equipment or furniture does not have an adverse
impact on safety in the workplace.
Reasonable adjustments should also be considered within role specific procedures
such as 
Giving evidence in court
Taking statements
Taking details from the public
Driving police vehicles
Recording or remembering details
Exercise of police powers
Sitting on boards or project teams
Liaising with partner organisations
This may require liaison with other partner organisations and community groups.
Again, this will ensure that individuals have what they need in every aspect of their
Useful Contacts
Contact details
Disability Employment
Jobcentre Plus
Ask your local Jobcentre Plus
Equalities and Human
Rights Commission
Telephone 020 3117 0235
(non helpline calls only)
Fax 0203 117 0237
Telephone: 0845 155 2700
Fax: 0845 155 2701
Minicom: 0845 155 0532
Support workers to assist
employers and individuals
Retention advice
Return to work advice
Equality Act advice
British Council of
Disabled People
Tel: 01332 295551
Fax: 01332 295580
Minicom: 01332 295581
Transcription service
National Disabled
Police Association
(Met Police)
Tel: 0207 321 (4) 8717
Fax: 0207 321 8716
Support network
Sharing good practice
Advice on disability issues in
the workplace
'Access to work' funding for
reasonable adjustments
Equality Act advice/helpline
Code of practice – Equality
FAQs website
Conciliation service
Disability friendly products
The following websites are also useful for identifying disability friendly products from
large-font keyboards to specialised desks:
For advice on making Microsoft products accessible, visit their website at:
The Disability Equipment Register is a nationwide service to buy and sell used
disability equipment directly from or to other users - Tel:
01454 318818
Some of these organisations can also provide after-sales training to ensure that
disabled staff can use the equipment effectively.
Some disability organisations also offer hire of specialist equipment, which is
particularly useful for interviews and temporary staff.
You can also seek advice on disability issues from your local HR Partner, the Force
Equality & Diversity Manager, and Occupational Health Team.
Name of staff member to whom the adjustment applies:
Job title:
Pin/Collar Number:
List details of any Health and Safety Issues identified in the personal risk assessment:
Date the personal risk assessment was carried out:
Details of other specialists either present at the interview and/or previously contacted:
Name of manager co-ordinating the adjustment process:
Manager’s job title:
What adjustments are considered necessary. Please provide details:-
If the disability or learning difficulty is newly diagnosed, has the individual discussed the matter with a Specialist Adviser. What
adjustments could be considered/are available. Please provide details:-
If reasonable adjustments require the involvement and co-operation of colleagues, describe what is likely to be required and how
this is to be actioned. (In agreement with the individual).
Manager advises/consults with Safety Representative; risk assessment of any new equipment or furniture to ensure no adverse
impact on workplace safety.
Detail any issues raised during this meeting.
Line Manager - Please now complete Part B of this form
Activities which
require adjustment
Description of adjustment
Name of person undertaking
How will the
adjustment be
What effect will this
have on existing
Reasonable adjustments agreed with
post holder:
Extension Number:
Describe, if
measures to protect
staff and/or public
Agree frequency of
Print Name
Collar Number
Line manager - Please send completed forms (Part A and Part B) to the HR Business Centre.
HR Business Centre – Copy to the HR Partner and for entering data onto the HR System.
Date of Review
Description of
adjustments made
Observations on
Monitoring exercise undertaken by:
Consultation with
Consultation with
local safety
Remedial follow up
Agreed with Post Holder:
Which manager
will be
Date of next review:
Line manager - Please send completed forms (Part A and Part B) to the HR Business Centre.
HR Business Centre – Copy to the HR Partner and for entering data onto the HR System.
Appendix 2
Examples of reasonable adjustments during the recruitment and selection process.
 Providing application forms and job details in an alternative format such as large print,
tape or Braille
 Holding the interview in a room which is easily accessed by an applicant who uses a
walking frame
 Allowing a dyslexic candidate to bring an aide-memoir/notes to interview
 Providing a British Sign Language Interpreter
 Allowing an applicant with a learning disability or mental health problem to be
accompanied by a mentor or friend
 Ensuring the interview room has appropriate lighting for a partially sighted interviewee
or an applicant with photosensitive epilepsy
 Providing a seat, table and power point for a palantypist accompanying a candidate with
a hearing impairment
 Giving 25% extra time in an exam to a candidate with a learning difficulty such as
dyslexia or dyspraxia
 Allowing a candidate with a visual impairment to take a written test orally
 Hiring a hands free keyboard to enable a candidate with severe upper limb disorder to
undertake a typing test
 Considering disabled applicants who can fulfil a substantial part of the role
Appendix 3
Examples of adjustments that could be considered in the workplace:
Premises / workplace  Providing tactile indicators on stair rails, switches, buttons, etc for a visually impaired
 Installing a telephone with controllable amplification for a worker with a hearing
 Providing a ‘reading machine’ (optical character recognition system) which scans and
reads aloud text for a visually impaired worker or a worker with a learning difficulty
 Installing soundproofing or visual barriers to minimise distractions for a worker with a
learning disability
Supplying matt pastel coloured paper and colour coded filing systems for a worker with
Installing a hands free keyboard for a worker with upper limb disorder
Providing ergonomic furniture/equipment for a worker with tendonitis
Providing a refrigerator (either in an office or in a vehicle) for storage of insulin for a
diabetic worker
Providing a place for a worker with HIV to store medication safely and confidentially
Installing hand rails to enable a worker with a mobility impairment to use walkways,
especially ramps
Relocating light switches and shelves for someone who has difficulty in reaching
Providing appropriate contrast in décor to help the safe mobility of a worker with a
visual impairment
Providing an accessible disabled parking bay for someone with restricted mobility
Training colleagues in first aid procedures to support a co-worker who experiences
epileptic seizures (with the individual's permission)
Providing extra support during induction training for a worker with a disability which
affects their confidence and memory skills
Communication  Providing a trained lip speaker to assist in lip reading for a worker who is deaf
 Providing reference manuals/policies, etc in large print, tape or Braille
 Producing written summaries of detailed verbal information for a dyslexic colleague
 Giving aide-memoirs or demonstrations to consolidate verbal instructions given to a
team member with a learning disability
 Adjusting the way instructions are given to a worker with a mental health problem
 Allowing time for reflection and response to verbal information given to workers with
learning difficulties
 Having regular meetings to review how reasonable adjustments are working and to
ensure that team members are supportive
Working hours or place of work 
Agreeing a flexible pattern of working and meal breaks for a worker with diabetes
Scheduling duties around the effects of someone's medication
Agreeing working hours to accommodate travel requirements
Agreeing a transfer to more suitable or accessible premises for a worker to undertake
their role
Considering occasional home-working
Providing training 
Training someone how to use any equipment that has been provided as a reasonable
Providing training materials in large print, tape, Braille, etc
Making reasonable adjustments to training such as extra time, e-learning access and
training techniques tailored to individual needs
Support 
Providing a support worker to assist a worker with restricted manual dexterity to
undertake filing duties
Allocating a mentor for a worker whose disability leads to uncertainty or lack of
confidence in the workplace
Re-alignment of duties among a team, making use of each member's ability
Regular meetings to ensure that reasonable adjustments are still meeting the
individual's needs and to ensure that colleagues are also being supportive
Holding an awareness session on a specific disability for colleagues (only with the
individual's consent)
Changing roles 
Re-aligning duties within a team to utilise each member's abilities
Allocating an aspect of the job to another colleague
Where it is not possible for a disabled team member to continue in their role, to
organise re-deployment to a suitable role. Consideration should also be given to
providing training to increase re-deployment options
Creating a disability-friendly workplace
There are simple things that we can all do to improve the quality of the working
environment for staff with disabilities:
 Disabled parking bays - these bays are dedicated for use by staff and visitors who have
a disabled parking permit. Please ensure that no-one shows disrespect for diversity by
abusing this facility
 Planning meetings / events – ask all attendees whether they have any specific
requirements to attend or participate in the meeting
 Coaching or training – ask individuals if they have any specific requirements to assist
them in gaining the most from their learning
 Communication methods – make use of a wide range of communication methods.
When you give your contact details out, do you include e-mail and fax number? Could
you learn British Sign Language?
 Raise awareness – managers and staff can raise their awareness of disability issues to
prevent unwitting prejudice and harassment of disabled staff and to ensure that
disability-friendly practices are adopted - the further reading and useful contacts
sections are a good starting point