Inspiring leaders to improve children's lives Mike Smith Lead Commissioner, Disability Harassment Inquiry Equality and Human Rights Commission Arndale House, The Arndale Centre Manchester M4 3AQ 9 February 2012 Dear Mike Thank you for providing us with the opportunity to comment on the outcome of the inquiry on disability-related harassment. We believe that the strength and effectiveness of a workforce and its leadership are enhanced by drawing on the talents and experiences of people from diverse backgrounds. In order to rise to the inherent challenges, we have developed a strategy which covers the National College's role in: external activity: as an authontattvs national voice on school and children's services leadership issues; delivery: as a commissioner and provider of leadership development and support; internal activity: as an employer. In a number of ways, activities identified in the core recommendations already underpin the College's strategy and some examples are given below. Our Executive Directors and Directors provide leadership to the College on equality issues and they are supported by our Governing Council. We have access to three dedicated Diversity Associates who work out in the field. They provide expert advice to the College on a range of diversity issues including support to the Equality and Diversity Manager in engaging with the College's programme teams to ensure that diversity/equality issues become mainstream activity. We, therefore, believe that there is real ownership and commitment from the top to drive forward transparency in our performance on all aspects of disability issues both in the College and within the activities we provide for our communities. Our Dignity at Work policy sets out our commitment to ensure fair treatment and dignity for all staff at work and for our clients. It prohibits all forms of harassment and bullying whether or not amounting to unlawful discrimination and all allegations result in a formal investigation lead by a senior manager. Our process ensures that any incident of harassment is automatically reported to the Director of HR and the Chief Operating Officer who are responsible for monitoring outcomes to ensure that appropriate action is taken and that there is no evidence of an escalating pattern. Where appropriate, the Occupational Health Service can also be called upon to provide specialist advice and guidance. All the College's facilities are easily accessible to guests and staff with disabilities. We provide special reserved car parking and purpose-built bedrooms. The National College's conference room and a selection of meeting rooms are equipped with facilities for delegates with hearing difficulties. Furthermore, the National College provides alarm systems in bedrooms for guests with impaired hearing. We undertake workplace assessments and provide reasonable adjustments to ensure that we can fully meet the needs of our staff. Both workshops and on-line training on equality and diversity issues (including harassment and disability) have been mandatory for all our staff and line managers so that they can recognise when harassment is taking place and have the skills to address it. As well as collating and monitoring the general employee diversity data which is regularly reported to the Senior Leadership Team and the Governing Council, we also collect data about our external programmes and evaluate outcomes to inform future provision. As a provider of services we have taken the following steps to ensure individuals with a disability are not discriminated against, harassed or victimised in any way: Our programmes and any related workshops are all held at venues accessible to all. This is one of the essential criteria used when assessing a venue's Suitability. All associates, facilitators, trainers and those working on behalf of the College must comply with the National College Equality and Diversity policy. This includes explicit reference to the eight protected characteristics under the Equality Act and our commitment to preventing and tackling all forms of harassment, discrimination and victimisation. All providers of services for the College have been approached to submit a copy of their own E&D policy to ensure equality governs their values as it does ours. Equality Impact Assessments have been undertaken for our programmes and provision to ensure our approach does not disadvantage particular groups of individuals in any way. Reasonable adjustments are made as needed for any disabled applicants to our programme and this is handled with sensitivity and discretion by programme leaders and teams, also liaising with the diversity manager as needed. As a public sector organisation we take steps to engage with and hear the views of disabled teachers aspiring to school leadership in the following ways: The Equality and Diversity Manager has been a regular member of the Disabled Teachers Taskforce run by the General Teaching Council for England. Membership includes representation from disabled teachers and ensures a forum through which the National College can better understand the barriers and challenges faced by disabled teachers, particularly those aspiring to leadership. A report was produced by the GTC during this time, the content of which will be used as a starting point for future follow up focus group work. Funding has been provided for a regional project looking at barriers to school leadership for disabled teachers. The project will initially focus on consulting with a range of aspirant disabled leaders and will go on to explore strategies for overcoming these challenges. Case studies and good practice will be written up and shared more widely via the College website. Therefore, through effective data capture, equality impact assessments and the reporting mechanisms already in place we can evaluate the impact on our communities and take action where necessary. As an organisation we are committed to the seven suggested recommendations you suggest and from our experience, of these recommendations, the one we believe of key importance and most achievable is real ownership and strong leadership of the equality agenda to deliver change. Our moral purpose and values set the scene for our staff to work compassionately in showing a strong personal commitment to identifying and dealing with any forms of harassment. Our equality scheme and action plan outline our commitment to equality and diversity in the way we employ staff, provide services and work with partners and stakeholders. Our 'two ticks' disability accreditation demonstrates our drive to show good practice in this area. Not only do we deliver our legal duty to meet the Equality Act 2010 requirements, we also stress our moral duty to promote diversity and to value the differences that each individual brings. This contributes to and enables our drive to diversify the leadership of schools and children's services and underpins our aim to encourage and support a diverse National College workforce. Along with the first of the seven recommendations, another one which is particularly relevant to us as an organisation is to continue to look for ways to prevent harassment at work and to respond positively and with challenge to the perpetrators and with compassion and support for those who feel this issue affects them. As previously mentioned all of our staff (not just frontline staff) have been through diversity training recently and have responded very positively to the experience. We will continue to work closely with the Human Rights Commission and other agencies in the development of our provision and remain willing to provide feedback and input at relevant forums. From 1 April 2012 we will become an Agency of the Department for Education which will give us access to a wider range of support mechanisms for staff and other specialist advice and guidance. This change will also lead to a consistent approach across agencies, learning from the best practice within each to effectively take forward the equalities agenda. In summary, the College will continue to support the achievement of real progress in tackling disability harassment and we will use the recommendations made by the EHRC to guide work in this area. We will continue to embed equality and diversity as a mainstream activity within our work with leaders in the wider community and we will keep listening to the views and challenges facing disabled leaders and aspirant leaders, providing support where we can. Yours sincerely Steve Munby Chief Executive Triumph Road Nottingham NG8 1DH T 0845 609 0009 F 0115872 2001 E enquiries@nationalcollege.org.uk www.nationalcollege.org.uk