Acknowledgments
The Disability Advocacy and Access Team, FaHCSIA would like to thank the
many people who contributed to the development of this Toolkit. The process
for developing the Toolkit included:

A review of the previous NDAP Quality Improvement Toolkit, the Quality
Strategy Toolkit for Disability Employment and Rehabilitation Services, and
research of existing and relevant advocacy sector, state and
Commonwealth resources;

Consultation with key stakeholders including disability advocacy agencies,
Certification Body and audit personnel, the Disability Advocacy Network
Australia (DANA) Limited, and FaHCSIA State and National Office staff; and

A workshop to road test the draft Toolkit with key stakeholders.
We would like to acknowledge the following organisations for their contribution
to this process.

Advocacy Law Alliance Inc (Disability Advocacy NSW and Mid North Coast
Community Legal Centre)

Advocacy Tasmania Inc

Disability Advocacy Network Australia (DANA) Ltd

E-QUAL (Enhancing Quality)

Joint Accreditation System of Australia and New Zealand (JAS -ANZ)

Newell Advocacy Inc

North East Citizen Advocacy Inc

Regional Information and Advocacy Council (RIAC)

SAI-Global

Villamanta Disability Rights Legal Service Inc
We would also like to thank those disability advocacy agencies who allowed us
to include relevant case studies and examples of their policies, procedures,
tools and templates in this Toolkit.
Parliamentary Secretary Foreword
Over the last few years significant reforms for people with
disability have been achieved.
The signing of the United Nations Convention on the Rights of
Persons with Disabilities by the Australian Government affirmed
a commitment to safeguarding rights for people with disability.
The introduction of the National Disability Agreement in 2009
paved the way for significant reform of the disability services
system and in February 2011 the Council of Australian
Governments endorsed the National Disability Strategy which
outlines a ten-year national policy framework to improve the
lives of people with disability, promote participation, and create
a more inclusive society.
The National Disability Strategy recognises the important role
that disability advocacy will play to safeguard the rights of
people with disability. Additionally the foundation work has
commenced for a National Disability Insurance Scheme. This
work will result in transformative reform of the disability service
system.
A well administered, quality assured disability advocacy sector will be crucial to support Australia’s human
rights framework and the achievement of broader disability reforms outlined in the National Disability
Agreement, the National Disability Strategy, the United Nations Convention on the Rights of Persons with
Disabilities and a National Disability Insurance Scheme. The Government is committed to supporting the
advocacy sector to meet these potential future demands.
A new Quality Assurance system to be introduced from 1 July 2012 for disability advocacy agencies
funded by the Australian Government features a third-party certification process, independent from
government, to assess the compliance of disability advocacy agencies against a tailored set of Disability
Advocacy Standards. It builds on the strengths of the previous Quality Assurance system but provides
greater assurances about the quality of disability advocacy support being provided and increased
guidance for advocacy services to improve service quality.
This National Disability Advocacy Program Quality Toolkit provides key resources for agencies to
meet the requirements under the new Quality Assurance system and to foster a commitment to
continuous improvement.
It is our vision that reforms being progressed, and the introduction of a new Quality Assurance system will
ensure quality disability advocacy support that is easy to access, responds flexibly to the changing
environment and provides people with disability access to advocacy that promotes, protects and ensures
their full and equal enjoyment of all human rights, enabling full community participation.
SENATOR THE HON JAN MCLUCAS
Parliamentary Secretary to the Prime Minister and Parliamentary Secretary for Disabilities and Carers
Feedback form
We welcome your feedback about how useful you find this Toolkit, including
your suggestions for additional resources or information for future inclusion.
Name:
Organisation:
Mailing Address:
Email address:
Contact telephone number:
I wish to:

Submit an additional resource to be considered for inclusion in the Toolkit
(attach resource)

Provide feedback about Toolkit’s tools or resources I have found useful

Provide general feedback about the Toolkit

Other
Feedback (please attach additional pages if required)
Please send to:
Post Advocacy and Access Team, PO Box 7576, Canberra Mail Centre, ACT
2610
Email disabilityadvocacy@fahcsia.gov.au
Contents
Section 1: Purpose of the NDAP Quality Toolkit ............................................... 1
Section 2: Overview of the Quality Strategy for the NDAP ................................ 2
2.1 Description of the NDAP…………………………………………………………….2
2.2 Purpose of the NDAP Quality Strategy…………………………………………….4
2.3 Key features and components of the NDAP Quality Strategy…………………...5
2.4 Information about the Disability Advocacy Standards, key performance
indicators and examples of evidence…………………………………………………..7
2.5 Overview of the third party certification process………………………………….8
2.6 Responsibilities of stakeholders……………………………………………………9
Section 3: Quality assurance and a step by step guide to certification ......... 10
3.1 Key points about the QA system…………………………………………………..10
3.2 Step by step guide to Disability Advocacy Standards certification…………….12
Step 1: Start the process early .............................................................................. 12
Step 2: Choose your Certification Body ................................................................. 13
Step 3: Notify FaHCSIA ......................................................................................... 15
Step 4: Conduct your self-assessment .................................................................. 15
Step 5: Prepare for your certification audit ............................................................ 18
Step 6: Participate in your certification audit ......................................................... 25
Step 7: Audit team assessment report and follow up ............................................ 27
Step 8: Start three year audit cycle ....................................................................... 28
3.3 Summary of the step by step guide to Disability Advocacy Standards
certification……………………………………………………………………………….31
3.4 Comprehensive step by step guide to Disability Advocacy Standards
certification……………………………………………………………………………….33
Section 4: Disability Advocacy Standards, examples of evidence and selfassessment worksheets ..................................................................................... 37
4.1 Disability Advocacy Standards, KPIs and evidence examples………………...39
Standard 1: Accessing advocacy .......................................................................... 39
Standard 2: Individual needs ................................................................................. 43
Standard 3: Decision making and choice .............................................................. 48
Standard 4: Privacy, dignity and confidentiality ..................................................... 53
Standard 5: Participation and integration .............................................................. 57
Standard 6: Valued status ..................................................................................... 61
Standard 7: Complaints and disputes .................................................................... 64
Standard 8: Agency management ......................................................................... 68
Standard 9: Staff, recruitment, employment and training ...................................... 71
Standard 10: Protection of human rights and freedom from abuse ....................... 74
4.2 Self-assessments…………………………………………………………………...78
4.3 Self-Assessment Worksheets ……………………………………………………..80
Section 5: Continuous Improvement ................................................................. 90
5.1 Sample policies, procedures, templates and tools………………………………92
Standard 1: Accessing advocacy ........................................................................ 92
Standard 2: Individual needs ............................................................................. 102
Standard 3: Decision making and choice .......................................................... 108
Standard 4: Privacy, dignity and confidentiality ................................................. 124
Standard 5: Participation and integration .......................................................... 131
Standard 6: Valued status ................................................................................. 134
Standard 7: Complaints and disputes ................................................................ 139
Standard 8: Agency management ..................................................................... 159
Standard 9: Staff, recruitment, employment and training .................................. 197
Standard 10:
Protection of human rights and freedom from abuse .................. 217
5.2 Case studies……………………………………………………………………….224
Standard 1: Accessing advocacy ........................................................................ 224
Standard 2: Individual needs ............................................................................... 228
Standard 3: Decision making and choice ............................................................ 231
Standard 4: Privacy, dignity and confidentiality ................................................... 235
Standard 5: Participation and integration ............................................................ 237
Standard 6: Valued status ................................................................................... 239
Standard 7: Complaints and disputes .................................................................. 241
Standard 8: Agency management ....................................................................... 243
Standard 9: Staff, recruitment, employment and training .................................... 249
Standard 10: Protection of human rights and freedom from abuse ..................... 252
5.3 Links to other resources…………………………………………………………..256
Standard 1: Accessing advocacy ........................................................................ 256
Standard 2: Individual needs ............................................................................... 256
Standard 3: Decision making and choice ............................................................ 256
Standard 4: Privacy, dignity and confidentiality ................................................... 257
Standard 5: Participation and integration ............................................................ 258
Standard 6: Valued status ................................................................................... 258
Standard 7: Complaints and disputes .................................................................. 258
Standard 8: Agency management ....................................................................... 259
Standard 9: Staff, recruitment, employment and training .................................... 259
Standard 10:
Protection of human rights and freedom from abuse .................. 260
Section 6: Complaints handling mechanisms ................................................ 261
6.1 Complaints associated with the NDAP Quality Strategy………………………261
6.2 External referrals…………………………………………………………………..263
Section 7: Key contacts .................................................................................... 267
Section 8: Glossary ........................................................................................... 272
Attachment 1 - JAS-ANZ Procedure 29 ........................................................... 280
Attachment 2 - Consent for the Release of Information................................. 306
Attachment 3 - Disability Advocacy Standards, key performance indicators
and examples of evidence ................................................................................ 308
Section 1: Purpose of the NDAP
Quality Toolkit
Following a review of the NDAP and consultations with the sector in 2007/8, it
was decided that a strategy to improve the quality of disability advocacy support
was needed to provide assurances to people with disability, the disability
advocacy sector and Government. The NDAP Quality Strategy includes:
1. A Quality Assurance (QA) system that commenced on 1 July 2012. A key
aspect of the new QA system is continuous improvement for disability
advocacy agencies to achieve better outcomes for people with disability.
2. A range of tools and supports to assist the sector to meet the requirements
of the new QA system, including this Toolkit, training, and mentoring.
3. Ensuring the quality of advocacy support by assisting disability advocacy
agencies to meet their requirements under their funding agreements.
This Toolkit has been developed as a resource for NDAP funded disability
advocacy agencies, and certification/accreditation personnel who will be
involved in conducting assessments of the quality of disability advocacy being
provided. It is designed to help you by providing a step by step guide to the QA
certification process, as well as case studies, and sample policies and
procedures you may wish to apply or adapt, or that may otherwise inspire your
quality improvement. You can use, adapt and copy the material in this Toolkit
however you like.
Please remember that implementing the tools in this Toolkit does not
automatically result in compliance with the Disability Advocacy Standards or
your certification. The tools are designed to help you build on your existing
systems and bring them together cohesively.
1
Section 2: Overview of the Quality
Strategy for the NDAP
2.1 Description of the NDAP
The NDAP provides people with disability access to effective disability advocacy
that promotes, protects and ensures their full and equal enjoyment of all human
rights enabling community participation. The NDAP is funded and administered
by the Australian Government Department of Families, Housing, Community
Services and Indigenous Affairs (FaHCSIA).
The target group for advocacy support provided by NDAP agencies, as
required under section 8 of the Disability Services Act 1986 (Commonwealth),
consists of people with disability that:
a.
‘is attributable to an intellectual, psychiatric, sensory or physical
impairment or a combination of such impairments;
b.
is permanent or likely to be permanent; and
c.
results in:
i. a substantially reduced capacity of the person for communication,
learning or mobility; and
ii. the need for ongoing support services.
Definition of disability advocacy
The Disability Services Act 1986 (Commonwealth) requires that disability
advocacy agencies support people with disability to exercise their rights and
freedoms, being rights and freedoms recognised by the Convention on the
Rights of Persons with Disabilities (Disabilities Convention).
Approaches to disability advocacy can be categorised into two broad
approaches being individual advocacy and systemic advocacy.
Advocacy for individuals supports people with disability to exercise their rights
and freedoms through either one-to-support, or by supporting people to
advocate for themselves individually, through a third party, or on a group basis.
Models of advocacy support for individuals include:




Individual advocacy
Citizen advocacy
Family advocacy
Legal advocacy
2

Self advocacy
Individual advocacy – seeks to uphold the rights and interests of people with
all types of disabilities on a one-to-one basis by addressing instances of
discrimination, abuse and neglect.
Individual advocates work with people with disability on either a short-term or
issue-specific basis.
Individual advocates:




Work with people with disability requiring one-to-one advocacy support;
Develop a plan of action (sometimes called an individual advocacy plan) in
partnership with the person with a disability that maps out clearly defined
goals;
Educate people with disability about their rights; and
Work through the individual advocacy plan in partnership with the person
with a disability.
Citizen advocacy seeks to support people with a disability (also called
protégés) by matching them with volunteers. Some of the matches made may
last for life.
Through citizen advocacy:



People with disability who are vulnerable, isolated and may have no family
or community supports or networks are sought out;
Citizen advocates (who are volunteers) are encouraged to represent the
interests of a person with a disability as if they were their own and be free
from conflict of interest; and
Citizen advocates are recruited, trained and supported by a coordinator who
manages the work of the citizen advocacy agency.
Family advocacy works with parents and family members to enable them to
act as advocates with and on behalf of a family member with disability. Family
advocates work with parents and family members on either a short-term or an
issue-specific basis. Family advocates work within the fundamental principle
that the rights and interests of the person with disability are upheld at all times.
Through family advocacy:


Family members are provided with advice and support;
The person with disability is assisted via the family member being directly
supported by the agency to advocate on their behalf.
Legal advocacy seeks to uphold the rights and interests of people with all
types of disabilities on a one-to-one basis by addressing legal aspects of
instances of discrimination, abuse and neglect.
Legal advocates may:
3



Provide legal representation for people with disability as they come into
contact with the justice system;
Pursue positive changes to legislation for people with disability; and
Assist people with disability to understand their legal rights.
Self advocacy supports people with disability to advocate on their own behalf,
to the extent possible, on a one-to-one or group basis.
Through self advocacy:


Advocates work with people with disability to develop their personal skills
and self-confidence to enable them to advocate on their own behalf; and
People with disability are educated about their rights.
Systemic advocacy seeks to introduce and influence long-term changes to
ensure that the rights and freedoms of persons with disabilities, being rights and
freedoms recognised or declared by the Disabilities Convention, are attained
and upheld so as to positively affect the quality of their lives.
The systemic advocacy agency:


Pursues positive changes to legislation, policy and service practices in
partnership with groups of people with disability, advocacy agencies and
other relevant organisations; and
Seeks to address barriers and discriminatory practices to produce long-term
positive changes.
2.2 Purpose of the NDAP Quality Strategy
The goal of the NDAP Quality Strategy is to introduce an effective performance
framework for Australian Government funded disability advocacy agencies that
will:




Provide people with disability, the disability advocacy sector and
government with assurances about the quality of disability advocacy
support being delivered;
Introduce a set of measurable performance requirements via the
introduction of the Disability Advocacy Standards and key performance
indicators (KPIs);
Introduce mechanisms independent from government to assess the
compliance of advocacy agencies against the Disability Advocacy
Standards and KPIs; and
Support disability advocacy agencies to continuously improve.
Quality should be seen as a right of people with disability receiving advocacy
support from a disability advocacy agency, and a collective responsibility of
agency staff, management and Boards or equivalents. A ‘quality culture’ is
central to the delivery of high quality advocacy support.
4
The values and commitment of a disability advocacy agency, combined with the
agency’s systems and processes work towards enhancing quality, which then
drives outcomes for people with disability.1
2.3 Key features and components of the NDAP
Quality Strategy
The components of the Quality Strategy
The NDAP Quality Strategy is based on a quality management approach and
comprises the new QA system which includes continuous improvement, the
provision of tools and other support and assistance for agencies to meet the
requirements under their funding agreements.
QA system:
Key features of the QA system include:



A set of 10 Disability Advocacy Standards and 25 KPIs, (which build on the
Disability Services Standards which have been in place since 1992);
Certification of advocacy agencies’ compliance with the Standards and KPIs
on the basis of assessments undertaken by independent, accredited
Certification Bodies; and
Accreditation of Certification Bodies by the Joint Accreditation System of
Australia and New Zealand (JAS-ANZ). Accreditation requirements are
contained in JAS-ANZ Procedure 29 at Attachment 1.
QA provides confidence that a particular standard of quality for a service or
product has been met and maintained. QA incorporates:


Standards against which internal and/or external assessment is undertaken;
and
Processes to control components of the quality system e.g. plans, policies,
procedures, guidelines.
Continuous improvement:
With a quality management approach, continuous improvement systems
incorporate a quality cycle of continuous improvement. Quality management is
seen as an ongoing journey of continuous improvement.
Continuous improvement involves:



1
Progressively increasing the value of advocacy support through changes
designed to better address the needs and preferences of people with
disability;
Enhancing performance against the Standards; and
Commitment to identifying needs and opportunities for improvement in a
systematic and planned way.
Quality Framework Handbook, Department of Human Services, Victoria
5
Quality systems
Quality management practice should be deployed through a quality system.
This ensures that a cyclical, consistent and coordinated approach to measuring,
monitoring and improving disability advocacy support is ensured.
A quality system framework includes formalisation of the disability advocacy
agency’s plans, policies and procedures, as well as documentation of
processes and practices such as position descriptions, meeting minutes and
system controls. Compliance with legislative and statutory requirements is
integral to a disability advocacy agency’s quality system. A ‘systems approach’
to management is a way of thinking that helps to link continuous improvement
of all internal processes or activities. In each stage of a system there will be
processes which require monitoring for opportunities for improvement. A robust
quality system aims to establish a consistent level of quality against agreed
Standards and achieve a culture of quality and continuous improvement.
Disability advocacy agencies that have integrated a quality system into how
they work can achieve better outcomes for people with disability, the
organisation, and ultimately, the broader community.
Some of the benefits include2:
For people with disability:



More likely to get the support they need and want, and achieve better
outcomes;
Greater confidence that the agency is well run;
More opportunities to have a say and be involved in decision making about
the agency.
For disability advocacy agency staff:




Greater job satisfaction;
Greater efficiency and effectiveness;
Greater sense of involvement and empowerment in their work;
Opportunities to learn new skills and a more interesting learning
environment.
For Boards or equivalent:



Greater confidence that the disability advocacy agency is achieving its
mission and purpose;
Development of a culture of ongoing learning and continuous improvement;
Opportunities to promote the values of the disability advocacy agency and
demonstrate these to the community.
For managers:




2
Development of a culture of ongoing learning and continuous improvement;
More efficient and effective work processes;
More time and resources spent on planning rather than reacting to
problems;
Opportunities to promote the values of the disability advocacy agency and
demonstrate these to the community.
Adapted from Quality Systems, A Resource Package for Disability Services, Disability Services Commission, WA
6
2.4 Information about the Disability Advocacy
Standards, key performance indicators and
examples of evidence
Disability Advocacy Standards
The 10 Disability Advocacy Standards and 25 associated key performance
indicators (KPIs) are central to the NDAP QA system. The Standards define the
elements of quality advocacy support for people with disability. The KPIs
describe a measurable element of practice that may be used to assess whether
the practice meets a particular Standard. To achieve certification, disability
advocacy agencies need to comply with, and demonstrate continuous
improvement against all the Disability Advocacy Standards and KPIs. A
complete set of the Standards and KPIs appears in Section 4, and is available
on the ComLaw website.
The Disability Advocacy Standards apply to all disability advocacy agencies
across the range of advocacy models funded under the NDAP. However, the
inherent differences between the six different models of advocacy are
recognised under the QA system. The examples of evidence provided in
Section 4 describe the different types and examples of evidence applicable to
the different models of advocacy.
Examples of evidence
Examples of evidence are tools to help you gather and develop evidence to:



Demonstrate to a Certification Body what your disability advocacy agency is
doing to meet the Disability Advocacy Standards;
Use internally to assess your disability advocacy agency's performance
against the Disability Advocacy Standards; and
Use internally to help your disability advocacy agency find ways to
continually improve and innovate.
The examples of evidence are not an all-inclusive checklist. You may have
different examples of evidence than those in the guidelines for demonstrating
compliance with the KPIs for each Standard.
Other Standards
Some NDAP disability advocacy agencies may also be required to meet other
Standards through certification schemes accredited by JAS-ANZ, for example
State Government disability services certification schemes. If this applies to
you, then your disability advocacy agency can have the extent of any common
criteria considered during the certification process to avoid audit duplication.
This could include co-scheduling of audits, where practicable. For more
information, see Section 3.
7
2.5 Overview of the third party certification
process
Audits against the Disability Advocacy Standards will be conducted by
independent third party Certification Bodies. These Certification Bodies will be
accredited to perform audits against the Disability Advocacy Standards by JASANZ (see Diagram 1).
Diagram 1: Hierarchy of the QA system
Certification Bodies
Report QA
audit results
Certification
FaHCSIA: the
funding body for
certified NDAP
disability advocacy
agencies that
administers the QA
system
Accreditation
JAS-ANZ (accreditation body)
Disability Advocacy Agencies
Certification
Certification is recognition by a third party that a disability advocacy agency
conforms to the requirements of the Disability Advocacy Standards. Disability
advocacy agencies that achieve certification will receive a certificate that will be
recognised by the Australian Government as proof that the agency is delivering
services in line with the Standards.
Certification will be at the level of the disability advocacy organisation – this
means that all outlets and all advocacy models provided by the organisation
must be compliant with the Disability Advocacy Standards for it to achieve
certification.
Accreditation
Accreditation is the process by which JAS-ANZ formally recognises that a
Certification Body is competent to carry out specific tasks — in this case to
undertake assessments and offer certification against the Disability Advocacy
Standards, according to a formal JAS-ANZ accreditation assessment.
8
2.6 Responsibilities of stakeholders
The role of FaHCSIA
FaHCSIA is responsible for administering the Quality Strategy for disability
advocacy agencies. In the new QA system FaHCSIA will remain independent
of the assessment and certification decision making process. FaHCSIA will
work closely with the NDAP sector to support NDAP disability advocacy
agencies to gain certification, to facilitate continuous improvement and assist
them to meet the requirements of their funding agreements.
The role of JAS-ANZ
JAS-ANZ is responsible for accrediting the Certification Bodies that audit
disability advocacy agencies against the Disability Advocacy Standards. The
criteria for accreditation of Certification Bodies are set out in JAS-ANZ
Procedure 29 Requirements for Bodies Providing Audit and Certification of
Advocacy Agencies under the National Disability Advocacy Program. Procedure
29 contains requirements for Certification Bodies, not disability advocacy
agencies. It covers requirements governing the impartiality, confidentiality and
competence of the Certification Body. Procedure 29 also sets out guidance for
how certification processes are to be conducted. Procedure 29 is included in
Attachment 1.
More information about JAS-ANZ, including all JAS-ANZ Procedures, is
available on the JAS-ANZ website.
The role of Certification Bodies
Certification Bodies are third party accredited entities that independently audit
disability advocacy agencies funded by FaHCSIA against the Disability
Advocacy Standards. Audit teams include competent personnel identified by a
Certification Body as meeting required team competencies as set down in JASANZ Procedure 29. The audit team will generally include a Lead Auditor and a
Consumer Technical Expert (CTE). Procedure 29 requires a person with a
disability to be included in the team either as a Leader Auditor or as a CTE.
Certification Bodies rate the performance of disability advocacy agencies
against the 10 Disability Advocacy Standards and 25 KPIs, using a scale of 0
(major nonconformity), 1 (nonconformity) and 2 (conformity). These results are
reported to the disability advocacy agency and FaHCSIA in the form of an audit
report.
9
Section 3: Quality assurance and a
step by step guide to certification
3.1 Key points about the QA system
1. The QA system applies to all NDAP funded disability advocacy agencies.
2. It involves independent assessments to certify that they comply with the 10
Disability Advocacy Standards. Quality is specified through 25 KPIs across
the Standards.
3. Third party Certification Bodies undertake the certification audits.
4. Certification Bodies are accredited by the JAS-ANZ. Accreditation
requirements are contained in JAS-ANZ Procedure 29. JAS-ANZ accredits
Certification Bodies as competent and impartial for undertaking audits
against the Disability Advocacy Standards.
5. The QA system has been designed to ensure that people with disability are
involved with all aspects and stages of the process.
6. Under the QA system, the role of FaHCSIA is to develop policy and provide
support and resources to help disability advocacy agencies gain certification
and pursue continuous improvement.
7. The QA system was formally implemented from 1 July 2012, with disability
advocacy agencies currently funded under the NDAP required to achieve
certification by 7 November 2013.
8. Those advocacy agencies that do not meet the 7 November 2013 deadline
will no longer be eligible for funding.
9. It is important to prepare for certification well in advance of the certification
deadline, to allow for the availability of Certification Body audit teams, as
well as to close out any nonconformities.
10. If disability advocacy agencies receive nonconformities against any of the
Disability Advocacy Standards, they have three months to take corrective
action for major nonconformities, and six months to take corrective action
for nonconformities.
11. Certified disability advocacy agencies receive a certificate of compliance
that is recognised by the Australian Government as proof that they are
delivering services in line with all of the Disability Advocacy Standards and
KPIs.
12. If a disability advocacy agency has been audited to another set of
Standards by a JAS-ANZ accredited Certification Body, then common
criteria can be considered during the NDAP QA process to avoid audit
duplication.
13. The timing of audits is important for continued funding. At 12 and 24 months
of certification, certified disability advocacy agencies participate in a
surveillance audit conducted by their chosen Certification Body. The first
surveillance audit must occur not more than 12 months after the last day of
the certification audit – the second surveillance must occur not more than
13 months after the last day of the first surveillance audit. Prior to 36
months of certification, disability advocacy agencies participate in a full
recertification audit.
10
Diagram 2 below shows the steps involved in the certification process.
Diagram 2: The certification process
11
3.2 Step by step guide to Disability Advocacy
Standards certification
Step 1: Start the process early
The first step in preparing for the audit process is to gather and review
background information about your disability advocacy agency. This may
include information about its structure, the models of advocacy used and any
documented policies and procedures. Your disability advocacy agency will also
need to consider its contractual requirements – including the advocacy models
and target group which form part of the FaHCSIA funding agreement. This
helps you assess exactly what you will need to consider for your certification
audit. This scoping exercise is a preliminary process before the more detailed
self-assessment your disability advocacy agency will need to undertake later as
part of your preparation – see Step 4.
It is highly recommended that disability advocacy agencies start this
process as soon as possible. Disability advocacy agencies need to think
carefully about the deadline for certification, which is 7 November 2013,
and work back from this date in planning for the audit. Although three
months is allowed to correct any identified major nonconformities, and six
months for nonconformities, they must be closed out before 7 November
2013 – irrespective of when the audit was conducted. Also, there may be
issues around the availability of Certification Bodies for assessment in
‘peak’ times close to the deadline, so getting the process happening
earlier is a wise move. For these reasons, and in order to allow the
maximum time to address any major/nonconformities identified, the audit
should be conducted before the second half of 2013.
FaHCSIA will encourage disability advocacy agencies that have ratings of
nonconformity in the Self-assessment completed in February 2012, to nominate
for an audit soon after the implementation of the QA system in July 2012. This
will ensure that those agencies that may require additional support to achieve
certification will have a longer period of time to access that support and make
the necessary improvements to their systems and operations to meet the 7
November 2013 deadline.
12
Step 1: Checklist
Check that you have considered:
Is our disability advocacy agency familiar with the Disability Advocacy
Standards, KPIs and relevant examples of evidence?
What are the contractual responsibilities in our Funding
Agreement/Contract?
Who will be involved in our audit process?
Consider:






Management and staff
People with disability
Family members/carers/interpreters/others
Board members and management
Community members
External stakeholders
How will we arrange and actively encourage the involvement of people
with disability?
Do we have documented policies and procedures?
Where are they?
When were they last updated?
How do they reflect all of the Disability Advocacy Standards?
Does our disability advocacy agency operate any other QA systems?
Could these systems contribute any evidence for our certification audits?
Have we spoken to our FaHCSIA Contract Manager to discuss the
process?
Have we thought through the timeframe for certification, and when we
would need to get started to ensure compliance before the deadline?
HINTS: Reviewing policies, procedures and documentation:



Develop a matrix to match your disability advocacy agency’s policies
against the Disability Advocacy Standards;
Link/hyperlink policies and procedures to the Standards;
Use this as an opportunity to provide training in quality management for
advocacy staff.3
Step 2: Choose your Certification Body
When choosing a Certification Body, remember that you will be working
together into the future, usually for at least three years. It is a good idea to 'shop
around' until you find a Certification Body that can work well with your disability
advocacy agency.
3
Final Report, Evaluation of the Trial of the NDAP QA System, December 2010 p. 31
13
HINTS: Selecting a Certification Body
Consider:

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
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The scope of QA services provided by the Certification Body i.e. ensure that
the Certification Body has been accredited by JAS-ANZ to undertake
certification assessments of disability advocacy agencies;
The experience the Certification Body has in assessment of disability
advocacy agencies, disability services, and its understanding of disability
advocacy;
The experience of their audit team, particularly in working with people with
disability, for example, their strategies and approaches to communicating
with people with disability;
The gender composition of the audit team – sometimes a mix of
male/female auditor/CTE may be appropriate to consider the specific needs
of people with disability;
Speaking to other disability agencies/services which the Certification Body
has assessed;
Asking to meet the audit team, including the CTE (Note: auditors typically
only get two days per month in the office, and are auditing the rest of the
time, so this may take time to arrange);
Putting the same effort into contracting your Certification Body, as if you
were recruiting a member of your management team;
The cost of the Certification Body's services – you should compare the
quotes from at least two Certification Bodies;
Whether the Certification Body conducts audits for other disability advocacy
agencies/organisations in your area and could organise for sharing of
travel/accommodation costs by co- scheduling of audits (of particular
relevance for agencies in remote or rural locations);
If you are already audited to another set of Standards by a JAS-ANZ
accredited Certification Body (e.g. Queensland Disability Standards,
Employment Standards, ISO 9001), whether the audits could be combined
to minimise audit duplication, as well as cost;
The consistency of the audit team throughout the audit cycle, and how the
Certification Body can review and change the team if your agency has
problems/issues with a team member(s);
The availability of the Certification Bodies for conducting audits, and the
lead time you would need to provide them with to ensure that they are
available for conducting your audit at a suitable time.
To find a Certification Body, you can use the register provided on the JAS-ANZ
website. In the ‘Program’ field select ‘Product Certification’, and then select
‘National Disability Advocacy Program’ from the ‘Scheme’ drop down options.
14
Step 2: Checklist
Check that you have considered:
Is the Certification Body formally accredited by JAS-ANZ to assess
services against the Disability Advocacy Standards?
JAS-ANZ can confirm accreditation status.
Is the Certification Body experienced at auditing disability advocacy
agencies similar to ours? Can it provide references?
Is it possible to meet with the audit team prior to the audit (may not be
feasible in rural and remote areas)?
The extent to which the Certification Body will avoid audit duplication
where a disability advocacy agency holds a current accredited
certification to service standards containing common or significantly
similar criteria.
Can the audit team provide examples of past (de-identified) audit
reports? Are these reports of good quality?
What approaches does the Certification Body have to engaging people
with disability in the audit process?
What is the likely composition of the audit team, and will this be
consistent throughout the audit cycle?
How does the quote from the Certification Body compare to other
Certification Bodies? Remember to compare ‘apples with apples’ and
double check what the quote includes/excludes.
Step 3: Notify FaHCSIA
As soon as you have engaged a Certification Body to conduct your quality
assurance certification audit you need to provide the details to your FaHCSIA
Contract Manager. This should include the name of the Certification Body and,
if scheduled, the dates of the Stage 1 and Stage 2 audits. Contact details for
FaHCSIA appear in Section 7.
Step 3: Checklist
Check that you have considered:
Have we provided FaHCSIA with details of our Certification Body and, if
scheduled, the dates of the Stage 1 and Stage 2 audit?
Step 4: Conduct your self-assessment
Self-assessment is the opportunity for your disability advocacy agency to
identify how it is currently travelling in relation to the Disability Advocacy
Standards. Self-assessment involves the review of your policies, procedures
and system documentation to confirm compliance with the Disability Advocacy
Standards.
Certification Bodies will require you to submit a copy of:


Your latest self-assessment;
Your documented policies and procedures relating to your management
system;
15

Your current funding agreement with FaHCSIA, and details of the models of
advocacy delivered and location(s) of the disability advocacy agencies.
The Certification Body will use this information to decide whether to proceed
with a certification audit. This is why it is important that you conduct a selfassessment in plenty of time before the official certification assessment is
scheduled. This will give you time to address any major issues identified by the
Certification Body prior to the audit.
The self-assessment process identifies areas of practice that are currently
working well and meeting the Standards, and thought can be given to how to
maintain and improve these systems and processes to ensure an ongoing level
of quality in advocacy support.
Self-assessment is an initial analysis (or snapshot) of quality in your agency.
The results of your self- assessment should lead to an improvement process
which is assessed over the three year cycle. Self-assessment should be
conducted annually in the lead up to the external annual surveillance or three
yearly reassessment audits.
Involving stakeholders
The self-assessment process provides an excellent opportunity to involve
people at all levels of your disability advocacy agency. Promoting high levels of
participation in the self-assessment process will increase the long term
sustainability of your quality system, as more people within your disability
advocacy agency develop an understanding and ownership of not only the
process but the outcomes of the process as well.
This Toolkit contains some resources and tools that can help you with
conducting self-assessments including:



Disability Advocacy Standards, KPIs and examples of evidence (see
Section 4)
Self-assessment worksheets against each Standard (see Section 4)
Continuous improvement resources that your disability advocacy agency
can use for each Standard as part of ongoing improvement actions (see
Section 5)
Step 4: Checklist
Check that you have considered
Have we involved the governing board, staff, management, people
with disability and other key stakeholders in the self-assessment
process (see next section)?
Have we allowed enough time before the certification assessment is
scheduled, so that there is time to address any gaps?
Have we developed and communicated a strategy to key stakeholders
about how the self-assessment will take place?
Have we taken action to address gaps identified by the selfassessment process using some of the continuous improvement
16
Check that you have considered
resources in Section 5?
Do we have the self-assessment materials ready to show the audit
team?
HINT: How to involve people with disability in the self-assessment
process
Although the involvement of people with disability in the self- assessment
process is not mandatory, it is highly recommended and will provide valuable
feedback. There are various ways you can involve people with disability in the
self- assessment process. These could include:

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Feedback forms or questionnaires
Telephone interviews
Face-to-face or group interviews
Use of ‘Skype’ technology
A suggestion box
Focus groups
Remember that the purpose is to find out about people’s perceptions of the
disability advocacy agency in relation to the Standards and KPIs. A range of
Easy Read and Standard Read NDAP QA information for people with disability
which will be useful resources are available on the FaHCSIA website.
To encourage people with disability to participate in the assessment processes
consider:

Explaining to them why their contribution is important and how it will have
an effect on your disability advocacy agency’s operations;

Integrating feedback gathering for a self-assessment into other activities
your agency currently does;

Linking the internal feedback to an event such as an afternoon tea to show
appreciation of the contribution people with disability make;

Keeping the costs of participation down by:
o utilising some written surveys and reply paid envelopes as part of the
feedback process; and/or
o arranging meetings at venues on good public transport routes;

Including independent support people or advocates.
The experience of previous certification assessments involving people with
disability suggests that face to face feedback usually provides more valuable
feedback than written surveys.
Involving people with disability in the self-assessment process makes sense on
a number of levels, and in particular demonstrates to a Certification Body how
your disability advocacy agency puts into practice Standard 3 (Decision making
and choice).
17
Step 5: Prepare for your certification audit
Once the self- assessment has been completed your disability advocacy
agency will need to forward the required documentation to the chosen
Certification Body.
The audit is then conducted in 2 stages (Stage 1 and Stage 2). At the Stage 1
audit the Certification Body:

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

Reviews your system documentation (policies, procedures, perhaps
samples some records);
Reviews your self- assessment results and decides if your disability
advocacy agency is ready for the Stage 2 audit. Note: Conducting the selfassessment early in the process provides time for your disability advocacy
agency to address any major issues prior to the audit;
Confirms staff numbers, consumer numbers, types of advocacy models
provided, other logistical needs;
Discusses consumer participation methods for the Stage 2 audit (e.g. what
is going to work for your disability advocacy agency, how will consumers be
selected, what interview methods will work best for your consumer group
etc.);
Plans the Stage 2 audit (e.g. determining/confirming dates, developing a
draft plan).
This is also an opportunity to advise the Certification Body of any other set of
Standards that your disability advocacy agency has already been certified
against by a JAS-ANZ accredited Certification Body, for example ISO 9001, or
State Government Disability Services Certification Schemes. In these cases the
Certification Body will consider the extent of demonstrated conformances for
any common criteria, and may co-schedule audit activities for multiple
certifications, to avoid audit duplication.
To reduce travel costs, the Stage 1 audit may be conducted remotely. Normally
the Stage 1 audit is conducted on site.
Once the Certification Body has assessed that your disability advocacy agency
is ready to participate in the Stage 2 audit, they will:

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
Prepare an assessment/audit plan;
Advise details of the audit team to the disability advocacy agency;
Make plans for consultation with people with disability as early as possible.
The Certification Body’s CTE will have discussions with your disability
advocacy agency about the support needs and sensitivities of selected
people with disability;
Advise how the different models will be audited (if more than one advocacy
model is provided);
Advise how any other JAS-ANZ accredited certification held by your
disability advocacy agency will be used to avoid duplication.
18
At this stage, your disability advocacy agency will:

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


Liaise with the Certification Body about audit activities;
Schedule meetings and activities;
Prepare any necessary further material for the audit;
Prepare people with disability for involvement in the audit, and plan for
providing a list of willing participants to the Certification Body;
Advise the Certification Body audit team in advance of specific consumer
issues (e.g. behavioural) that they need to be aware of. Remember that
what is normal for disability advocacy agency staff may not necessarily be
normal for the auditor or CTE. For example, if the consumer wants to greet
the audit team with a hug, then it is useful for the audit team to be
forewarned about this. It is also useful for the audit team to know of ‘signs’
that may indicate an interview should be concluded (e.g. fidgeting, or other
personal behaviours that indicate the consumer is ready to leave, or may be
getting upset).
Key things to know about preparing for the certification audit
How are different advocacy models included in the audit?
Where a disability advocacy agency provides multiple advocacy models, the
Certification Body is required to assess every advocacy model, and to sample
people with disability and/or key stakeholders from every advocacy model. JASANZ Procedure 29 requires that the time spent auditing the different advocacy
models, and therefore the number of people with disability/stakeholders
sampled per model, is proportional to the level of funding provided for each
model.
How will people with disability and other key stakeholders be involved in
the certification audit?
JAS-ANZ Procedure 29 requires that ‘consumer’ feedback is a key element of
the audit process. For individual advocacy this means people with disability
who have received individual advocacy support within the last three months
from the individual disability advocacy agency being audited. In the case of
family advocacy, ‘consumers’ to be involved and interviewed should include
parents and/or family members. For citizen advocacy, the citizen advocate is
also considered a ‘consumer’.
For systemic advocacy this means people with disability who are associated
with the systemic advocacy work of the agency through stakeholder committees
and groups. Where such ‘consumers’ are not available, other external
stakeholders connected with the advocacy work will be sampled, including nongovernment, and government agencies. The Certification Body will also sample
whatever documents or records are available to cross-check information
gathered in interviews with external stakeholders.
Certification Bodies shall ensure that wherever possible, people with disability
have been offered the opportunity to participate in the audit process. It is not
usually practicable for all consumers to provide direct feedback, and this is why
a sampling approach is used.
19
How does consumer sampling work?
The strategy for sampling people with disability should be developed by the
disability advocacy agency, and negotiated with the Certification Body, taking
into account the needs of the consumer group. Consideration should be given
to the individual context of each advocacy agency, for example, a disability
advocacy agency with a small number of people with disability would not need
an extensive consultation mechanism around sampling.
Ideally the disability advocacy agency needs to contact people with disability in
advance about the audit process, and ask who may be interested in providing
feedback to the audit team.
The disability advocacy agency then provides a list of willing participants to the
Certification Body, which in turn selects the sample of people with disability to
be interviewed. The Certification Body aims to select a sample that represents
the demographics of the advocacy agency consumers. These include:

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
Disability type;
Gender;
Age;
Cultural or language differences;
Complexity and variety of advocacy issues;
Length of tenure with the agency (including those exited).
Only those people with disability who have received advocacy support of an
ongoing nature should be included in the consumer group. Those who have
received information of a one-off nature only from the disability advocacy
agency (e.g. phone calls or requests for information) are not considered to have
received ‘ongoing’ support.
Consumer file sampling will aim to cross check information gathered from
people with disability selected in the sample, and to confirm outcomes for those
people with disability.
JAS-ANZ Procedure 29 requires that the minimum number of consumers to be
sampled for an audit of a disability advocacy agency for initial and recertification
audits is:

The square root of the number of consumers receiving advocacy support
over the last three months.
The minimum number of consumers to be sampled for an audit of a disability
advocacy agency for surveillance audits is:

0.6 times the square root of the number of consumers receiving advocacy
support over the last three months.
How should communication with consumers take place during the audit?
The Certification Body should maintain a flexible approach to consumer
involvement methods, ensuring that priority is given to methods involving direct
20
communication where possible. JAS-ANZ Procedure 29 provides examples of
the types of methods which could be used, e.g. face-to-face interview, focus
groups, telephone survey, mail survey. However it is important to negotiate
what will work best for your consumer group with the Certification Body when
planning the audit.
Based on the findings of the trial of the NDAP QA process, the following
methods are suggested as useful options:

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Before each interview, providing the audit team with background information
on the person they will be speaking to;
Using a specialist independent support person known to many of the
consumers to facilitate a group meeting;
Allowing a minimum of 1.5 hours for conducting the group interviews;
Using Skype technology to conduct audit interviews with advocacy
consumers living in remote locations;
Conducting consumer workshops before the audit to raise awareness of the
Standards;
Considering the cultural needs of consumers, for example female
Indigenous consumers may not be comfortable being interviewed by a male
CTE;
Spending unstructured time observing, listening and having informal
conversations with protégés (citizen advocacy);
Reading events and outcomes of protégé-advocate relationships in files
(citizen advocacy);
Using consumer feedback forms that may be completed during the year;
Providing a range of meeting/appointment times;
Meeting with people in a place of their choosing.
Step 5: Checklist
Check that you have considered:
Have we collated our disability advocacy agency’s policies,
procedures and self-assessment documents, and forwarded these to
the Certification Body?
Have we provided general information to the Certification Body about
our consumers and the disability advocacy models we deliver?
Note: All advocacy models provided by your disability advocacy
agency will be assessed during the audit process and a sample of
your sites. JAS-ANZ Procedure 29 provides further guidance on this.
Have we taken action to address any issues identified by the
Certification Body in the Stage 1 audit?
Have we liaised with our Certification Body to discuss how the
certification audit will proceed including the details to be covered by
the audit, such as the:
 Sample of people with disability that they require?
 Inclusion of all advocacy models provided?
 Inclusion of all demographics (e.g. age, disability type,
21
Check that you have considered:
gender, cultural or language differences, complexity and
variety of advocacy issues, length of tenure with our disability
advocacy agency)?
 Consideration, where appropriate, of any other JAS-ANZ
accredited certification our disability advocacy agency already
has?
Have we invited people with disability to participate in the audit? In
turn the Certification Body will select from a list of willing participants
(see the following Hints regarding how you can encourage and
support people with disability to participate, plus Easy Read and
Standard Read NDAP QA information for people with disability). The
Certification Body will negotiate the proposed sample numbers and
sampling approach, including methods of communication and
sampling methods (face-to-face interviews, focus groups, telephone
survey, mail survey, visits) with the advocacy agency during this
planning phase.
Note: JAS-ANZ Procedure 29 specifies the process and formula for
determining consumer sample size.
Have we arranged consent forms and consent for access to files for
participating consumers (for models of advocacy where the person
with disability or a member of their family is a consumer of the
disability advocacy agency) plus citizen advocates (in the case of
citizen advocacy)? See Attachment 2 for a sample consent form.
Have we organised appropriate support for participating consumers?
Have we coordinated audit activities in line with our Certification
Body's requirements, including:
• Preparing the formal entry and exit meetings (e.g. arranging a
room and alerting attendees);
• Scheduling interviews with staff, management, governing body,
people with disability, external stakeholders.
HINT: How to encourage people with disability and other disability
advocacy agency consumers to participate in certification audits
In certification audits, the Certification Body should aim to have a flexible
approach to consumer involvement methods, ensuring that priority is given to
methods using direct communication.
Your disability advocacy agency is responsible for ensuring that people with
disability, and any other agency consumers, are able to provide feedback and
be involved in the audit. Depending on the nature of the advocacy your agency
undertakes, they may or may not be direct consumers.
Feedback obtained from consultation with people with disability and other
agency consumers should be related to the systems and processes your
disability advocacy agency has in place to meet the Disability Advocacy
Standards, and what can be done to maintain and/or improve these. Broader
22
feedback may also be used to develop and improve opportunities for people
with disability to participate in the activities of your agency. Consultation is not
intended to provide general feedback or personalised complaints – although
where this occurs, your agency will need to address the concern.
Considering the needs of people with disability
In involving people with disability and other disability advocacy agency
consumers in the audit process, your agency will need to consider:

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





The needs of people with disability and other agency consumers
The necessary supports required
The time required
How to consult with people with disability and other agency consumers in
planning the approach
How to ensure feedback on the specific Standards and KPIs
How to protect the confidentiality of those involved
How to document and report findings
How to take action for improvement based on findings
How to provide feedback to people with disability and other agency
consumers on the findings and actions your agency has undertaken
Communication needs
To engage people with disability in the audit process your disability advocacy
agency will need to consider whether, or what specific, communication
assistance may be needed to enable their full participation. Your agency will
need to make the information used easy to understand, for example, providing
information about the NDAP QA process for people with disability in Easy Read
and/or Standard Read format. It may mean involving a family member or carer
to support the person with disability, or where this is not possible or appropriate,
involving an independent support person. Interpreters might be needed for oneon-one or group interviews.
Level of participation
The level of participation of people with disability will vary according to a range
of factors, such as their disability type, their level of interest, their relationship to
your disability advocacy agency, and the processes your agency chooses to
use. People with disability may be actively involved in all aspects of the
process. Your agency might consult with them to obtain feedback and keep
them informed of the process and how their feedback has been used, or where
the person/ people with disability have a limited capacity to contribute feedback,
they may be supported by a family member/ carer/ advocate. Your agency will
need to tailor methods of involving consumers to meet different needs.
Confidentiality
To ensure participants’ confidentiality, your disability advocacy agency should
aim to get their informed consent, where possible. Where this is not possible, an
23
independent support person should be involved to determine the capacity of the
person to provide consent and to support an appropriate level of involvement by
the person. It is preferable to obtain consent in writing.
Building trust
In arranging consultation mechanisms, it is important to keep in mind that this is
not a one-off activity, but a recurring process. Trust will build over time, and by
informing people how their feedback is used and demonstrating the effects on
agency practice, your disability advocacy agency will be demonstrating that
feedback is valued and useful. Where a person/ people with disability are
reluctant to participate, your agency should respect this, but inform them that
their role is important to the process.
Preparing people with disability
In certification audits, the Certification Body aims for direct communication
where possible with people with disability. To ensure that this happens, your
disability advocacy agency will need to prepare individuals to participate where
possible. It is important for people with disability to understand that the audit is
not a check or ‘test’ of them, but is a way of checking how your agency is
providing advocacy support. The Easy Read and Standard Read NDAP QA
information available on the FaHCSIA website are useful resources for
preparing consumers for the audit.
Key questions for this stage
In planning, consider the following questions:












What is your disability advocacy agency hoping to achieve from
consultation with people with disability?
How do people with disability want to participate and provide feedback?
What consultation strategies will suit the people with disability who will be
involved?
Who does your disability advocacy agency need to include?
What processes for participation does your agency already use, and can
they be used in the audit process?
Who else will need to be involved? (e.g. family members/ carers,
advocates, facilitators, interpreters)
What resources will be needed?
What time is best to hold the consultations?
Is it necessary to provide an option for anonymous feedback?
What tools are needed for the consultation? (e.g. a survey, a meeting
agenda)
What support is needed for people with disability to fully participate?
What information do people with disability need to participate?
24

How will your disability advocacy agency record and use the feedback, and
then inform people with disability of the outcomes?
Step 6: Participate in your certification audit
Who conducts certification audits?
Audits are conducted by a team nominated by the Certification Body, which
always includes an Auditor and a Consumer Technical Expert.




Lead Auditor - a person who has knowledge of disability advocacy and
quality management practices and skills in collecting and analysing data, as
well as leadership experience. They are responsible for organising and
directing the activities of the audit team, as well as participating in general
auditing activities.
Auditor - a person who has knowledge of disability advocacy and quality
management practices, and skills in collecting and analysing data. Auditors
collect and analyse evidence from a range of sources and have input into
audit ratings.
Consumer Technical Expert (CTE) - a person with disability, engaged for
his/her specialist knowledge and abilities (e.g. empathy with the life
experience of people with disability) and ability to plan and facilitate the
effective input of people with disability in an audit process. They must
themselves have been a service recipient of a State or Commonwealth
funded disability organisation in Australia.
Witness auditors - additional auditors may participate in your audit. Called
witness auditors, they are appointed by JAS-ANZ and are there to observe
how your Certification Body conducts the audit. Witness auditors are part of
JAS-ANZ's system for ensuring that organisations receive a quality
certification audit. Certification Bodies also use witness audits or
‘verifications’ as part of their training and ongoing auditor monitoring
programs where another auditor will come along to ‘verify’ that the audit
team is competent and following the right processes and procedures.
What does a certification audit involve?
Certification audits involve a range of activities designed to collect evidence to
demonstrate that a disability advocacy agency is complying with the Disability
Advocacy Standards and KPIs. These include interviewing the governing body,
agency management, staff, people with disability and other agency consumers,
and reviewing files. It may also include observing the environment/physical
layout, as well as interactions between staff/management/people with disability.
The time needed for the on-site assessment will vary depending on your agency
size, number/type of models, and the communication abilities and support
needs of people with disability. JAS-ANZ Procedure 29 provides guidance on
audit duration.
25
The Stage 2 audit (on-site assessment) will typically include:






A formal entry meeting - when the audit team must formally explain the
scope and objectives of the audit, the timetable and planned audit activities,
as well as allow adequate time for your questions.
Evidence gathering - most of which involves observations, sighting
documents, forms, and records and conducting interviews with the
governing body, management and staff. When gathering evidence, many
auditors work on the basis of “Show me”. A specific component of the
evidence gathering involves consultation with people with disability and
other agency consumers. Certification Bodies are required to have
developed a consultation plan for people with disability before the on-site
assessment, and to communicate with you about sample size, selection and
consultation methods.
An audit review meeting - when the audit team discusses findings and
develops its assessment decisions. Most audit teams work on the principle
of “no surprises” so the agency is kept informed throughout the audit of any
compliance issues.
The audit team will assess each agency as either compliant or noncompliant with the Disability Advocacy Standards. The assessment is based
on the ratings scale in JAS-ANZ Procedure 29 and outlined next in Step 7.
The audit team will explain the process if there are nonconformities,
including how to close these out, and the specific timeframes which must be
met. Remember that a nonconformity is not a failure – it just means
that it will take more time for your disability advocacy agency to
become certified.
A formal exit meeting - when the audit team presents its findings, including
compliance with each of the 10 Disability Advocacy Standards and 25 KPIs.
If a disability advocacy agency has any questions about the audit team’s
assessment of their agency, they should take this opportunity to ask
questions. If the agency feels they have been unfairly assessed, they are
able to make an appeal. See Section 6 of this Toolkit for further information.
Step 6: Checklist
Check that you have considered:
Have we prepared the venue for the formal entry meeting and
ensured that it is an empowering environment for all individuals
present?
Have we taken the opportunity to ask any questions we need to about
the audit process at the formal entry meeting?
Have we assisted our Certification Body to gather evidence and
observe activities?
Have we ensured that staff and people with disability and other
agency consumers, Board/management members are present for
scheduled interviews or feedback sessions?
Have we prepared the venue for the formal exit meeting and ensured
26
Check that you have considered:
that it is an empowering environment for all individuals present?
Have we taken the opportunity to comment on the findings of the audit
team at the formal exit meeting?
Step 7: Audit team assessment report and follow up
After your certification audit, you will receive a draft audit report from the
Certification Body within 10 working days of completing the on-site audit for a
single site agency (or 20 working days for multiple site agencies).
Audit Reports
You will receive a draft report from your Certification Body with ratings against
each Standard and KPI, based on the following rating system:



Major nonconformity (you have three months to correct)
Nonconformity (you have six months to correct)
Conformity
The KPI with the lowest rating under each Standard determines the overall
rating for each Standard.
If your disability advocacy agency delivers more than one model of advocacy
support, you will receive one overall report, with one overall rating provided for
each KPI. If your agency has a number of outlets, the organisation as a whole
will be assessed, outlets sampled, and one overall report provided. The report
will identify nonconformities at on-site audit completion even if your agency has
addressed nonconformities before the report is finalised. JAS-ANZ Procedure
29 provides details of what will be included in audit reports.
Reports may also include 'observations' which could include positive feedback
or notes about opportunities for improvement. Such observations do not prevent
certification but you should carefully consider them, to make sure that the issue
does not create a nonconformity in the future.
Your agency has 10 working days from receiving the draft written report in
which to provide a response to the Certification Body.
The Certification Body will consider any responses provided by your disability
advocacy agency, and the final certification decision is made by Certification
Body personnel not involved in the actual audit itself. The final audit report is
then provided to FaHCSIA and your agency within a further seven working
days.
Step 7: Checklist
Check that you have considered:
Have we provided feedback from the draft report to people with
disability and other relevant stakeholders, staff/management, and the
27
Check that you have considered:
governing body?
Have we provided responses back to the Certification Body within 10
working days?
If you have received a 0 - major nonconformity rating:
Have we sent a corrective action plan to the Certification Body within
five working days?
Have we taken corrective action within three months?
Have we participated in a follow-up visit by our Certification Body to
assess the corrective action within three months? If your Certification
Body thinks that corrective action has been partly successful, the 0
rating may be upgraded to a 1. This will give you an additional three
months to correct the nonconformity.
If you have received a 1 - nonconformity rating:
Have we taken corrective action within six months?
Has our Certification Body verified the corrective action we have taken
within six months?
HINT: Achieving certification
Your disability advocacy agency cannot be granted certification until all major
nonconformities and nonconformities have been corrected, and that correction
has been verified by the Certification Body.
It is advisable for all disability advocacy agencies to plan their certification
activity early within the transition period, so that audits can be organised and
booked in advance, and there is sufficient time to correct any nonconformities or
major nonconformities.
Step 8: Start three year audit cycle
Once your disability advocacy agency has achieved certification, you begin a
three year audit cycle involving annual self-assessments, surveillance audits
and recertification audits. Internal audits are also a very practical tool to utilise
each year as part of continuous improvement activity (see Section 5 for further
information about internal audits).
Self-Assessment
The self-assessment should take place annually as per the suggestions in Step
4. The self-assessment will provide valuable information about areas for
improvement which can be addressed in the lead up to the surveillance and
recertification audits.
Surveillance and recertification audits
Surveillance audits happen once a year to check that your disability advocacy
agency continues to comply with the Disability Advocacy Standards. The first
surveillance audit must take place within 12 months from the date of the last
28
day of the on-site certification audit. The second surveillance audit must take
place within 13 months from the last day of the first surveillance audit. Disability
advocacy agencies should plan for and book in their surveillance audit at least
two months prior to the deadline.
Surveillance audits typically cover:
1. Interviews with relevant management and a sample of consumers;
2. An assessment of Standards 2, 7, 8, and 10 and other selected Standards;
3. Your procedures for periodically evaluating and reviewing your compliance
with relevant legislation and regulations;
4. Progress of planned activities aimed at continuous improvement; and
5. Follow-up action taken on nonconformities identified during the last audit.
Recertification audits happen every three years. The first recertification audit
must be undertaken within three years of the issue of the certificate of
compliance. The purpose is to verify the continuing overall effectiveness of your
disability advocacy agency and to examine the commitment and actions
towards continuous improvement. Recertification audits review past
performance over the three year certification period. Recertification audits
generally take as long as, and involve a similar level of consultation with people
with disability and other key stakeholders, as the initial certification audit.
Step 8: Audit cycle checklist
During the first year after certification:
Have we ensured that there are methods in place to continuously
improve against the Disability Advocacy Standards?
Have we undertaken a self-assessment prior to the surveillance audit?
Have we made arrangements for our surveillance audit, has it been
conducted and have we checked the areas for improvement or action
items and included them on our improvement plan?
During the second year after certification:
Have we undertaken a self-assessment prior to the surveillance audit?
Have we ensured that we have methods in place (e.g. internal audits) to
continuously improve against the Disability Advocacy Standards?
Have we made arrangements for our surveillance audit, has it been
conducted and have we checked the areas for improvement or action
items and included them on our improvement plan?
.During the third year after certification:
Have we undertaken a self-assessment prior to the recertification audit?
Have we ensured that we have methods in place (e.g. internal audits) to
continuously improve against the Disability Advocacy Standards?
Have we re-negotiated our contract with our current Certification Body or
negotiated a contract with a new Certification Body with sufficient time to
ensure the audit takes place before the end of the third year?
Refer to Step 2 for what to consider in choosing a Certification Body.
Additional considerations include:

How professionally, fairly and efficiently you feel the audit team
conducted certification and surveillance audits in the last cycle
29
During the first year after certification:


Quality and quantity of feedback provided at audits
Quality of the audit report.
Have we prepared for our recertification audit?
Checklist for your consideration:

Where is our last audit report?

What comments did the audit team make?

Are there any priority issues we can identify for this audit cycle?

What did we learn from the last audit cycle?

What strategies could we use to overcome barriers we identified?

Has our disability advocacy agency substantially changed since our
last audit cycle (e.g. staff or structural changes)?

How will this impact our agency’s performance against the Disability
Advocacy Standards?
30
3.3 Summary of the step by step guide to
Disability Advocacy Standards certification
This is an overall summary of the steps involved, timeframes and actions
required for achieving initial certification and entering into the three year audit
cycle.
Step
Milestones/Notes
1. Start the process




Pre-audit
2. Select a
Certification Body


3. Notify FaHCSIA

4. Conduct selfassessment




5. Prepare for
certification
audit/Stage 1 audit





Review your disability advocacy agency’s
structure and documented policies and
procedures
Consider who will be involved in the audit –
staff, management, people with disability,
board members, other stakeholders
Become familiar with the tools available in
this Toolkit
Consider how your disability advocacy
agency will arrange and encourage
consumer participation
Choose an accredited Certification Body
that best suits your disability advocacy
agency
Negotiate your contract with the
Certification Body
Advise FaHCSIA of your chosen
Certification Body
Conduct an assessment of your disability
advocacy agency’s performance against
the Standards and KPIs
Identify any gaps your agency will need to
work on before the audit
Take action to address gaps identified by
the self-assessment process
Submit materials relating to selfassessment, including policies and
procedures relevant to the Standards, to
the Certification Body prior to the official
audit
Liaise with your Certification Body to
discuss the audit plan
Provide general information to your
Certification Body about consumers etc.
Actively encourage consumers to be
involved in the audit
Your certification body reviews your
disability advocacy agency’s documentation
(Stage 1) and decides if they are ready for
the audit
Your certification body will nominate an
audit team and prepare an audit plan
31
Step
Milestones/Notes

3 yearly cycle
Assessment and Decision
6. Participate in
certification
audit/Stage 2 audit
7. Audit team
assessment report
and follow up
8. Start three year
cycle
a)Prepare for first
surveillance audit
b) Prepare for second
surveillance audit
c) Re-negotiate
contract with
Certification Body
d)Prepare for
recertification audit
Liaise with your Certification Body about
preparations, in particular strategies for
consumer consultation
 An audit team from the Certification Body
will visit your disability advocacy agency on
site
 Your agency will be expected to help
organise audit activities
 Assist your Certification Body to gather
evidence and observe activities
 The audit team prepares a draft audit report
including an assessment of your disability
advocacy agency’s compliance and
provides verbal feedback
 Your agency takes the opportunity to
comment on the findings of audit team
 Your agency receives the draft report and
provides response
 The audit team finalises the report and
provides a copy to your agency and
FaHCSIA
 Certification Body personnel independent of
the audit team reviews the audit report and
makes a decision regarding certification
 A certificate of compliance is issued to your
agency by your Certification Body who
provide a copy to FaHCSIA
NB: All nonconformities need to be addressed
before a certificate of compliance can be
issued
 Ongoing continuous improvement and
corrective action
 Review your Certification Body’s cost and
quality of work
 Document continuous improvement
32
3.4 Comprehensive step by step guide to
Disability Advocacy Standards certification
This is a more comprehensive guide for steps involved in the certification
process.
Step 1 – Start the process
Date
Notes
Has your disability advocacy agency collated the
documentation that describes the advocacy work of your
agency?
What model/s of advocacy does the agency undertake?
Has your disability advocacy agency collated policies and
procedures Does your agency have written policies and procedures?
Where are they and when were they last updated?
Do they reflect all of the Disability Advocacy Standards?
Collate documentation for other quality systems Does your organisation operate any other quality
systems?
Could these systems contribute any evidence for the
NDAP certification audits and avoid audit duplication?
Has your disability advocacy agency developed a plan for
involving all relevant stakeholders? Who should be
involved in the audit process? Regardless of whether
people with disability are consumers of your agency, they
will need to be involved in the audit process. Your
disability advocacy agency will need to consider
involving:
 staff/ volunteers
 people with disability/consumers
 family members/carers
 Board members and management.
Step 2 – Select a Certification Body
Date
Notes
Has your disability advocacy agency investigated the
options What requirements are important to your agency in
selecting a Certification Body?
Is the Certification Body experienced in auditing similar
agencies? Can they provide references?
What are the costs of the Certification Body?
Has your disability advocacy agency submitted an
application form to the chosen Certification Body,
following any requirements they have outlined.
Has your agency negotiated a contract with a Certification
Body?
33
Step 3 – Notify FaHCSIA
Date
Note
Step 4 – Conduct a self-assessment
Date
Notes
Has your disability advocacy agency completed the
following steps?
Has your agency involved consumers and people with
disability and stakeholders (where people with disability
are not the consumers of the agency, they will still need to
be involved)?
Has your agency conducted a self-assessment against
the Disability Advocacy Standards?
Has your agency taken action to address gaps identified
by the self-assessment process?
Has your agency documented self-assessment findings?
Step 5 – Prepare for the certification audit
Date
Notes
Notify FaHCSIA of your chosen Certification Body
Has your disability advocacy agency completed the
following steps?
Has your agency collated the agency’s policies and
procedures and self-assessment findings?
Has your agency sent the relevant documents to your
Certification Body?
Has your agency provided general information to your
Certification Body about the consumers and the model/s
of advocacy undertaken?
If the Certification Body identified any issues in their
Stage 1 Audit, has your agency taken action to address
these?
Has your agency liaised with your Certification Body to
discuss how the certification audit will proceed, for
example, the sample of consumers or people with
disability who will need to be involved in the audit and how
your agency will include representatives of all
demographics (e.g. gender, age, cultural, or language
differences, complexity of support needs including
communication, and length of tenure with the agency,
including those exited)?
NOTE: If your agency offers more than one model of
advocacy or operates from more than one site, the
sample will include representation from each model of
advocacy and each site selected by the Certification Body
for the audit. JAS-ANZ Procedure 29 provides further
details about this sampling
Has your agency prepared the sample of consumers
and/or people with disability to provide feedback and
organised support, where necessary?
Has your agency actively encouraged consumers and
34
people with disability to participate and arranged their
involvement and organised support, where necessary?
Has your agency arranged consent forms and consent for
access to files of participating consumers (for models of
advocacy where the person with disability or a member of
their family is a consumer of the advocacy agency)? See
Attachment 2 for a sample consent form.
Has your agency prepared for audit activities in line with
your Certification Body’s requirements, including:
 preparation for the formal entry and exit meeting e.g.
schedule, arrange a room and alert attendees?
 organised interviews with consumers and people with
disability?
Step 6 – Participate in the certification audit
Date
Notes
Has your disability advocacy agency prepared the venue
for the formal entry meeting and ensured that it is an
empowering environment for all individuals present?
Has your agency taken the opportunity to ask any
questions about the audit process at the formal entry
meeting?
Has your agency assisted your Certification Body to
gather evidence and observe activities?
Has your agency ensured that staff, volunteers,
consumers and people with disability are present for
scheduled interviews or feedback sessions?
Has your agency taken the opportunity to comment on
findings of the audit team?
Step 7 – Audit team assessment report and follow up
Date
Notes
Has your disability advocacy agency prepared the venue
for the formal exit meeting and ensured that it is an
empowering environment for all individuals present?
Has your agency taken the opportunity to comment on
findings of the audit team at the formal exit meeting?
Has your agency reviewed the draft report when
received?
Has your agency provided a response on the draft report
to Certification Body?
Has your agency provided feedback about the audit
results to:
 consumers/ people with disability?
 staff, volunteers and management of the agency?
 the Board of the agency?
Has your agency addressed suggested improvements Did the Certification Body suggest any improvements to
your agency’s operations?
How will your agency address suggestions?
35
Has your agency addressed nonconformities Did your agency receive a major nonconformity or
nonconformity assessment against any of the Standards
or KPIs?
Does your agency feel the assessment is fair? (If not, you
can lodge an appeal – please see the complaints
resolution information in Section 6)
If your agency is not appealing the decision, what
corrective action will be taken to address the
nonconformity?
Did your agency gain certification? Celebrate!
Step 8 – Start 3 year cycle
Date
Notes
Has your disability advocacy agency put in place an
ongoing system for continuous improvement and
corrective action?
1) Has your agency prepared for and participated in the
first surveillance audit:
 Conducted annual self-assessment?
 Implemented continuous improvement activities?
 Participated in a surveillance audit before the end
of the first year?
2) Has your agency prepared for and participated in the
second surveillance audit:
 Conducted annual self-assessment?
 Conducted continuous improvement activities?
 Participated in a surveillance audit before 13
months after the last surveillance audit?
3) Has your agency re-negotiated/negotiated a contract
with a Certification Body:
 Considered the professionalism of the audit team
during the last three years, the quality and quantity
of feedback at audits, and the quality of the audit
reports?
4) Has your agency prepared for and participated in a
recertification audit?
 Check that you have considered:
o Undertaking a new self-assessment;
o What did we learn from the last audit cycle?
o Are there any priority issues we can audit for this
audit cycle?
o What strategies could we use to overcome
barriers we identified?
o Has our organisation substantially changed
since our last audit cycle?
36
Section 4: Disability Advocacy
Standards, examples of evidence and
self-assessment worksheets
In this section, you will find the Disability Advocacy Standards with policy and
program context, and examples of evidence for each Standard. This information
will be essential during the self-assessment process. You will also find
recommended self-assessment worksheets, which allow you to rate your own
agency against each of the Disability Advocacy Standards.
Disability Advocacy Standards
The 10 Disability Advocacy Standards and 25 KPIs define the elements of
quality advocacy support for people with disability. The Standards form the
basis for QA and continuous improvement processes. To be certified, disability
advocacy agencies must comply with and demonstrate continuous improvement
against the Disability Advocacy Standards. A complete set of the Standards and
KPIs appears in the following pages in this Section, and can be found on the
ComLaw website.
The Disability Advocacy Standards have the same intent across all advocacy
models, but may require different kinds of evidence to demonstrate compliance
and continuous improvement. Disability advocacy agencies undertaking
different advocacy models will demonstrate conformity with the Disability
Advocacy Standards in different ways and with different forms of evidence.
Auditors are required to have a clear understanding of the different models of
advocacy and what this means for demonstrating compliance and reporting
requirements.
Policy and program context for Disability Advocacy Standards
Each Standard contains a statement about the policy and program context of
the Standard for disability advocacy agencies. This statement is intended to
highlight the strategic intent and key features of the Standard. Over time these
statements may be updated to reflect new policy or program initiatives or
changed stakeholder expectations.
Where compliance with the Standard will be different depending on the
approach to advocacy, this has been indicated.
Examples of evidence
Examples of evidence have been developed for all of the Disability Advocacy
Standards and are provided in this Toolkit to assist disability advocacy agencies
in preparing for the certification process. A complete set of the Standards, KPIs
and examples of evidence is included in Attachment 3.
The core examples of evidence are a resource that your disability advocacy
agency can use to reflect on what may constitute evidence of compliance with a
37
Disability Advocacy Standard. Your agency can use this resource to help gather
and develop evidence to:



Use internally to assess your agency’s performance against the Disability
Advocacy Standards (for example, through the self-assessment);
Demonstrate to a Certification Body’s audit team what your agency is doing
to meet the Disability Advocacy Standards; and
Use internally to help your agency find ways to continually improve and
innovate.
Examples of evidence have been developed for each Standard, and the related
KPIs, to guide disability advocacy agencies on the types of evidence that might
be appropriate to demonstrate compliance. There are some forms of evidence
that will be applicable to all models of advocacy and others specific to the
model/s of advocacy undertaken. As the majority of disability advocacy
agencies deliver advocacy through a range of models, they will demonstrate
conformity with the Standards through the use of evidence appropriate to the
various models of advocacy used.
It is important to remember that the examples of evidence are not
intended to be a compliance checklist. Rather they offer examples and
guidance only. If you have different or additional evidence that shows how
your disability advocacy agency has complied with, or continually
improved against the Standards, you can present that evidence to your
audit team. Think of evidence not in terms of what your agency does, but
how your agency can demonstrate what it does.
The strongest evidence is that which can be verified through three sources:
interview, observation and documentation (sometimes referred to as ‘people,
process and paper’).4 Your documentation, your staff’s understanding and
compliance with it and people with disability and agency consumer’s
confirmation of its application are key components for verification that your
processes and systems comply with the requirements of the Disability Advocacy
Standards. The focus of evidence for certification will be on practical
observations (‘Show me’) of on-the-ground practices and consumer feedback
that demonstrate that your disability advocacy agency has a systematic
approach to meeting the Standards.
Organisational checklist – evidence examples
Check that you have considered:
Have we become familiar with the examples of evidence for the relevant
advocacy models we provide?
Have we used the examples of evidence to develop material to show the
audit team?
Have we reviewed the examples of evidence internally to assess
performance through self-assessments?
Have we reviewed the examples of evidence internally to find ways to
continually improve?
4
Disability Sector Quality System, Resources and Guide, Queensland Government
38
4.1 Disability Advocacy Standards, KPIs and
evidence examples
Standard 1: Accessing advocacy
Each person with disability has opportunities to access advocacy on the basis
of relative need and available resources.
1.1
The advocacy agency adopts, applies and promotes non-discriminatory
policies in respect of age, gender, race, culture, religion, disability or
living arrangements, consistent with the contractual obligations and
purpose of the advocacy agency and the relative need and available
resources.
1.2
The advocacy agency has processes to determine how the individuals or
issues supported are chosen and prioritised based on relative need and
available resources.
1.3
Each person with disability is informed about how decisions are made in
relation to access and advocacy issues.
Policy and program context
This Standard covers the policies, procedures and practices used by disability
advocacy agencies to ensure people with disability have opportunities to access
advocacy – where an individual or group directly seek advocacy; where the
agency seeks to provide opportunities for individuals and groups to access
advocacy; and where the agency supports and facilitates advocacy undertaken
by families, citizens or the person with disability.
In terms of entry processes in relation to Standard 1, disability advocacy
agencies should consider:




Target group – the group of people whose needs the agency is designed or
funded to meet, potentially specifying characteristics, such as age,
geographical location, the type of needs which can be met, or type of
disability;
Eligibility criteria – the criteria for determining whether a person is part of
the agency’s target group and therefore eligible for advocacy;
Entry processes – the basis for deciding between applicants when there are
more people wanting to access advocacy than there are vacancies
available; and
Exit processes.
Every disability advocacy agency must be able to demonstrate that its entry
processes are non-discriminatory in respect of age, gender, race, culture or
disability. The agency’s eligibility criteria must not contain any restrictions on
entry, other than those defined by its target group and FaHCSIA’s contractual
39
obligations. Similarly, the agency’s process for allocating priority between
eligible applicants should only be based on FaHCSIA’s contractual
requirements, the relative needs of applicants and its available resources.
In terms of exit processes, the disability advocacy agency should consider:






The circumstances in which people with disability can voluntarily leave the
agency, for example, when their needs have changed;
The agency’s contractual requirements in relation to exits;
The circumstances in which people with disability can be required to leave
the agency and the basis on which such decisions may be made, for
example, when the agency can no longer meet their needs;
The agency’s approach to referrals to other advocacy agencies, either when
the agency does not have the capacity to accommodate a new consumer or
when they can no longer meet a current consumer’s needs;
What happens to personal information about a consumer when he or she
leaves the agency; and
Consumer involvement in decision making about the exit process in any of
the above instances.
Disability advocacy agencies undertaking family advocacy should outline in
their purpose statement, policies and practices that the focus of the advocacy is
on the person with disability.
As disability advocacy agencies undertaking systemic advocacy do not
undertake advocacy on an individual basis, they will need to outline and make
clear in their purpose statement, policies and practices that they do not work
with individual people with disability. In this context, systemic advocacy
agencies should demonstrate opportunities given for people with disability to
contribute to/ participate in the prioritising of processes that determine which
systemic issues receive attention.
Things to consider: Accessing advocacy
All disability advocacy agencies

We clearly communicate with people with disability, who our agency works
with to promote, protect and defend the welfare of and justice for people
with disability
Disability advocacy agencies with individual consumers

Our eligibility criteria and entry procedures are non-discriminatory,
consistent with the contractual obligations and purpose of our agency

Our entry procedure is documented and consistently applied by staff.
Procedure specifies the catchment area/ target population of our agency
and other relevant eligibility criteria
We use proactive strategies to reach those who are unable or unlikely to
access advocacy for various reasons

40

Exit procedure is documented and consistently applied by staff

Referral policy is documented and used when the demand for advocacy is
greater than our agency’s capacity, or our agency cannot meet an
applicant’s needs

System for determining priority of access to advocacy is documented and
consistently applied. System is fair, equitable and takes account of relative
need and available resources

Our consumers are informed about and understand how decisions
regarding access and prioritisation of resources are made

Information about our agency is accessible to people with disability
including those from Culturally and Linguistically Diverse (CALD)
backgrounds
Systemic

We inform people with disability about the systemic advocacy issues our
agency pursues
The following table contains some examples of evidence an agency may want
to use to demonstrate their compliance with Standard 1.
41
Disability Advocacy Standards, KPIs and Examples of Evidence 2012
Standard
Key Performance Indicator
Examples of Evidence
Standard 1:
Accessing advocacy
1.1 The advocacy agency adopts,
applies and promotes nondiscriminatory policies in respect of
age, gender, race, culture, religion,
disability or living arrangements,
consistent with the contractual
obligations and purpose of the
agency and the relative need and
available resources.
All agencies
 Purpose statement that makes it clear who the agency works with to promote, protect
and defend the welfare of and justice for people with disability.
 Evidence of staff participation in anti-discrimination and cultural awareness training
and/or evidence of links with relevant specialist agencies as appropriate, such as
MOUs or participation in joint projects with multicultural or indigenous advocacy
agencies.
 Evidence that the organisation is aware of demographic information/ABS statistics
and match of this to the profile of people with disability who receive advocacy
support.
 Documented and implemented non-discriminatory practices and policies for
identifying and/or responding to requests for information, referral and/or advocacy
support.
Each person with
disability has
opportunities to access
advocacy on the basis
of relative need and
available resources.
1.2 The advocacy agency has
processes to determine how the
individuals or issues supported are
chosen and prioritised based on
relative need and available
resources.
1.3 Each person with disability is
informed about how decisions are
made in relation to access and
advocacy issues.
Agencies undertaking individual advocacy/ legal advocacy
 Documented and implemented entry and exit policies and procedures highlighting
non-discriminatory practice, which may include ongoing access for people with
disability who receive advocacy support after their issue/case is closed.
Agencies undertaking systemic advocacy
 Documented and implemented practices and/or policies for deciding and
communicating which systemic issues the agency will work on.
 Documented and implemented practices and policies showing how people with
disabilities influence/contribute to the prioritising processes that determine which
issues receive attention.
Agencies undertaking citizen advocacy



Annual protégé recruitment plan that reflects diversity and level of vulnerability of
people with disability.
Consistent practice of “seek-out” recruitment of people with a disability who need
advocacy, but who would not ordinarily come to the attention of the agency if it relied
solely on (self- or other-initiated) referrals.
Established Advisory Support Group (e.g. Sub-Committee), which can assist in the
implementation of the appropriate Protégé entry and exit policies and procedures.
42
Standard 2: Individual needs
Each person with disability receives advocacy that is designed to meet their
individual needs and interests.
2.1
The advocacy agency has a process for determining and documenting
the advocacy objectives that reflect the wishes, needs or interests of
each person with disability.
2.2
Advocacy activities are directed to meeting the advocacy objectives of
each person with disability.
2.3
Each person with disability engaged in determining advocacy objectives
is provided with opportunities to involve a support person of their choice.
2.4
In meeting the needs of a person with disability, the advocacy agency
avoids, where possible, any conflict of interest or the perception of any
conflict of interest in relation to the conduct of its advocacy work, and
deals with any conflict or perceived conflict transparently.
2.5
The advocacy agency helps to empower people to advocate for
themselves or their family or others with appropriate strategies (e.g.
information, training, mentoring, support.)
Policy and program context
Disability advocacy agencies must ensure support is provided in a manner
sensitive to the age, sex, and the cultural, linguistic and religious background of
each person with disability. In the context of Standard 2, where applicable to the
programs and activities they undertake, agencies are expected to ensure that:





Advocacy objectives are established to reflect the needs of people with
disability;
Individual’s objectives and plans do not have any unnecessary restrictions
or constraints;
The social and cultural values, beliefs and practices of people with disability
are respected;
People with disability are adequately involved in the development and
review of advocacy objectives and plans; and
People are empowered to advocate for themselves or family or others.
Standard 2 refers to ‘individual need’ in terms of both the needs of an individual
person that may be met through individual advocacy provided to the person
with disability, and the collective needs of people with disability that may be met
through systemic advocacy.
For those disability advocacy agencies that provide advocacy on an individual
basis, people with disability are entitled to receive advocacy that is tailored to
their individual needs and interests. In these cases, they should ensure people
with disability have:


individual advocacy objectives; and
an individual advocacy plan that outlines strategies to be used.
43
In the context of systemic advocacy, where disability advocacy agencies do
not have individual consumers, or develop individual advocacy plans, they
should demonstrate that people with disability have been consulted prior to
systemic advocacy actions being undertaken on their behalf; or, in reactive
cases, that people with disability have been informed of the actions being
undertaken on their behalf.
Disability advocacy agencies undertaking family advocacy do not provide
direct support to the individual with disability. In this context, they should
demonstrate how the best interests and needs of the person with disability are
determined when advocates work directly with family members of the person
with disability.
It is expected that self advocacy agencies will have established practices and
policies for developing the capacity of people with disability to self advocate. In
the case of individual and citizen advocacy, the agency may not provide specific
self advocacy training, but in the course of their work with the person with
disability, may empower individuals to do as much as possible for themselves,
and show effective advocacy processes so they could self advocate in the
future.
Things to consider: Individual needs
All disability advocacy agencies

We ensure people with disability are actively involved in establishing
advocacy objectives (on an individual or collective basis, as appropriate to
the purpose of our agency)

We avoid where possible, conflict of interest arising in relation to advocacy
work

We involve people with disability in regular reviews of advocacy activities to
ensure their continued relevance (on an individual or collective basis, as
appropriate to the purpose of our agency)

People with disability are satisfied with the way we work with them to
determine their needs

People with disability are satisfied with the way we respond to their needs

People with disability are informed of the advocacy activities being
undertaken (on an individual or collective basis, as appropriate to the
purpose of our agency)
Where people with disability are the direct consumers of the disability
advocacy agency

We ensure that consumers understand and, where appropriate, sign-off on
advocacy activities undertaken
44

We ensure that people with disability are empowered to advocate for
themselves or family or others with appropriate strategies
Family advocacy

We consider the needs of the person with disability as the priority in
planning advocacy that supports their family member
The following table contains some evidence examples that an agency might
consider using to show how they comply with Standard 2.
45
Disability Advocacy Standards, KPIs and Examples of Evidence 2012
Standard
Standard 2: Individual
needs
Each person with disability
receives advocacy that is
designed to meet their
individual needs and
interests.
Key Performance Indicator
Examples of Evidence
2.1
The advocacy agency has a process
for determining and documenting the
advocacy objectives that reflect the
wishes, needs or interests of each
person with disability.
2.2
Advocacy activities are directed to
meeting the advocacy objectives of
each person with disability.
2.3
Each person with disability engaged
in determining advocacy objectives is
provided with opportunities to involve
a support person of their choice.
2.4
In meeting the needs of a person
with disability, the advocacy agency
avoids, where possible, any conflict
of interest or the perception of any
conflict of interest in relation to the
conduct of its advocacy work, and
deals with any conflict or perceived
conflict transparently.
2.5
The advocacy agency helps to
empower people to advocate for
themselves or their family or others
with appropriate strategies (e.g.
information, training, mentoring,
support)
All agencies
 Evidence of practice of supporting/educating people with disabilities to
advocate for themselves and/or of supporting/educating families to
advocate on their behalf.
 Examples of how the agency has taken into account the specific needs of
people from Indigenous and CALD backgrounds, people with specific
disabilities such as hearing impairment, people with literacy difficulties.
 Interpreters are provided where requested or where a need is identified.
 Agency promotional material that makes it clear the extent, if at all, the
agency provides training and support.
 Documented and implemented policies and practice of responding to the
information needs of people with disabilities/families and providing referrals
as appropriate.
 Agency policy on conflict of interest.
 Documented and implemented practices and policies for identifying and
transparently dealing with conflicts of interest that arise for the
organisation, Board and staff, for example, a Conflict of Interest register
maintained for staff and Boards of Management, or evidence in minutes of
a standing agenda item that flags the need to declare any conflict of
interest.
 Management, staff and volunteer training in recognising and dealing with
conflicts of interest.
Agencies undertaking individual advocacy/ legal advocacy
 Documented and implemented policies and practices for developing and
implementing individual advocacy plans in partnership with people with
disability and/or their families/guardians (as appropriate).
 Evidence of collecting and reviewing feedback about the extent to which
the needs of the person with a disability are met.
46
Agencies undertaking self advocacy

Observations of people with disabilities receiving support to develop
advocacy action plans to address their wishes, needs or goals.
Agencies undertaking systemic advocacy
 Documented and implemented practices and policies showing how people
with disabilities influence the choice of advocacy objective.
 Evidence of reporting of outcomes / review of advocacy process.
 Evidence of advocacy plan, actions taken and people/agencies involved, or
file notes detailing progress or justification for not having a plan in place.
 Policies and procedures to address how the agency selects and prioritises
the systemic issues it addresses.
Agencies undertaking citizen advocacy






Documented and implemented practices and policies for developing
confidential individual written profiles detailing ‘need’ and seeking
advocates based on their skills in relation to these needs.
Observations of individual being given opportunity to discuss their
advocacy needs and advocate role.
Details of completed relationships, and/or those being rematched or
awaiting rematching.
Documented and implemented practices and policies for reviewing the
extent to which the needs of the person with a disability are being met.
Practice of one-to-one (or near one-to-one) matching of people with a
disability with advocates to ensure that the individual needs of the person
with the disability remains the focus of the advocacy relationship.
Practice of recruiting advocates whose role is strictly voluntary, thereby
avoiding any conflicts of interest arising from receipt of monetary and/or inkind payments.
47
Standard 3: Decision making and choice
Each person with disability has the opportunity to participate as fully as possible
in making decisions about the advocacy activities undertaken.
3.1
The advocacy agency’s policies support each person with disability to
direct, within the limits of their capacity or interest, the advocacy activities
undertaken to meet their advocacy objectives.
3.2
In all circumstances the advocacy activity is informed by ethical
guidelines.
Policy and program context
The intent of this Standard is to ensure that disability advocacy agencies:




Ensure people with disability are supported to direct within the limits of their
capacity and interest, the advocacy activities undertaken to meet their
personal objectives;
Provide opportunities for people with disability to make informed decisions
and choices according to their individual needs;
Incorporate flexible options to facilitate informed decision making; and
Are informed by ethical guidelines and apply the principles of duty of care
and least restrictive alternative.
This Standard recognises that advocacy outcomes are best achieved where
people with disability have input into the decisions and choices about the
advocacy they receive. Primarily, people with disability will have input into the
day-to-day decisions and choices made in relation to their advocacy planning,
but input will also extend into the broader planning for the agency.
This Standard recognises that some people with disability may not always make
the decisions, but that they are supported to direct within the limits of their
capacity and/or interest the advocacy activities undertaken. Emphasis is put on
their involvement to improve the quality of decision and choices, and that
people with disability are informed at all stages in the decision making process.
People with disability may contribute to decision making in the following areas:



Planning the advocacy they receive as an individual (e.g. individual
advocacy plans);
Planning the overall priorities and direction of the advocacy agency (e.g.
corporate, business and advocacy planning, where appropriate); and
QA and continuous improvement processes (e.g. participation in consumer
consultations as part of an internal or certification audit).
Within each of these areas, disability advocacy agencies are expected to:

Ensure appropriate access to information about opportunities for
participation of people with disability;
48


Ensure that people with disability are encouraged and supported to access
these opportunities; and
Act upon the outcomes of people with disability’s contribution and influence.
Specifically, disability advocacy agencies are expected to:



Develop suitable processes for communicating with and educating all
people with disability about the audit process and the quality system;
Promote and implement opportunities that support the contribution of
people with disability in the consultation activities of certification
assessments with particular consideration given to supporting the
participation of ‘difficult to reach’ groups; and
Develop suitable mechanisms for facilitating people with disability’s
representation in audit preparation activities (e.g. self-assessments) and
certification assessment and reporting processes.
For systemic advocacy agencies, where people with disability are not the
direct consumers of the agency, the agency should, where appropriate and
possible, involve people with disability in decision making about the systemic
advocacy actions the agency will pursue on their behalf.
For family advocacy agencies, where the family member is the direct
consumer of the agency rather than the person with disability, agencies should
demonstrate that the person with disability has been consulted about the
advocacy activities undertaken on their behalf.
Things to consider – Decision making and choice
All disability advocacy agencies

We give consumers/ people with disability the information they need to
make choices that are genuinely informed

The information our agency provides to consumers/ people with disability is
in accessible formats

We ensure consumers/ people with disability have the opportunity to
participate in decision making and choice at the management/ corporate
level of our agency

We support consumers/ people with disability to take on roles on Board/
management committees in our agency

We ensure the choices/ preferences/ suggestions of consumers/ people
with disability are taken into account at an organisational level

We have systems for ensuring that the choices of consumers/ people with
disability are acted upon (where reasonable)
49

We ensure that people with disability are encouraged to be involved in our
agency’s QA activities

In all circumstances the advocacy activity is informed by ethical guidelines
Where people with disability are the direct consumers of the disability
advocacy agency

We obtain valid informed consent, where this is possible

We ensure consumers/ people with disability have the opportunity to
participate in decision making and choice at a personal/ individual level
The following table contains some examples of evidence an agency may want
to use to demonstrate their compliance with Standard 3.
50
Disability Advocacy Standards, KPIs and Examples of Evidence 2012
Standard
Standard 3: Decision
making and choice
Each person with disability
has the opportunity to
participate as fully as
possible in making
decisions about the
advocacy activities
undertaken.
KPI
3.1
3.2
Examples of Evidence
The advocacy agency’s policies
support each person with disability
to direct, within the limits of their
capacity or interest, the advocacy
activities undertaken to meet their
advocacy objectives.
In all circumstances the advocacy
activity is informed by ethical
guidelines.
All agencies




Observations of the way advocates interact with people with disability in making
decisions about advocacy activities.
Evidence of the involvement of people with disability in agency decision-making (e.g.
representation on the Board, participation in consultations that feed into agency’s
strategic plan or lead to improve practices, involvement in surveys that inform
agency policies and procedures).
Evidence of the involvement of people with disability in the agency’s QA activities.
Observation of information, strategies and ideas presented to people with disabilities
and families in ways that they can understand.
Agencies undertaking individual advocacy/legal advocacy

Ethics guidelines for supporting people with disability in making decisions about
advocacy activities.

Procedures are established and implemented for the regular review of advocacy
actions and these require review of the extent to which the agency promotes the
person’s choices and decisions.
Feedback is sought from people with disability on the extent to which the agency
promotes choice and decision making.


Documented and implemented practices and policies for determining a decision on
behalf of a person who has impaired decision making capacity e.g. consultation with
them, documenting factors taken into account including knowledge gathered over
time.
51
Agencies undertaking citizen advocacy



Evidence of induction and or training that orientates advocates to the need to
support people with a disability, where appropriate, to make decisions and choices.
Practice of supporting advocates to facilitate the process, where appropriate, of
decisions and choices made by people with a disability.
Evidence of feedback gained from people with disability about how they are
supported to make their choices.
Agencies undertaking systemic advocacy



Documented and implemented practices and policies that demonstrates that people
with disabilities influence decision making about advocacy activities.
Observations of individual people with disability and/or their families becoming
involved in systemic advocacy activities of their choice.
Ethical guidelines inform systemic advocacy policy and practice.
Agencies undertaking family advocacy

Documented and implemented practices and policies for encouraging families to
include the views of the person with disability in advocacy efforts where appropriate.
52
Standard 4: Privacy, dignity and confidentiality
The right of each person with disability to privacy, dignity and confidentiality is
recognised and respected.
4.1
The advocacy agency complies with the Information Privacy Principles of
the Privacy Act 1988 in order to protect and respect the rights of each
person with disability.
4.2
The advocacy agency promotes privacy, dignity and respect for each
person with disability.
Policy and program context
In the context of Standard 4, disability advocacy agencies are expected to:



Comply with the privacy principles contained within relevant legislation;
Ensure that people with disability are treated with dignity and respect in all
aspects of their lives; and
Maintain the confidentiality of all personal information relating to people with
disability.
This Standard refers to the promotion of tolerance and respect for people with
disability’s personal needs and circumstances. It relates not just to the disability
advocacy agency’s legal and contractual obligations in the area of privacy, but
more fundamentally to the values demonstrated by it in interacting and
communicating with people with disability. This includes:




Use of language and terminology within the agency;
How staff communicate with people with disability;
How staff work with people with disability (for example, where physical
assistance is required, it is provided in such a way as to respect and
promote the individual’s dignity, or where challenging behaviours are
displayed, these are dealt with well); and
How people with disability collaborate in advocacy planning and delivery
(see Standard 3).
In terms of legal compliance, people with disability have a right to privacy and
confidentiality consistent with the Information Privacy Principles contained in the
Privacy Amendment Act (Private Sector) 2000 and the Privacy Act 1988.
Agencies should be familiar with the Information Privacy Principles which cover,
among other things, requirements in relation to:


Collection – the disability advocacy agency should only collect personal
information if that information is necessary for one or more of its functions
or activities. It must take reasonable steps to ensure that the individual is
aware of the fact that he or she is able to gain access to the information and
the purposes for which the information is collected
Use or disclosure – the disability advocacy agency must not use or
disclose personal information about an individual for a purpose other than
53




the primary purpose of collection unless the individual has consented to the
use or disclosure
Data quality – the disability advocacy agency must take reasonable steps
to make sure that the personal information it uses or discloses is accurate,
complete and up-to-date
Data security – the disability advocacy agency must take reasonable steps
to protect the personal information it holds from misuse and loss and from
unauthorised access, modification or disclosure
Openness – the disability advocacy agency must set out in a document,
clearly expressed policies on its management of personal information
Disposal – the disability advocacy agency must destroy or permanently deidentify personal information if it is no longer needed for any purpose for
which it was collected. Destruction of personal information must be
conducted under secure conditions.
Disability advocacy agencies should demonstrate documented procedures
consistent with the privacy principles. These may include:



Storing files in locked filing cabinets;
Ensuring consumer consent forms are signed; and
Ensuring staff and volunteers sign confidentiality agreements.
For further information in relation to the collection of information about
individuals, please refer to the Office of the Australian Information
Commissioner website.
Every disability advocacy agency and its staff should demonstrate respect for
the privacy and dignity of people with disability in terms of the way they interact
with and refer to people with disability.
As systemic advocacy agencies do not undertake advocacy on a one-to-one
basis they are less likely to collect information on individuals. However, where
information on individuals is collected as part of a systemic advocacy action,
agencies will need to adhere to the above requirements.
Although people with disability are not the direct consumers of family
advocacy agencies, it likely that personal information about the person with
disability will be collected while supporting the person’s family member. This
information should be treated in the same way as other agencies are expected
to deal with their consumers’ information.
Things to consider – Privacy, dignity and confidentiality
All disability advocacy agencies

We have documented privacy and confidentiality policies and procedures,
in line with the relevant requirements of the Privacy Act 1988

We ensure consistent implementation of our privacy and confidentiality
policies and procedures
54

We provide staff/ volunteer training that includes privacy, dignity and
confidentiality

Policies for this Standard may cover: record keeping; access policy for
confidential information, record disposal, confidentiality and privacy

Staff, management and volunteers demonstrate their commitment to
tolerance and respect

We have proactive strategies to promote tolerance and respect both for
individual needs and circumstances, and cultural, ethnic and religious
sensitivity

People with disability are satisfied with the tolerance and respect
demonstrated by our agency

We have practices in place that ensure staff have the right mix of skills to
treat people with disability with dignity

We have secure storage for both our paper and electronic files

We ensure that our privacy policies and procedures are updated, when
needed as technology changes

Our premises have a private space for use that has two exits

We have practices in place that ensure our privacy and safety obligations
are met
Where people with disability are the direct consumers of the disability
advocacy agency

We use, and make sure consumers understand, information
release/consent forms that consumers sign when a third party wants to
access their information

We inform and ensure that people with disability understand how we will
use their information
The following table contains examples of evidence a disability advocacy agency
may consider using to demonstrate their compliance with Standard 4.
55
Disability Advocacy Standards, KPIs and Examples of Evidence 2012
Standard
KPI
Standard 4: Privacy,
dignity and confidentiality
4.1
The advocacy agency
complies with the Information
Privacy Principles of the
Privacy Act 1988 in order to
protect and respect the rights
of each person with disability.
4.2
The advocacy agency
promotes privacy, dignity and
respect for each person with
disability.
The right of each person
with disability to privacy,
dignity and confidentiality is
recognised and respected.
Examples of Evidence
All agencies
 Observations of the way advocates and agency staff talk and write about people
with a disability.
 Clear privacy policy ensuring compliance with relevant State/Territory and Federal
legislation.
 Documented and implemented practices and policies for obtaining consent where
relevant and possible, examples could include consent to use photographs for
publicity or to share information.
 Confidential information safely stored e.g. locked filing cabinets.
 Staff [and volunteers and contractors] sign confidentiality agreements.
 Evidence that information about right to privacy is provided to people with
disabilities and their families when they receive advocacy support.
 Evidence that the feedback from people with disability who receive advocacy
support is used to influence the development of policies, procedures and practice of
the agency.
 Feedback from people with disability who receive advocacy support about the
attitude of agency staff to people with a disability.
 Feedback from external observers on the attitudes of the advocacy agency to
people with disability.
Agencies undertaking citizen advocacy
 Feedback from people with disability who receive advocacy support about the
attitude of agency staff to people with disability.
 Feedback from people with disability who receive advocacy support on the attitudes
of the advocacy agency to people with disability.
 Feedback from people with disability who receive advocacy support.
 Content and practice of orienting advocates to the importance of recognising and
respecting the right of people with disability to privacy, dignity and confidentiality.
Agencies undertaking family advocacy
 Documented and implemented practices and policies for encouraging families to
obtain the approval of the person with disability before sharing information about
the person with disability in the pursuit of advocacy efforts, where appropriate.
56
Standard 5: Participation and integration
Each person with disability is supported and encouraged to participate and be
involved in the community.
5.1
Through advocacy, opportunities for participation and involvement in the
community are promoted.
5.2
Where appropriate, the advocacy agency takes action to introduce,
influence or produce positive systemic change in the community.
Policy and program context
The Australian Government recognises that the quality and sustainability of
advocacy outcomes for people with disability are enhanced by physical and
social integration into the life of the wider community. The intent of Standard 5
is to provide advocacy that facilitates the inclusion of people with disability into
the life of the community.
The capacity of disability advocacy agencies to facilitate such integration will
vary according to several factors, including the nature of the advocacy they
undertake, FaHCSIA contractual obligations, the purpose of the agency and
other factors outside of their control. However, all disability advocacy agencies
have a responsibility to respond to barriers that limit opportunities for
participation and involvement in the community.
Disability advocacy agencies may engage in community education programs to
create awareness in the community of the need for change.
A holistic approach to advocacy recognises the importance of both immediate
outcomes for the individual consumer/ person with disability, and the barriers
that limit the participation and involvement of people with disability in the
community.
In practice, the ways in which disability advocacy agencies address this
Standard will vary according to the nature of the advocacy undertaken. For
example, systemic advocacy agencies will be able to demonstrate the
systemic issues the agency has selected to pursue. However, systemic
changes may take a significant amount of time to influence and it is important to
remember that agencies cannot control all outside factors, so it is expected that
agencies will only demonstrate the steps taken towards this goal.
Disability advocacy agencies that undertake advocacy on an individual basis
may demonstrate steps taken towards systemic change by identifying systemic
issues occurring for their consumers, and referring these to systemic advocacy
agencies to pursue. Referred cases should have appropriate follow-up and
support.
Where individual advocacy planning occurs, consideration should be given not
only to immediate needs and goals, but to the sustainability of these
opportunities. Advocacy plans should be reviewed regularly to ensure people
57
with disability are supported in making informed choices about either continuing
current advocacy strategies, or pursuing alternative opportunities which offer
greater physical and social integration with the wider community.
The community participation activities or programs should be meaningful and
varied and, where applicable to the model of advocacy being undertaken,
tailored to the individual’s community participation goals.
Additionally, people with disability must have access to appropriate information
about the scope of opportunities that an agency is able to offer so they can
make informed decisions about whether it will meet their needs.
Disability advocacy agencies undertaking individual advocacy may
demonstrate activities or programs they have engaged in that support
participation in community life. File notes may demonstrate the strategies and
goals for addressing barriers to community participation.
Citizen advocacy agencies will demonstrate the activities undertaken that
promote the involvement of people with disability in the community, recognising
that decisions about the advocacy activities undertaken made by the citizen
advocate and person with disability are outside the control of the agency.
Family advocacy agencies will not directly undertake advocacy activities with
the individual with disability but, where appropriate, will be able to demonstrate
that through supporting their family member, the person with disability’s
opportunities for participation in the community are enhanced.
Self advocacy agencies will work with individuals to build their skills and
abilities to advocate on their own behalf, which in turn increases their ability to
participate in wider community life.
Things to consider – Participation and integration
All disability advocacy agencies
 We provide information in accessible formats to help people with disability to
participate in the community
 We provide support for people with disability to participate in the community
(may be on an individual or collective basis)
 We develop networks within the community to promote and support the
participation of people with disability
 We create an inclusive and ‘non-threatening’ atmosphere within our agency
environment to make all consumers/ people with disability and their families
feel comfortable and welcome
 We network and liaise with relevant ethnic organisations to facilitate the
participation and integration of consumers/ people with disability in their own
communities
58
 We have practices to ensure that proposed advocacy activities are not in
conflict with the cultural and religious beliefs and practices of consumers/
people with disability
 We gather current information about the ethnic background of residents in
our agency’s local area
Where people with disability are the direct consumers of the disability
advocacy agency
 We align the ethnic profile of applicants and our agency’s current consumer
groups to more closely reflect the demographics of the local area
 We investigate referral rates when there is a low or nil response from local
ethnic communities to assess what steps need to be taken to improve our
agency
 We gather and make available resources pertaining to ethnic communities
(e.g. appropriate service directories, reference books, statistical information)
 We promote our agency to all potential consumers (e.g. through ethnic radio
and in ethnic newspapers and newsletters)
Systemic advocacy
 We take action to introduce, influence or produce positive systemic change in
the community
The following table contain examples of evidence an agency may consider
using to demonstrate their compliance with Standard 5.
59
Disability Advocacy Standards, KPIs and Examples of Evidence 2012
Standard
KPI
Standard 5: Participation
and integration
5.1
Through advocacy, opportunities for
participation and involvement in the
community are promoted.
5.2
Where appropriate, the advocacy
agency takes action to introduce,
influence or produce positive
systemic change in the community.
Each person with disability
is supported and
encouraged to participate
and be involved in the
community.
Examples of Evidence
All agencies
 Purpose statement that makes it clear that the agency seeks to promote
participation and inclusion.
 Examples of barriers to community participation being raised with other
agencies and authorities for the purpose of promoting change.
 People with disability connected to the organisation report that they feel
valued and accepted by agency staff.
Agencies undertaking individual advocacy/legal advocacy
 Evidence of advocacy taken on behalf of individual people with disabilities aimed
at increasing their participation and inclusion in the community.
Agencies undertaking citizen advocacy
 Examples of activities people with disability who receive advocacy support
and advocates are involved in – while recognising that the citizen advocates
and the person with a disability make their own decisions outside of the
control of the funded agency.
 Observation that community participation is covered in citizen advocate
orientation.
 Practice of recruiting advocates who—by virtue of being non-service,
“ordinary” members of the community—can facilitate the participation and
integration of people with a disability.
 Content and practice of orienting advocates to their potential role in
facilitating the participation and integration of people with a disability.
Agencies undertaking family advocacy /systemic advocacy/ self advocacy
 Examples of events /activities hosted or engaged in which promote the
inclusion of people with disabilities as valued and contributing members of
community.
 Examples of evaluation forms from events or activities hosted by the
organisation.
60
Standard 6: Valued status
The intrinsic value of each person with disability is recognised and each person
is supported and encouraged to enhance their valued status in the community.
6.1
Through advocacy, the aspirations and strengths of each person with
disability is promoted.
6.2
The advocacy agency promotes the intrinsic value and the valued status
of each person with disability in all its activities.
Policy and program context
Advocacy activities are undertaken on the basis that they support and enhance
the valued status of people with disability, whether on an individual or collective
basis. Disability advocacy agencies recognise that a person’s self-worth can be
affected by how well they fit into roles that are valued in the community. It may
be appropriate for agencies’ mission and vision statements to include reference
to valued status.
Disability advocacy agencies are required to undertake advocacy in a way that
enables people with disability, as far as possible, to live and work in ways that
are valued by the community. Agencies may undertake activities in the
community to promote the intrinsic value of people with disability. Depending on
the model/s of advocacy the agency undertakes, this may include community
education, media and communications that positively promote people with
disability, or speaking at public conferences and lectures.
Disability advocacy agencies are expected to promote a positive image of
people with disability both within the community and within the advocacy
agency itself. For all agencies, promoting the valued status of people with
disability will involve the way in which people with disability are referred to by
the agency and staff, for example, in promotional material.
In cases where agency staff or volunteers undertake advocacy on a one-to-one
or near one-to-one basis, activities should promote the person’s valued status
and enhance their abilities, skills and/or opportunities to make valued
contributions to the community. For example, the person with disability may be
supported to undertake activities that enhance their confidence and skills, and
encouraged to participate according to their abilities.
Although systemic advocacy agencies will not directly support people with
disability to develop skills to enhance their valued status in the community, the
systemic actions pursued by the agency should, where appropriate, aim to
enhance the valued status of people with disability.
In the case of citizen advocacy, it is recognised that decisions about the
advocacy activities undertaken made by the citizen advocate and person with
disability are outside the control of the agency.
61
Family advocacy agencies will not directly undertake advocacy activities with
the individual with disability but, where appropriate, will be able to demonstrate
that through supporting their family member, the person with disability’s valued
status is promoted.
In the context of Standard 6, it is recognised that ‘status’ and ‘value’ are
subjective terms and that people will have different understandings of what
constitutes valued roles and status, as will different cultures. Where applicable,
consideration should be given to what the person with disability accessing the
agency considers as valued status.
Things to consider – Valued status
All disability advocacy agencies

Our agency’s mission statement refers to supporting the valued status and
intrinsic value of people with disability

Our staff relate to consumers/ people with disability in a way that supports
their valued status

Staff/ volunteers do not demonstrate any of the following behaviours/
attitudes which can undermine valued status:
o disrespectful or patronising manner of speech to consumers/ people
with disability
o use of words that devalue a person’s adult status or draw attention to
the disability first , rather than the person
o lack of attention to the recognition people deserve

Our agency management, Board, staff and volunteers believe and know
that people with disability have the ability to fulfill valued roles in the
community

Our marketing and promotional material supports the valued status of
people with disability

We network within the community and/ or use community events to
promote valued status of people with disability
The following table contains some evidence examples that a disability advocacy
agency might consider using to show how they comply with Standard 6.
62
Disability Advocacy Standards, KPIs and Examples of Evidence 2012
Standard
KPI
Standard 6: Valued status
6.1
Through advocacy, the aspirations
and strengths of each person with
disability is promoted.
6.2
The advocacy agency promotes the
intrinsic value and the valued status
of each person with disability in all its
activities.
The intrinsic value of each
person with disability is
recognised and each
person is supported and
encouraged to enhance
their valued status in the
community.
Examples of Evidence
All agencies
 The valued status of people with disability is promoted in reports and
promotional material.
 Details of public speaking at conferences, lectures and professional
gatherings to promote a positive image of people with disabilities.
 Examples of issues raised or referrals made to systemic advocacy agencies
and/or other agencies and authorities.
 Examples of activities and issues that the agency engages in that supports
the valued status of people with a disability.
Agencies undertaking citizen advocacy


Examples of activities people with disability who receive advocacy support
and advocates are involved in that promote the intrinsic value and the valued
status of people with disability– while recognising that the citizen advocates
and the person with a disability make their own decisions outside of the
control of the funded agency.
Citizen advocacy orientation documentation includes information about
valued status and what this means in practice.
63
Standard 7: Complaints and disputes
Each person with disability, who has a complaint or dispute with the advocacy
agency, is encouraged to raise it, and have it resolved without threat of
retribution.
7.1
The advocacy agency informs each person with disability about how to
raise a complaint or initiate a dispute about any areas of dissatisfaction
with the advocacy agency, without threat of retribution.
7.2
The advocacy agency seeks to resolve complaints or disputes raised or
initiated by a person with disability, with access to both internal
complaints resolution mechanisms and external complaints resolution
mechanisms.
Policy and program context
All disability advocacy agencies are expected to:





Encourage the raising of complaints regarding any area of dissatisfaction
with the advocacy agency, without any fear of retribution;
Create an atmosphere whereby complaints are viewed proactively as an
opportunity for improvement;
Provide an accessible, accountable and transparent process for the
management of complaints;
Enable people with disability to access independent support as needed
throughout a complaints process; and
Ensure the satisfactory closure of the complaint through an open and
transparent process.
It is the responsibility of disability advocacy agencies to provide an accessible
and effective complaint process for people with disability, taking into
consideration that people with disability may feel less empowered to make a
complaint.
Disability advocacy agencies should have an internal complaint/ feedback
mechanism that provides:

Commitment at all levels of the agency to resolving the complaint at the
local level. This can be demonstrated through effective dissemination of
policies and procedures, that recognise the positive and important role of
complaints to increase the satisfaction of consumers/ people with disability,
and provide insights to continuously improve the agency

Fairness to all concerned, including the complainant, the agency and the
person complained about. This would include availability of support or
appropriate referral to another to provide support to ensure that the
complainant can make the complaint effectively and does not suffer
retribution or intimidation as a result
64

Accessible information about the process in a variety of appropriate
formats (including plain English and other languages where appropriate)
that is promoted both internally and externally. There should be flexible
methods of making complaints, with assistance available to complainants
as necessary. This element is particularly important, as people with
disability may not feel empowered to make a complaint

A responsive process, including full, impartial and timely investigation of all
aspects of the complaint and fair and reasonable remedies where
warranted

An effective mechanism that addresses individual complaints and uses
the information collected to improve overall delivery of advocacy and
address systemic and recurring problems.
The disability advocacy agency’s complaints/ feedback mechanism should be
reviewed regularly to ensure that it is meeting the needs of people with
disability. The system should also demonstrate:

Openness and accountability – so people with disability can judge for
themselves whether the system is working effectively

Privacy, dignity and confidentiality, as outlined in Standard 4

External referral where a complaint cannot be resolved by the internal
process. This may involve an alternative dispute resolution procedure such
as mediation, or referral to another appropriate avenue for resolving the
complaint, such as an appeal procedure or other legal remedy

Cooperation with external complaint resolution agencies where a person
with disability has approached such an agency, in the investigation of
complaints. External complaints mechanisms can include the Complaints
Resolution and Referral Agency (CRRS), the National Abuse and Neglect
Hotline, the Australian Human Rights Commission, the Privacy
Commissioner or other advocacy agencies. Disability advocacy agencies
are expected to refer people with disability to other advocacy agencies for
support during the complaints process, if this support is requested.
Things to consider – Complaints and disputes
All disability advocacy agencies

We have a clearly documented complaints policy and procedure

We have an escalation process if a complaint is not resolved in the first
instance (documented in our complaints procedure)

Our escalation process states how external referrals will be used, when
necessary
65

Our complaints process is made available and explained to people with
disability so that they understand their right to make a complaint and how
they can do this

We inform people with disability they can have a support person with them
during the complaints process and we assist them to access a support
person

We publicise the Complaints Resolution and Referral Service
(CRRS) in our office(s) and inform people with disability of the role of the
CRRS

We have a documented complaints handling register, which includes who is
handling the complaint, timeframe for resolution, the resolution and the
complainant’s satisfaction/ dissatisfaction

We review the complaints register regularly to ensure timeliness of, and
satisfaction with, complaints handling and resolution

We ensure that we do not breach confidentiality in the way that we handle
complaints

We have a procedure in place to appropriately deal with complaints that
involve a serious allegation or a potential crime

We use information (de-identified) from our complaints handling to inform
continuous improvement
The following table contains some evidence examples that an agency might
consider using to show how they comply with Standard 7.
66
Disability Advocacy Standards, KPIs and Examples of Evidence 2012
Standard
Standard 7: Complaints
and disputes
Each person with disability,
who has a complaint or
dispute with the advocacy
agency, is encouraged to
raise it, and have it
resolved without threat of
retribution.
KPI
Examples of Evidence
7.1
The advocacy agency informs each
person with disability about how to
raise a complaint or initiate a dispute
about any areas of dissatisfaction
with the advocacy agency, without
threat of retribution.
7.2
The advocacy agency seeks to
resolve complaints or disputes
raised or initiated by a person with
disability, with access to both
internal complaints resolution
mechanisms and external
complaints resolution mechanisms.
All agencies
 Documented complaints policy and procedures.
 Documented and implemented practices and policies for investigating and resolving
complaints – cover both internal and external complaints resolution mechanisms,
including the Complaints Resolution and Referral Service (CRRS).
 File review demonstrates that the agency completes complaints investigations in
accordance with its complaints procedures.
 People with disability who access the advocacy agency are provided with information
about the agency’s complaints policy and procedures.
 The agency reviews its complaints policy, procedures, processes and practices to
ensure implementation is appropriate to complainants.
 Service user feedback about the complaints mechanism.
 Complaints register.
67
Standard 8: Agency management
Each advocacy agency adopts quality management systems and practices that
optimise the effectiveness of advocacy for each person with disability and
facilitates continuous improvement.
8.1
The advocacy agency has clearly stated aims and objectives that
communicate to each person with disability and other relevant
stakeholders the scope and limitations of the advocacy agency.
8.2
The advocacy agency has governance and management systems in
place that facilitate quality management practices and continuous
improvement.
8.3
The advocacy agency operates independently and is structured in such a
way that it is as free as possible from conflicts with other service
provision and the interests of each person with disability.
Policy and program context
This Standard recognises that effective and efficient management of the
disability advocacy agency is essential for optimising the effectiveness of
advocacy for people with disability.
It is expected that disability advocacy agencies will have a positive
organisational culture and through strong and effective governance and robust
management be responsive to the needs of people with a disability, meet their
compliance and reporting obligations and embed a culture of continuous
improvement by implementing quality management systems.
The disability advocacy agency’s management system encompasses all the
things an agency does to establish the outcomes it wants to achieve and the
policies and procedures it uses to ensure these outcomes are attained.
However, the type and complexity of the management systems used by
agencies are expected to vary greatly, depending on the size of the
organisation and the models of advocacy undertaken. Clearly, a small rural
agency is not expected to have the same management system as a large multisite agency. In addition, where an agency is part of a larger organisation, it will
need to consider what management systems are needed at the local level and
how they link to management systems across the organisation as a whole.
Audit teams will take into account the relative size of agencies, and the budgets
and funding they have available to them.
In all cases, what is important is that every disability advocacy agency has a
management system that best enables it to optimise the effectiveness of
advocacy for people with disability. For all agencies, a quality management
system involves:

A clear organisational structure and corporate governance arrangements
that provide confidence for people with disability in the probity and
accountability for the management of the agency. These governance
68




arrangements should include skilled and qualified Board/management
members;
Processes for setting and working towards business priorities and outcomes
for people with disability (e.g. corporate or business planning processes);
Continuous improvement processes for identifying agency strengths and
weaknesses and working towards improvements;
Documented policies and procedures relevant to the Disability Advocacy
Standards; and
Internal controls to comply with relevant Standards and other legislation and
funding requirements.
Things to consider – Agency management
All disability advocacy agencies

We have clearly stated aims and objectives that are communicated to
stakeholders

We have a clear identification and understanding of the powers, roles,
responsibilities and accountabilities between the Board, the Chief Executive
Officer and management

Responsibilities are clearly communicated to key stakeholders

The Board has appropriate decision making processes. There is clear
distinction between what decisions should be made by the Board and those
decisions that should be made by our agency’s management

We have skilled and qualified Board and management members

We have a quality management system that facilitates quality management
practices and continuous improvement

We have processes governing policy development, implementation and
review, which involve input from stakeholders

We have written policies and associated processes which reflect relevant
legislation, standards, and funding requirements

We have a risk management plan that is supported by risk management
strategies and reviewed regularly

We have practices in place to ensure the agency is structured and operates
independently and is as free as possible from conflict with other service
provision and the interests of people with disability
The following table contains some evidence examples that an agency might
consider using to show how they comply with Standard 8.
69
Disability Advocacy Standards, KPIs and Examples of Evidence 2012
Standard
KPI
Standard 8: Agency
management
8.1
The advocacy agency has clearly
stated aims and objectives that
communicate to each person with
disability and other relevant
stakeholders the scope and
limitations of the agency.
8.2
The advocacy agency has
governance and management
systems in place that facilitate quality
management practices and
continuous improvement.
8.3
The advocacy agency operates
independently and is structured in
such a way that it is as free as
possible from conflicts with other
service provision and the interests of
each person with disability.
Each advocacy agency
adopts quality management
systems and practices that
optimise the effectiveness
of advocacy for each
person with disability and
facilitates continuous
improvement.
Examples of Evidence
All agencies
 Documented agency aims and objectives.
 Documented and implemented practices and policies for promotion and
communication of agency aims and objectives with people with disability who
receive advocacy support and stakeholders.
 Reviews of agency management systems involving service users (e.g.
people with disability who receive advocacy support, family members, citizen
advocates) – including documented annual self-assessments and
continuous improvement plans.
 Clear governance arrangements.
 Documented and implemented policies and practices for performance and
risk management are undertaken.
 Documented policy on agency independence.
 Agency management and staff can provide practical examples of how they
operate to ensure they are as free as possible from things that conflict with
the best interests of people with disability.
 Policies and procedures include referral to another agency if required to
prevent a conflict of interest.
 Evidence of the involvement of people with disability in the agency’s QA
activities.
 Minutes of management committee meetings.
 Documented roles and responsibilities of management committee office
bearers.
70
Standard 9: Staff, recruitment, employment and training
Each person who has an employment or volunteer relationship with the
advocacy agency has appropriate skills and competencies.
9.1
The advocacy agency ensures that its staff have relevant skills and
competencies.
9.2
The advocacy agency provides opportunities for the appropriate and
continuing training and skills development for each staff member.
Policy and program context
This Standard recognises that having staff with appropriate skills and
competencies, and providing opportunities for professional development,
training and organisational learning, are critical to achieving the best advocacy
outcomes for people with disability. Crucial to an effectively managed
organisation is a skilled workforce with the right values and attitudes. Having
staff without appropriate skills and competencies should be considered an
unacceptable management practice due to the vulnerable nature of people with
disability accessing disability advocacy agencies.
The staff of disability advocacy agencies require skills in areas such as
communication, respect and dignity, confidentiality, effective supports,
appropriate conduct, positive attitudes, behavioural support and responding to
individual needs. In agencies that are contracted to provide advocacy for people
with a specific type of disability, some specialist knowledge and skills may also
be required.
Disability advocacy agencies will need to identify and document the skills and
competencies needed for positions within the agency in role descriptions.
Established practices and policies for recruitment and induction should ensure
paid and unpaid staff have the necessary skills and competencies for their
position, including relevant qualifications (where appropriate). Agencies should
outline the methods for assessing these skills and competencies, and
addressing any gaps through staff training and/or recruitment.
The disability advocacy agency’s management should also have strategies to
support agency-wide learning that acknowledges the changing needs of the
agency and its staff and continues to develop responses to new challenges.
Recruitment practices should meet probity requirements and disability advocacy
agencies should be committed to training and equipping staff and unpaid staff to
meet the needs of the people they support and to maximise positive outcomes.
Planning for future workforce needs is essential.
In this Standard, ‘staff’ refers to both paid and unpaid staff of the agency.
However, in citizen advocacy and family advocacy, the advocates do not
have an employment relationship with the advocacy agency – for these models,
‘staff’ refers to staff of the advocacy agency employed either to support and
71
recruit volunteer citizen advocates or to support family members of people with
disability.
Things to consider – Staff, recruitment, employment and
training
All disability advocacy agencies

Our agency has detailed job descriptions for all roles, including
responsibilities

Job descriptions are maintained and updated as necessary

We have an induction process for all new staff/ volunteers and Board
members

We have processes in place to ensure staff/ volunteers understand the skill/
competency requirements of their job

We encourage appropriately skilled and qualified people with disability
(along with people from other disadvantaged groups) to apply for positions

We have clear policies and procedures regarding the roles, responsibilities
and treatment of volunteers. Volunteers are made aware of and understand
these

We ensure recruitment based on qualifications and skill, and the
competency requirements of the role

Conditions of employment are agreed and evidenced through a signed
Contract of Employment

We ensure our staff have the relevant skills and competencies

Staff and Board members’ performance is periodically reviewed

Staff have input regarding their own development and training needs

Staff are given opportunities to access appropriate training and
development activities to enable them to perform their work
The following table contains some evidence examples that an agency might
consider using to show how they comply with Standard 9.
72
Disability Advocacy Standards, KPIs and Examples of Evidence 2012
Standard
KPI
Examples of Evidence
Standard 9: Staff,
recruitment, employment
and training
9.1
The advocacy agency ensures that
its staff have relevant skills and
competencies.
Each person who has an
employment or volunteer
relationship with the
advocacy agency has
appropriate skills and
competencies.
9.2
The advocacy agency provides
opportunities for the appropriate and
continuing training and skills
development for each staff member.
All agencies
 Current list of all people who have an employment relationship with the
advocacy agency.
 Position descriptions of all paid and unpaid staff that describe skills and
competencies needed for their role.
 Documented and implemented practices and policies for recruitment &
induction that ensure paid and unpaid staff have the necessary skills and
competencies for their position, including relevant qualification (where
appropriate).
 Staff appraisals conducted at least annually.
 Training and development plans for all staff.
Agencies undertaking citizen advocacy
 Independent evaluations of practices for developing the capacity of citizen
advocates to assist people with disability meet their advocacy objectives.
 Regular opportunities for the staff and board of management to avail
themselves of Citizen Advocacy-related training, including participation in the
independent evaluation of other Citizen Advocacy agencies, as a means to
enhance conceptual and practical knowledge.
73
Standard 10: Protection of human rights and freedom from
abuse
The advocacy agency acts to prevent abuse and neglect and to uphold the legal and
human rights of each person with disability.
10.1 The advocacy agency takes all practical and appropriate steps to prevent abuse,
neglect and discrimination of each person with disability.
10.2 The advocacy agency upholds and promotes the legal and human rights of each
person with disability.
Policy and program context
Standard 10 requires disability advocacy agencies to uphold the legal and human rights
of people with disability. Agencies are expected to advocate to prevent abuse and
neglect and, where people with disability are supported on an individual basis, to
empower and support them to exercise their human rights.
Australia is party to a number of international agreements and conventions that require
the upholding of the basic legal and human rights of all Australians, including people
with disability. Australia ratified the United Nations Convention on the Rights of People
with Disabilities (CRPD) in July 2008 as part of a global effort to promote the equal and
active participation of people with disabilities.
The CRPD’s guiding principles on fairness and human rights include:





Respect for human dignity and freedom
Equality before the law
Privacy
Protection against discrimination
Equal opportunity in employment
Disability advocacy agencies are expected to be proactive in preventing abuse and
neglect of people with disability, where consistent with contractual obligations and the
purpose of the agency. In comparison with the general population, people with disability
are more likely to experience abuse and neglect. There are many forms of abuse,
including:



Physical, sexual, psychological or emotional abuse
Constraint and restrictive practices
Neglect and deprivation
Some forms of abuse may be intentional while others are more likely to result from
system failures or poor practice.
Every disability advocacy agency should have prevention strategies in place within their
own agency. Some considerations include:
74




The agency’s workplace culture supports valued attitudes
Staff have basic competencies/ skills in abuse prevention
Human resource planning, including monitoring indicators and risks related to
abuse occurs
Policy guidelines related to abuse prevention are developed
Although all disability advocacy agencies have a commitment to uphold the legal and
human rights of people with disability and endeavour to prevent abuse and neglect,
they will undertake different activities.
For agencies that undertake advocacy on an individual basis, a proactive strategy for
preventing abuse could involve proactive outreach to consumers who may be
vulnerable, isolated, or otherwise unlikely to access an advocacy agency.
Agencies undertaking legal advocacy, may pursue legal activities that uphold the legal
and human rights of people with disability.
Those agencies undertaking family advocacy will demonstrate how providing support
to family members of people with disability will uphold the rights of people with disability
and prevent abuse and neglect.
For agencies undertaking systemic advocacy, preventing abuse and neglect or
upholding the legal rights of people with disability will involve pursuing positive systemic
changes for people with disability.
The National Disability Abuse and Neglect Hotline was established for reporting
allegations of abuse and neglect against people with disability. Agencies are expected
to actively promote the existence of the Hotline to people with disability (see Section 7
for contact details of the Hotline).
Things to consider – Protection of human rights and freedom from
abuse
All disability advocacy agencies

We have clearly documented policies and procedures for preventing and
responding to abuse and neglect

Management, staff and volunteers have been informed of, and trained in, the policy
and procedures relevant to abuse and neglect

Our procedures reflect the best interests of the person alleged to have been
abused

Our documented reporting procedures include roles, responsibilities and
identification of when and how to report to the police or other relevant bodies
75

We provide/ make available appropriate support to alleged victims, families and
staff/ volunteers around allegations of abuse and neglect

We have an incident reporting process which includes:
o Nature of incident
o Names of people involved
o Outcomes
o Response to person making allegation
o Records which are dated and signed

Our register of incidents and complaints files are kept secure
The following table contains some evidence examples that an agency might consider
using to show how they comply with Standard 10.
76
Disability Advocacy Standards, KPIs and Examples of Evidence 2012
Standard
KPI
Standard 10: Protection
of human rights and
freedom from abuse
10.1
The advocacy agency takes all
practical and appropriate steps to
prevent abuse, neglect and
discrimination of each person with
disability.
10.2
The advocacy agency upholds and
promotes the legal and human rights
of each person with disability.
The advocacy agency acts
to prevent abuse and
neglect and to uphold the
legal and human rights of
each person with disability.
Examples of Evidence
All agencies
 Staff knowledge and skills in recognising and reporting criminal activities,
abuse and neglect.
 Evidence of staff knowledge/learning about human and legal rights.
 Agency management and staff can provide practical examples of how they
act to prevent abuse and neglect – (e.g. an outreach program which seeks
out people with disability who are abused or neglected and who would not
normally come to the attention of other agencies; community education to
raise awareness about abuse of people with disabilities and strategies to
prevent and respond to it, etc.).
 Documented and implemented policies and procedures around responding
to/reporting in situations of abuse and neglect. Examples could include a
flow chart on who to notify and/or stages of reporting sequence/steps.
 Documented and implemented policies and procedures reflect prevention of
abuse that could occur internal to the agency and external to the agency.
 Evidence of advocacy agency activities to promote and uphold the legal and
human rights of people with disabilities on either an individual or systemic
basis.
Agencies undertaking citizen advocacy
 Practice of recruiting advocates for people with a disability who are isolated
and otherwise vulnerable, in order to ensure their protection of human rights
and freedom from abuse, consistent with the mission of Citizen Advocacy.
 Content and practice of orientating advocates to their role in ensuring the
protection of the human rights, and prevention from abuse, of peoples with a
disability.
 Practice of supporting advocates in their role of ensuring the protection of
the human rights, and prevention from abuse, of people with a disability.
77
4.2 Self-assessments
Self-assessments are a key part of the NDAP QA system. Self-assessment is the
opportunity for your disability advocacy agency to assess how your quality
management system (including your policies, procedures, practices) meets the
requirements of the Disability Advocacy Standards. Self-assessments are an ideal
platform from which to then plan continuous improvement activities.
As part of the initial certification process, the Certification Body will use this information
to decide whether to proceed with a certification audit (refer Section 3).
The self-assessment process is of great value in implementing a quality management
philosophy and creating an internal culture which encourages excellence. Principles of
quality management suggest that high levels of participation lead to the establishment
of a more sustainable quality system through increased staff commitment and
‘ownership’ of any planned changes. There should be input from governance,
management, staff, people with disability and other relevant stakeholders. Note: input
from people with disability is not mandatory in NDAP self-assessments, though is
highly recommended as a measure of how people with disability participate in agency
decision making (Standard 3), and agency management (Standard 8). The Easy Read
and Standard Read NDAP QA information for people with disability, provided on the
FaHCSIA website will be useful for this process.
What methods can be used to do the self-assessment?
There is no set formula for conducting self-assessments, as it will vary in part due to
the size and type of the advocacy agency. Some useful methods include:

Feedback from staff, people with disability, relevant stakeholders – either through
interviews, or a survey;

A review of policies and procedures;

Workshops to discuss where your agency is working well and where there are gaps
in systems;

Staff meetings discussing the self-assessment as a training/staff development
exercise.
To assess current performance, you could use the compliance/non-compliance rating
scale consistent with audit assessments:

Rating of 0: Major nonconformity – that means that you have not met the
requirements of a KPI, or the outcomes are ineffective.

Rating of 1: Nonconformity – this means that you have not fully met the
requirements of a KPI or the outcomes are only partially effective. Several related
nonconformities may also constitute a major nonconformity.

Rating of 2: Conformity – this means you have met the requirements of a KPI.
78
HINT: What is the difference between self-assessment and internal audit?
Self-assessment and internal audit are not synonymous. Self-assessments check the
extent to which documents in the management system meet the requirements of the
Disability Advocacy Standards. Internal Audits do this, as well as check to see if those
procedures are implemented and followed.
The NDAP QA certification process does not specifically require disability advocacy
agencies to have an internal audit process. However, internal audits are an important
tool in ensuring an effective quality management system, and are highly recommended
to check that procedures are in place and are being followed (see Section 5, Standard
8, for more information). It would be desirable (though not mandatory) for agencies to
aim to implement an internal audit process by the end of the first three year certification
cycle.
HINT: Can peer assessments be used in place of self-assessments?
An increasing number of NDAP agencies are now undertaking peer assessments
against the Disability Advocacy Standards as part of their continuous improvement
processes. JAS-ANZ Procedure 29 provides that the results of peer assessments can
be used in place of self-assessments. Where this occurs, it would be desirable for your
agency to also have in place its own internal audit process to provide a backup of
internal controls.
HINT: What format does NDAP disability advocacy agencies need to use for
completion of the self-assessment?
A template is provided (see next page) however this template is not mandatory. It is
mandatory that self-assessment is against the Disability Advocacy Standards.
The National Association of Community Legal Centre’s QA process provides an on-line
self-assessment process (which maps relevant Standards to evidence against other
related Standards). It is understood that the Disability Advocacy Standards will be
integrated into this system by the NACLC during 2012. If NDAP agencies wish to
utilise this system, the outcomes of the self-assessment process should be made
available to the Certification Body for consideration during the Stage 1 audit.
79
4.3 Self-Assessment Worksheets
Self-Assessment Worksheet – Disability Advocacy Standards
Date of Self-Assessment:
Name of Disability Advocacy Agency:
Standard 1: Accessing advocacy
Each person with disability has opportunities to access advocacy on the basis of relative need and available resources.
KPI
Key Performance Indicator
1.1
The advocacy agency adopts, applies and
promotes non-discriminatory policies in
respect of age, gender, race, culture,
religion, disability or living arrangements,
consistent with the contractual obligations
and purpose of the advocacy agency and
the relative need and available resources.
1.2
The advocacy agency has processes to
determine how the individuals or issues
supported are chosen and prioritised based
on relative need and available resources.
1.3
Each person with disability is informed
about how decisions are made in relation to
access and advocacy issues.
Assessment
of current
performance
(rating = 0, 1
or 2)
Examples of Evidence
Improvement action
80
Self-Assessment Worksheet – Disability Advocacy Standards
Date of Self-Assessment:
Name of Disability Advocacy Agency:
Standard 2: Individual needs
Each person with disability receives advocacy that is designed to meet their individual needs and interests.
KPI
Key Performance Indicator
2.1
The advocacy agency has a process for determining and
documenting the advocacy objectives that reflect the wishes, needs
or interests of each person with disability.
2.2
Advocacy activities are directed to meeting the advocacy objectives
of each person with disability.
2.3
Each person with disability engaged in determining advocacy
objectives is provided with opportunities to involve a support person
of their choice.
2.4
In meeting the needs of a person with disability, the advocacy
agency avoids, where possible, any conflict of interest or the
perception of any conflict in relation to the conduct of its advocacy
work, and deals with any conflict or perceived conflict transparently.
2.5
The advocacy agency helps to empower people to advocate for
themselves or their family or others with appropriate strategies (e.g.
information, training, mentoring, support).
Assessment of current
performance
(rating = 0, 1 or 2)
Examples of
Evidence
Improvement action
81
Self-Assessment Worksheet – Disability Advocacy Standards
Date of Self-Assessment:
Name of Disability Advocacy Agency:
Standard 3: Decision making and choice
Each person with disability has the opportunity to participate as fully as possible in making decisions about the advocacy activities undertaken.
KPI
Key Performance Indicator
3.1
The advocacy agency’s policies support
each person with disability to direct, within
the limits of their capacity or interest, the
advocacy activities undertaken to meet
their advocacy objectives.
3.2
In all circumstances the advocacy activity
is informed by ethical guidelines.
Assessment
of current
performance
(rating = 0, 1
or 2)
Examples of Evidence
Improvement action
82
Self-Assessment Worksheet – Disability Advocacy Standards
Date of Self-Assessment:
Name of Disability Advocacy Agency:
Standard 4: Privacy, dignity and confidentiality
The right of each person with disability to privacy, dignity and confidentiality is recognised and respected.
KPI
Key Performance Indicator
4.1
The advocacy agency complies with the
Information Privacy Principles of the Privacy
Act 1988 in order to protect and respect the
rights of each person with disability.
4.2
The advocacy agency promotes privacy, dignity
and respect for each person with disability.
Assessment
of current
performance
(rating = 0, 1
or 2)
Examples of Evidence
Improvement action
83
Self-Assessment Worksheet – Disability Advocacy Standards
Date of Self-Assessment:
Name of Disability Advocacy Agency:
Standard 5: Participation and integration
Each person with disability is supported and encouraged to participate and be involved in the community.
KPI
Key Performance Indicator
5.1
Through advocacy, opportunities for
participation and involvement in the community
are promoted.
5.2
Where appropriate, the advocacy agency takes
action to introduce, influence or produce
positive systemic change in the community.
Assessment
of current
performance
(rating = 0, 1
or 2)
Examples of Evidence
Improvement action
84
Self-Assessment Worksheet – Disability Advocacy Standards
Date of Self-Assessment:
Name of Disability Advocacy Agency:
Standard 6: Valued status
The intrinsic value of each person with disability is recognised and each person is supported and encouraged to enhance their valued status in the community.
KPI
Key Performance Indicator
6.1
Through advocacy, the aspirations and
strengths of each person with disability is
promoted.
6.2
The advocacy agency promotes the
intrinsic value and the valued status of each
person with disability in all its activities.
Assessment
of current
performance
(rating = 0, 1
or 2)
Examples of Evidence
Improvement action
85
Self-Assessment Worksheet – Disability Advocacy Standards
Date of Self-Assessment:
Name of Disability Advocacy Agency:
Standard 7: Complaints and disputes
Each person with disability, who has a complaint or dispute with the advocacy agency, is encouraged to raise it, and have it resolved without threat of retribution.
KPI
Key Performance Indicator
7.1
The advocacy agency informs each person
with disability about how to raise a complaint
or initiate a dispute about any areas of
dissatisfaction with the advocacy agency,
without threat of retribution.
7.2
The advocacy agency seeks to resolve
complaints or disputes raised or initiated by
a person with disability, with access to both
internal complaints resolution mechanisms
and external complaints resolution
mechanisms.
Assessment
of current
performance
(rating = 0, 1
or 2)
Examples of Evidence
Improvement action
86
Self-Assessment Worksheet – Disability Advocacy Standards
Date of Self-Assessment:
Name of Disability Advocacy Agency:
Standard 8: Agency management
Each advocacy agency adopts quality management systems and practices that optimise the effectiveness of advocacy for each person with disability and facilitates continuous
improvement.
KPI
Key Performance Indicator
8.1
The advocacy agency has clearly stated aims
and objectives that communicate to each
person with disability and other relevant
stakeholders the scope and limitations of the
advocacy agency.
8.2
The advocacy agency has governance and
management systems in place that facilitate
quality management practices and continuous
improvement.
8.3
The advocacy agency operates independently
and is structured in such a way that it is as free
as possible from conflicts with other service
provision and the interests of each person with
disability.
Assessment
of current
performance
(rating = 0, 1
or 2)
Examples of Evidence
Improvement action
87
Self-Assessment Worksheet – Disability Advocacy Standards
Date of Self-Assessment:
Name of Disability Advocacy Agency:
Standard 9: Staff, recruitment, employment and training
Each person who has an employment or volunteer relationship with the advocacy agency has appropriate skills and competencies.
KPI
Key Performance Indicator
9.1
The advocacy agency ensures that its staff
have relevant skills and competencies.
9.2
The advocacy agency provides opportunities
for the appropriate and continuing training
and skills development for each staff
member.
Assessment
of current
performance
(rating = 0, 1
or 2)
Examples of Evidence
Improvement action
88
Self-Assessment Worksheet – Disability Advocacy Standards
Date of Self-Assessment:
Name of Disability Advocacy Agency:
Standard 10: Protection of human rights and freedom from abuse
The advocacy agency acts to prevent abuse and neglect and to uphold the legal and human rights of each person with disability.
KPI
Key Performance Indicator
10.1
The advocacy agency takes all practical and
appropriate steps to prevent abuse, neglect
and discrimination of each person with
disability.
10.2
The advocacy agency upholds and promotes
the legal and human rights of each person
with disability.
Assessment
of current
performance
(rating = 0, 1
or 2)
Examples of Evidence
Improvement action
89
Section 5:
Continuous Improvement
Continuous improvement is an integral component of the NDAP Quality Strategy and
the associated QA system of certification.
Continuous improvement allows disability advocacy agencies to constantly review
performance against the Disability Advocacy Standards and plan ongoing
improvements.
To be certified and receive Australian Government funding, your disability advocacy
agency must be able to demonstrate the quality of your continuous improvement
processes and outcomes. As part of your certification audit, an independent
Certification Body assesses your continuous improvement processes and outcomes
against Disability Advocacy Standard 8 (Agency management).
However, the real value of continuous improvement as part of the overall quality
system is to create stronger, more sustainable support that better meets the
advocacy needs of people with disability.
A quality improvement culture helps disability advocacy agencies accommodate
changes, such as government reforms, variations in the economy and the needs of
consumers, and continually develop a high quality agency to meet the needs of
people with disability.
Quality agencies are agencies which generally show:







Strong customer focus;
Clear direction and accountability;
Continuous learning and innovation;
Valuing people and diversity;
Collaborative work practices;
Evidence based decision making
Social and ethical responsibility. 5
The intent of continuous improvement is to lay solid foundations to underpin agency
delivery outputs, outcomes and impacts – that is, to:



Improve efficiency (to do things right)
Improve effectiveness (to do the right thing)
Improve consumer outcomes/outcomes for people with disability.
6
Continuous improvement operates at both an individual agency level and a sector
level. Ideally, improvement actions at the two levels are related so that information
5
South Australian Department of Families and Communities, Benefits of a Quality System, Service Excellence Program:
http://www.dfc.sa.gov.au/pub/tabid/267/itemid/755/Benefits-of-a-Qualty-System.aspx
Disability Service Queensland, Introduction to Quality Management: https://www.disabiltiy.qld.gov.au/keyprojects/quality/documents/section-26
90
about successful innovations is shared across the sector, and areas of need are
identified so that training and support can be provided.
Effective continuous improvement is integrated into the day-to-day life of
organisations. It should be part of your disability advocacy agency’s core functions.
Implementing quality improvement processes has a range of benefits for consumers,
staff, Board and other stakeholders.
How your disability advocacy agency can continually improve
This section contains information about how your agency can continually improve
against the Disability Advocacy Standards. The information is practically based and is
intended to be referred to in conjunction with your certification progress. The selfassessment process is an ideal place to review your agency’s performance and
further your improvement opportunities.
How to use information in this section
Each Disability Advocacy Standard is provided with a range of resources, including:



Sample policies, procedures, templates and tools;
Case studies;
Links to other resources.
These resources will support you in planning quality improvement actions arising
from your self-assessment, and as part of ongoing continuous improvement activities.
The resources are not prescriptive, and you can adapt them based on your disability
advocacy agency’s purpose and practices. Your agency is not expected to adopt all
policies or practices or use all resources provided. Some of the resources will be
relevant to all agencies, while others will only apply to particular models of advocacy.
The sections are numbered as per the sequencing of the Disability Advocacy
Standards, however, it is not essential to work through them in this order. The results
of your self-assessment will identify those Standards and KPIs that require
improvement actions, and you may wish to refer directly to those sections. Another
useful option is to commence with Standard 8: Agency management. This
Standard is about the overall management system of disability advocacy agencies,
and it connects all of the other Disability Advocacy Standards. Experience of other
QA systems has shown that conformance with Standard 8 requirements is essential
for overall conformity with the other Standards.
DISCLAIMER: This section contains ideas and practice related to the Disability
Advocacy Standards which have been used by disability advocacy agencies,
disability services, and a range of government and non-government organisations.
The resources are not intended to be prescriptive, but may help you think of ideas to
improve the quality of advocacy support within your agency. Using these resources
does not guarantee certification. The resources also need to be considered in the
context of compliance with relevant Commonwealth and State/Territory legislation.
91
5.1 Sample policies, procedures, templates and tools
Standard 1:
Accessing advocacy
1.1 Sample policies and procedures
Sample Policy: Entry, Non-Discrimination, Referral, Exit and Accessibility7
Entry criteria
The definition of disability as per the Disability Discrimination Act 1992, is:
(a) total or partial loss of a person’s bodily or mental functions; or
(b) total or partial loss of a part of the body; or
(c) the presence in the body of organisms causing disease or illness; or
(d) the presence in the body of organisms capable of causing disease or illness; or
(e) the malfunction, malformation or disfigurement of a part of the person’s body; or
(f) a disorder or malfunction that results in the person learning differently from a
person without the disorder or malfunction; or
(g) a disorder, illness or disease that affects a person’s thought processes,
perception of reality, emotions or judgment or that results in disturbed behaviour;
and includes a disability that:
(h) presently exists; or
(i) previously existed but no longer exists; or
(j) may exist in the future; or
(k) is imputed to a person.
Consistent with the contractual obligations and purpose of the agency, our agency
will advocate for people with disability as defined above, as well as for the families
and carers of those people (note that in the case of systemic and family advocacy
agencies, people with disability are not consumers of the agency).
All consumers of our agency must also live, work, or have close links to [insert
region/ area].
Non-discrimination policy
When deciding on eligibility for entry into our agency, we will adopt, apply and
promote non-discriminatory entry rules in respect of age, gender, race, culture,
religion or disability, consistent with the contractual obligations and purpose of our
agency.
Where people with disability are not consumers of the advocacy agency, the
mechanisms for involving people with disability with our agency are nondiscriminatory in respect of age, gender, race, culture, religion or disability, consistent
with the contractual obligations and purpose of our agency.
7
National Disability Advocacy Program Quality Improvement Toolkit 2009 FaHCSIA
92
Entry procedure
Where people with disability and/or the carers and family of people with disability are
consumers of the advocacy agency, our agency will assess the eligibility of
consumers who:
 Contact our agency directly;
 Are referred to our agency;
 Are identified through any recruitment and promotional activities of our agency.
To ensure that our agency addresses the needs of Culturally and Linguistically
Diverse (CALD) and Indigenous consumers at the point of entry, our agency will:
 Ensure that appropriate translating or interpreting services are provided, if
required, to assist the consumer during the assessment of eligibility and entry
process;
 Ensure that any recruitment or promotional activities of our agency are targeted so
as to be accessible to those of CALD or Indigenous background. This may include
the provision of information in languages other than English, particularly for
languages spoken widely in the catchment area. Where possible, our agency will
periodically compare consumer data with available demographic data for the
catchment area to assess whether the needs of minority groups are being met by
our agency.
Once entry eligibility has been established, our agency will:




Describe to the person what our agency does and how advocacy will be
undertaken;
Describe to the person any relevant specific agency or program information, and
provide written material relating to relevant specific advocacy activities or
programs;
Discuss our agency’s privacy, dignity and confidentiality policy; and
Provide a consent form for signing if appropriate.
If resources are currently unavailable, our agency will:




Offer a place on the waiting list
Inform the person of the approximate waiting period
Place the person on the mailing list for the newsletters and other relevant
information
Provide interim information and/or referral, as appropriate.
If the person is not eligible, our agency will:




Provide the person with the reason
Document the reason
Provide information and/or referral as appropriate
Provide information about complaints and disputes.
Priority of advocacy provision
Where people with disability and/or their families and carers are consumers of the
advocacy agency, when our agency assesses applications, priority will be given to
the following:


The actual or potential seriousness of the problem the person or group is facing
The lack of alternative assistance to resolve the problem
93

The probability of successful outcome for the person in relation to: (a) our
agency’s limited resources and (b) other high priority advocacy matters.
Highest priority will be given to advocacy requests where there is an urgent and
serious risk of harm – including physical or psychological harm to the individual and
exposure to a harmful situation, such as jail or homelessness.
Our agency will also take into account ethical issues, especially potential conflicts of
interest.
Where people with disability are consumers of the advocacy agency, when our
agency assesses applications, priority will also be given to the seriousness of the
person's disability in terms of the way it affects his or her ability to deal with the
problem they are facing.
Referral
Where people with disability and/or their families and carers are consumers of the
advocacy agency and our agency is unable to accommodate a potential consumer, it
will arrange for a referral.
Our agency will develop and maintain up-to-date networks and information with a
comprehensive range of agencies and services within the region to ensure
appropriate referrals can be made (note where the agency is located in a regional
area the potential for referral may be limited).
When making a referral, our agency will:







Provide the person with information to facilitate informed choice and decision
making regarding referrals
Provide collaboration and seek permission before referral is made
(when possible) contact the referral agency with the person present
(if this is not possible) provide a referral form including full contact details,
including a contact name
Provide a privacy, dignity and confidentiality form for signing, if appropriate
support referrals if necessary
Note all referrals on the person’s file.
Consumer exits
Where people with disability and/or their families and carers are consumers of the
advocacy agency, consumer exits will occur:



At any time when the consumer makes an informed decision that they will no
longer continue to require advocacy; or
When the problem/ issue for which advocacy was sought has been resolved; or
When our agency can no longer assist the consumer, because:
o The consumer displays unsafe or unacceptable behaviour and all steps have
been taken to address the effects of this behaviour
o Our agency reasonably believes that our agency, in its capacity to advocate
for other consumers, or the consumer, will be negatively impacted if the
advocacy is pursued
o Due to changes in the consumer’s mental capacity they are no longer able to
instruct our agency
o All reasonable avenues of complaint and appeal in relation to the advocacy
matter are exhausted and further effort is futile or unwarranted on the
94

evidence available.
When the consumer or advocate is moving to another area.
Where a consumer is moving to another area, our agency will investigate referral
options on behalf of the consumer.
Accessibility of information on our advocacy agency
Our agency will ensure that written and audio materials about our activities (and
eligibility and entry requirements, where people with disability and/ or their families or
carers are consumers of the advocacy agency) are available to people with disability,
their families and carers.
These materials will be:

Written in a style that will be easily comprehensible for people with disability, for
example, plain English

Provided for Culturally and Linguistically Diverse (CALD) populations. The
agency will use available demographic information to assess which CALD
population groups should be targeted.
Sample procedure: Steps in the Enquiry Process8
1. Enquiry 
Initial contact for information, referral and/or advocacy

Complete (yellow) Advocacy Enquiry Form and forward to Coordinator. The
provision of the information is voluntary, but if this information is not provided,
Rights In Action Inc. may be unable to process the enquiry.

Coordinator identifies immediate action required and/or refers to regular
“Status Review Meeting”.

Forward to Administration to register on consumer database, send an “Initial
Advocacy” letter (if applicable) and file.
2. Request for advocacy

Discuss at “Status Review Meeting”.

Prioritise based on vulnerability.

Nominate an Advocate to address the follow up action. This may include:
arranging an initial meeting to identify the advocacy issue, refer to another
service, provide information to support self advocacy, notify the individual they
have been placed on a waiting list or arrange an appointment to commence
advocacy effort.
 If declined  document reason, notify and file accordingly
See following pages for Rights In Action Inc’s Advocacy enquiry flowchart and
spectrum of vulnerability.
8
Rights in Action Inc
95
96
SPECTRUM OF VULNERABILITY
HIGH
 Risk of Suicide
 No Income
 No Food
 Homeless
MEDIUM
 Risk of
Institutionalisation
LOW

Poor Literacy
and Numeracy
 No Natural Support 
System (Family, Friends)
No Valid
Activities/
Lifestyle (Social/
 Abusive
Situation
 Impaired capacity/
Decision making
Difficulties (may have or 
 Living in
Segregated
Setting (Nursing
 Communication
Difficulties (Sensory/
Home/ Hospital/
Institution/ Supported
Accommodation)
 Indigenous or
CALD
need Adult Guardian/ Public
Trustee)
Cogitative/ Speech
Impairment)

Recreational/
vocational)
Unemployed &
looking for work
Poor Social
Setting (Live in
Caravan Park /
Boarding house)
 Rural and Remote
 Mobility Impairment
 Aging or Young
Carers
 Justice/ Health
order (treatment order,
parole/ probation)
 Requiring Personal
Support (lack of support/
funding)
97
1.2 Sample templates
Template: Assessment Information Checklist9
Giving this checklist of information to consumers at the time of initial
assessment is one way that you can demonstrate the information you provide.
Asking the consumer to sign the form verifies they received the information.
You can adapt the checklist based on your agency’s practices or the type of
advocacy you provide.
I have explained the following information to: ………………………..Date: ………
Signed by assessment officer: …………………………….………………………….
1. Eligibility criteria for entry to our agency, and procedures for
prioritising access
Yes/No
2. Consumer’s right to access a support person of their choice
to assist them when entering or exiting our agency, and in
developing their personalised plan
Yes/No
3. How our agency works with the consumer to develop a
personalised plan to assist them to achieve their goals, and
in what format the copy of the plan will be provided
Yes/No
4. What support will be provided, what support will not be
provided, how the support will be delivered, and how
frequently the personalised plan will be reviewed
Yes/No
5. Procedures for minimising risks to the consumer without
unduly limiting their choices
Yes/No
6. The consumer’s rights in relation to privacy and confidentiality
of personal information, and how they may access information
held about them
Yes/No
7. Procedures for release of personal information to another party
and the requirement for informed consent
Yes/No
8. The processes for raising a complaint or concern, and our
agency’s policies for resolving issues causing dissatisfaction
Yes/No
9. How the consumer can participate in decision-making
processes to assist our agency to improve
Yes/No
9
Resource adapted from Disability Services Queensland, Introduction to Quality Management:
https://www.disability.qld.gov.au/key-products/quality/docuents/section-2-intro.pdf
98
Template: Referrals Register10
You can use a document register, like the example provided below, to provide evidence of the consistency and fairness of your entry
and exit procedures, decisions on relative need, non-discriminatory access, and referrals made to alternative agencies/ services. You
may want to adapt this format based on your agency’s practice.
Date
Consumer name/
of
contact details
referral
Nominated support
person contact details
Date of
assessment
Priority
entry
rating
Date
of
entry
Referrals made
Outcome of
referrals
10
Adapted from Disability Services Queensland , Introduction to Quality Management:
https://www.disability.qld.gov.au/key-products/quality/docuents/section-2-intro.pdf
99
1.3 Tools
Tool: Information for consumers on entry and exit policy and procedures11
Entry to the service
GDAI provides an individual advocacy service to people with disability, as well
as carers and family members of people with disability.
When you ask for a service from the GDAI we will:

Do all we can to make you feel welcome and treat you with dignity and
respect at all times

Clearly explain to you the details of the individual advocacy service and
advise you on what the GDAI can offer you

Deliver an individual advocacy service to you in a way that best empowers
you.

Prepare an individual advocacy plan with your input

Ensure that all people seeking an advocacy service will be treated fairly.
However, when a number of requests are received at the same time priority
will be given to those deemed to be at risk or in the most need.
Exiting the service
The service will cease

When you no longer need the service

The problem has been resolved

You agree that after discussing all available options with your advocate that
the outcome you want is not realistically achievable

When GDAI has referred you on to a more appropriate service that is better
equipped to assist you and you do not need or want your progress
monitored by GDAI.
Your individual advocacy plan can be destroyed at your request when you no
longer require an advocacy service from GDAI.
11
Extract from Gippsland Disability Advocacy Client Information Handbook (Plain English)
100
Tool: Checklist for culturally competent disability advocacy access12
Culturally competent disability advocacy support
Things to consider for accessing advocacy:
Do we provide information about our services in formats that are
accessible to all identifiable groups within our service area?
For example, do we provide, promote and distribute material in
languages other than English, or in audio formats?
Do we have established practices that give equity of access to people
with disability from a CALD or Indigenous background? What evidence
of this could we gather?
Do our intake processes take note of special requirements relating to a
person’s culture, language or religion?
Are all new consumers provided with important information about user
rights and responsibilities in a manner that is appropriate to their
needs?
For example, is information provided via an interpreter and in written
and/or audio format in the consumer’s preferred language?
Things to consider for service exit:
Do our exit policies ensure that people from a CALD or Indigenous
background are fully aware of available options for their future needs?
Do we have an established referral policy that informs the referral
agency of any cultural and linguistic factors that they will need to
consider in meeting the consumer’s needs?
Do we liaise and network with ethnic or Indigenous organisations
services that may help someone who is exiting our service make the
transition to another agency?
12
Adapted from MDAA document, Building Cultural Competency in the Disability Services, 2003 NSW:
https://www.mdaa.org.au
101
Standard 2:
Individual needs
2.1 Sample policies and procedures
Sample Policy: Individual Needs for Disability Advocacy13
Where people with disability are the consumers of the advocacy agency, when
a consumer enters our agency, our agency will create an individual profile
tailored to the needs of that consumer. The individual profile will:
 Include any relevant details of the consumer’s personal history, as well as
details of age, sex, and cultural, linguistic and religious backgrounds. The
agency will ensure that the consumer is treated appropriately according to
any cultural or linguistic needs identified in this process
 Identify the goals and needs of the consumer
 Where relevant and appropriate, work with the family, carers and friends of
the consumer to identify the consumer’s needs.
The individual profile will be periodically reviewed by our agency in consultation
with the person with disability to take account of their changing circumstances
and needs.
Our agency will, as much as possible, take into account the specific needs and
issues identified in the consumer profile when providing planning and
undertaking advocacy with and on behalf of the consumer.
Where people with disability are not the agency’s consumers (systemic and
family advocacy), in planning and undertaking advocacy, our agency will consult
people with disability to identify their needs. This will be on an individual or
collective basis, as appropriate to the advocacy approach.
Supporting individual needs
Where people with disability are the consumers of the advocacy agency, the
advocacy process will be:
 Sensitive to each consumer's age, sex, cultural and religious background
 As much as possible, planned around the preferred advocacy objectives of
the consumer.
Our agency will:
 Inform consumers about how their needs will be met
 Where possible, inform consumers of timeframes for actions undertaken with
and on their behalf
 Use the information from the individual profile to appropriately match
advocates to consumers.
13
National Disability Advocacy Program Quality Improvement Toolkit, FaHCSIA, 2009
102
Our agency will ensure that Culturally and Linguistically Diverse (CALD) and
Indigenous consumers are provided with culturally appropriate services and are
adequately supported through the advocacy process.
Where people with disability are not the agency’s consumers (systemic and
family advocacy), our agency will aim to undertake advocacy activities to reflect
and supports their needs.
103
2.2 Sample templates
Tool: Personalised Plan Format14
Where people with disability are the direct consumers of your agency, it is likely you will develop and document individual plans for
each consumer. Recently established agencies may find this sample template useful as a starting point for developing your agency’s
individual plan formats.
Individual Program Plan for__________________________________________________________________________
For the period_______________________________________________________________________
__________
Agency name:
Support worker:
Nominated advocate/ support person:
Plan developed in consultation with:
Review date for individual program plan:
Plan authorised by: _____________________________
(Signature of consumer/ nominated support person)
Copy of plan provided to consumer/ support person:
Preferred format: _______________________________
(enter date)
Identified skills/ knowledge/ attributes:__________________________________________________________________
Health and wellbeing needs:_________________________________________________________________________
Behavioural support needs:__________________________________________________________________________
Physical support needs/ aids:_________________________________________________________________________
14
Adapted from Disability Services Queensland, Introduction to Quality Management:
https://www.disability.qld.gov.au/key8-projects/quality/documents/section-2-intro.pdf
104
Psycho-social support needs:________________________________________________________________________
Communication needs:______________________________________________________________________________
Cultural needs:____________________________________________________________________________________
Who will provide the required support:
For what length of time:___________________________
At what time:
Under what conditions:___________________________
What risks are involved in implementing the plan:_________________________________________________________
How will risks be managed___________________________________________________________________________
Consumer’s vision statement:________________________________________________________________________
Long-term goals:
1._______________________________________________________________________________________________
2.______________________________________________________________________________________________
3.______________________________________________________________________________________________
Short-term goals:
1.1
1.2___________________________________________
2.1
2.2___________________________________________
3.1
3.2___________________________________________
4.1
4.2___________________________________________
105
RESPONSES: Our agency will address progression towards achieving these goals in the following manner:
Long-term goals:
1. Measuring device:____________________________________________________________________________________
2. Measuring device:____________________________________________________________________________________
3. Measuring device: ___________________________________________________________________________________
4. Measuring device: ___________________________________________________________________________________
5.
Program content details for: ___________________________________________________________________________
6.
Date/s: _____________________________Days:_____________________
Date
Action
Review date
Date for next review:
106
Tool: Personalised Plan Review Schedule15
To continue to meet the needs of people with disability, where they are the consumers of your agency, you will need to regularly
review consumers’ individual plans. Your staff or volunteer advocates may want to use a document similar to the template below to
record the planned schedule for review of individual plans for the consumers who he/she is supporting.
Consumer’s name
Date of last plan
review
Date next quarterly
review due
Appointment made
with consumer
Goal attainment
reviewed and new
activities planned
15
Adapted from Disability Services Queensland, Introduction to Quality Management:
https://www.disability.qld.gov.au/key8-projects/quality/documents/section-2-intro.pdf
107
Standard 3:
Decision making and choice
3.1 Sample policies and procedures
Sample Policy: Decision Making and Choice for Disability Advocacy16
Our agency will ensure that people with disability are provided with the
opportunity and the necessary support to participate as fully as possible in
making decisions about steps in the advocacy process and in the way in which
our agency operates.
Our agency will encourage and support people with disability to make informed
choices about advocacy activities our agency pursues with and on their behalf.
However, in some circumstances, this must be balanced against our agency’s
responsibility not to act on decisions by a person/ people with disability that
might pose a significant and foreseeable risk to their safety or interests, our
agency’s ability to assist other people with disability and the safety of our
agency’s staff and volunteers.
People with disability – decision-making about advocacy
Our agency will respect and promote the right of people with disability to selfdetermination and assist them to identify and clarify their needs and goals – this
may be on an individual or collective basis, based on our agency’s approach to
advocacy.
Where people with disability are the consumers of the advocacy agency, our
agency will work with the individual consumer to ensure informed decisionmaking and, where possible and appropriate, act upon the consumer’s choices.
Where people with disability are not the consumers of the advocacy agency,
effort will be made to discuss advocacy activities with the relevant person/
people with disability prior to deciding on and undertaking the advocacy
activities. Where this is not possible, for example, we will endeavour to inform
people with disability of actions being undertaken.
Agencies may limit a person/ people with disabilities right to self-determination
when, in their judgment, the person’s actions or potential actions pose a
serious, foreseeable, and imminent risk to themselves or others.
Informed consent
Where people with disability are the consumers of the agency, advocacy will be
provided to consumers only in the context of valid informed consent, where this
is possible. Our agency will use clear and understandable language to inform
consumers of the purpose of the advocacy activities, risks related to the
16
(National Disability Advocacy Program Quality Improvement Toolkit, FaHCSIA 2009
108
advocacy activities, limits to advocacy activities because of our agency’s
contractual obligations to FaHCSIA, relevant costs, reasonable alternatives,
consumers' right to refuse or withdraw consent, and the time frame covered by
the consent. Consumers should be given an opportunity to ask questions.
If consumers are not literate or have difficulty understanding English, our
agency should take steps to ensure consumers' comprehension. This may
include providing consumers with a detailed verbal explanation or arranging for
a qualified interpreter or translator whenever possible.
Where consumers have impaired decision-making abilities, our agency will use
ethical guidelines in determining the actions pursued (Refer to following section
on Consumers who Lack Decision-Making Capacity).
Duty of care
Where people with disability are the consumers of the agency, our agency has
a duty of care to these consumers. A duty of care exists where a consumer is
reasonably likely to be affected by what our agency does or doesn’t do, that is,
what information our agency provides or fails to provide in response to an
inquiry; what actions our agency takes or fails to take in response to a request
requiring advocacy support and what information our agency provides in
advocacy development activities.
Duty of care is part of the law of negligence.
To establish that our agency has been negligent in providing advocacy, a
consumer must be able to show that:
•
•
•
Our agency owed a duty of care to the consumer; and
Our agency breached that duty: our agency should reasonably have known
that its action/ advice (or its failure to act/ provide information or advice)
would harm the consumer, but our agency failed to take reasonable steps to
prevent that harm; and
The consumer has actually suffered harm as a result of our agency’s action/
information/ advice/ failure to act.
In advising consumers before they make a decision/ choice, agency staff and
volunteers should use the duty of care checklist and:
•
•
•
•
Assess the likelihood and extent of any foreseeable harm
Assess the likelihood and extent of the foreseeable benefit
Look for ways to minimise the risk of harm without sacrificing the benefit,
and
Balance the foreseeable harm against the benefit.
Consumers who lack decision-making capacity
In instances when consumers lack the capacity to provide informed consent,
where possible, our agency will protect consumers' interests by seeking
permission from an appropriate third party recognised by the law (e.g. guardian,
109
parent, person responsible), informing consumers consistent with the
consumers' level of understanding. In such instances, our agency will seek to
ensure that the third party acts in a manner consistent with consumers' wishes
and interests. Advocates should take reasonable steps to enhance such
consumers' ability to give informed consent.
If there is no alternative decision maker for the consumer our agency will, in the
first instance, support relevant agencies or people to make application to the
Guardianship Tribunal. Our agency will take this avenue in the first instance to
allow the advocate more freedom to support the consumer through the
Guardianship Tribunal process if necessary. However, in circumstances where
our agency is particularly concerned about a consumer’s welfare and there are
no alternative applicants it may seek to make an application for an alternative
decision maker itself.
If there is no alternative decision maker or the decision maker appears to be
acting against the consumer’s wishes or interests, the advocate should take
reasonable steps to safeguard the interests and rights of the consumer. In
doing so, ethical guidelines should be used. The following principles will help to
guide the advocate’s actions:




Take the least restrictive option: the intervention by the advocate will be the
least restrictive option in relation to the freedom of the consumer
Consider the consumer’s wishes: the advocate will take into account the
consumer’s present and past wishes and feelings so far as they can be
ascertained
Consult with relevant others: the advocate will seek and take into account
the views of relevant people who are close to the consumer or who may
know the consumer well. In weighing up the views of relevant others the
advocate will consider issues such as conflict of interest
Encourage and support consumer to use whatever skills he/ she has: the
advocate will encourage their consumer to exercise whatever skills that he
or she may have to participate in decision making about their welfare and
where practicable help the consumer develop new skills.
Advocacy process procedure
Where the advocate has an employment relationship with the agency advocates
will ensure that consumers, if they so wish, participate in decision making during
the advocacy process and will follow a procedure with each consumer or group
of consumers to ensure that this happens.
The following procedures should be undertaken as soon as possible after the
consumer has contacted our agency:


Clarify with the consumer what their preferred objective is regarding the
issues they have raised and plan the advocacy process around this
preferred objective
Clarify with the consumer any foreseeable consequences of actions that
may achieve their preferred outcome. This may involve suggesting a range
of actions along with providing alternative information sources
110



Inform the consumer about options for participating in the advocacy
process, based on the approach/es to advocacy we deliver
Does the consumer understand the options before them, or would the
advocacy process be improved if the consumer was supported by a family
member, friend etc. who knew the consumer well
Inform the consumer about our agency's policy relating to consent if the
consumer wishes information to be disclosed to people outside our agency
during the advocacy process.
Decision making in the management of our agency
Consumers, people with disability, advocates, volunteer advocates, families and
interested members of the public are encouraged to give feedback and have
input into our agency. Our agency will encourage consumers and people with
disability to participate in our agency’s operations.
People with disability will be encouraged to be involved in governance of our
agency and be provided with the necessary support, by Committee members,
staff and volunteers, to ensure their representation is as active as possible.
All stakeholders of our agency, including people with disability, their families,
carers and advocates, will be invited to participate in policy development and
evaluation of our agency.
111
Sample Policy: Consumer/ people with disability – Participation17
Policy statement:
In developing its services, Service Excellence will involve customers through
consultation and active participation in decision making.
Contents
1.
2.
3.
4.
5.
6.
Purpose
Scope
Links to other documents
Aims
Principles
Review
1. Purpose
To consult with consumers/ people with disability or have consumers/ people
with disability participate in decisions that may affect them or will shape the
future of our agency.
In addressing quality, continuous improvement, learning and development – we
are committed to the belief that by involving consumers/ people with disability
our advocacy delivery will more relevant to their needs.
We are committed to achieving real outcomes for consumers/ people with
disability.
Consumers’/ people with disability’s participation is seen as fundamental to
meeting current objectives, achieving positive outcomes for consumers/ people
with disability and developing meaningful advocacy delivery into the future.
2. Scope
The term “consultation” refers to our agency having dialog with consumers/
people with disability for the purpose of gaining their opinions and views.
The term “participation” refers to our agency actively involving consumers/
people with disability in the decision making process.
The principles of consumers’/ people with disability’s participation are detailed in
Section 5 of this Policy.
3. Links to other documents
4. Aims
The Policy aims to outline the principles relating to consumers’/ people with
disability’s participation. Fundamental to our approach to consumers’/ people
with disability’s participation is a commitment to:
17
South Australian Department of Families and Communities, Benefits of a Quality System, Service Excellence
Program
http://www.familiesandcommunities.sa.gov.au/DesktopModules/SAHT_DNN2_Documents/Download/633
652959205440320/SE%20CustomerParticipationPolicy.pdf
112
 Consumers’/ people with disabilities' needs being central to all that we do
 Consumers’/ people with disability’s involvement being an integral part of
continuous improvement
 Consumers/ people with disability being involved in decision making through
either consultation or participation
 Working collaboratively with consumers/ people with disability to reach our
objectives.
5. Principles
To operationalise the vision for consumers’/ people with disabilities'
participation, the Board and agency management will ensure the following
principles are adhered to:
• Consumers/ people with disability will have a voice
• Consumers/ people with disability will be involved in the planning and
development of advocacy activities that may affect them
• Consumers’/ people with disability’s participation includes a two-way sharing
responsibility involving consumers/ people with disability and all staff
• Our agency accepts that as a result of customer participation our advocacy
activities may evolve differently to that originally envisaged
• Consumers’/ people with disability’s participation will be a continuing
processes and a culture – it will not be a one-off event
• Consumers’/ people with disability’s participation strategies will, in general,
include:
o Providing accurate information
o Seeking views though consultation
o Active participation in decision making processes.
 Specific participation strategies our agency will use to involve consumers/
people with disability will include:
o Participation in planning processes
o Consultation on the development of resources, policies and procedures
o Consultation on issues relating to advocacy activities.
 Our agency will be open and honest with consumers/ people with disability
about where there is scope for choices to be made and where there is not.
 Consumers/ people with disability will be involved early in planning and
decision making processes, not later when directions are already set.
 When they have been involved, consumers/ people with disability will be
given prompt feedback regarding the actions that resulted from their input.
6. Review
Our agency is committed to continually working to improve its consumers’/
people with disability’s participation. In keeping with this commitment, the
Board will ensure that this Policy is reviewed initially after one year from its
introduction and on a triennial basis thereafter.
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Sample Policy: Board Members with intellectual disability policy and
procedure18
Citizen Advocacy South Australia Inc. (CASA) strives to ensure that any person
with intellectual disability acting in any Board of Management (BoM) capacity
understands, to the best of their ability, the consequences of any decision being
made within the organisation, and that through proper mentoring and support,
people with intellectual disability can grow and develop into their role.
Policy
CASA endorses the view of the funding body that people with intellectual
disability should have opportunities to be mentored to participate at an
organisational level within CASA.
All BoM Members have voting rights and their opinions are valued.
CASA recognises that many of the decisions and procedures used within the
organisation are complex and take time to understand. This reality, combined
with CASA’s awareness of not wishing to place any person in a position where
they could be made to feel inadequate, or seen as tokenistic, the following
procedure has been written.
Procedure
BoM members with intellectual disability may require a variety of supports from
another member when motions are moved or seconded or voted upon at Board
meetings.
18
Citizen Advocacy South Australia (CASA)
114
3.2 Tools
Tool: How to conduct focus groups for consumers'/ people with
disabilities' feedback19
Focus groups are an informal way of obtaining feedback from consumers/
people with disability in a friendly, non-threatening atmosphere. This sample
process takes you through steps for organising and conducting focus groups,
and using and distributing the information generated.
This process is one way that consumers/ people with disability can have an
input into agency management and make decisions and choices about
advocacy. The process can also be used as a feedback mechanism for
complaints about your agency’s systems and processes, and gathering
information to continually improve.
1. Select a topic
Ideas for a useful focus group topic can come from many sources:
•
•
•
From issues identified by consumers/ people with disability
From staff meetings
From management needs.
Once you have selected a topic, define a series of key questions relating to the
topic (not more than 10, in the interests of clarity).
Example: In the process of developing your corporate plan, you may seek
feedback on the topic of ‘The Corporate Plan and Advocacy Agency
Satisfaction’, specifically:








The Mission Statement
Goals of your agency
Quality of advocacy delivery
What advocacy is provided
How your agency should be marketed
What consumers/ people with disability liked or disliked
What was missing from support
Suggested changes or areas of improvement.
19
Based on the process used by Personnel Employment, SA, a Disability Employment Network service, Quality
Strategy Toolkit for Disability Employment and Rehabilitation Services, FaHCSIA
115
2. Arrange a convenor
So that consumers/ people with disability are able to communicate their views
frankly, it is useful for the focus group convenor to be someone from your
agency who is not directly involved in advocacy delivery to those consumers/
people with disability.
Make sure the independent convenor you select is adequately briefed on
relevant background relating to the focus group topic, your agency and your
consumers/ people with disability.
3. Invite consumers/ people with disability
Invite consumers/ people with disability to attend. Using groups of less than
10 consumers/ people with disability are recommended. You could encourage
participation by integrating the focus group with another event, like a lunch or
morning tea. Encourage consumers/ people with disability of different ages,
genders, backgrounds, to participate so that your group is more representative
of your agency as a whole.
Consider at this point whether any of the attending consumers/ people with
disability will require support to participate in the focus group, and how you can
arrange support for them.
4. Convenor conducts the meeting
The convenor will then facilitate the focus group. The convenor should
establish some ground rules to emphasise that all participants should listen to
one another’s views, take turns to express their opinion and respect the views
of others. The convenor will find it useful to tape record the focus group, but
should check first that the participants consent to be taped and complete
consent forms.
Advise all participants that their comments will be kept anonymous.
5. Convenor writes-up results
The convenor should then write-up the results of the focus group into a
summary report, using the views expressed by the participants. The write-up
should not identify any participants, either by name or other identifying details.
6. Convenor circulates write-up to focus group members
The convenor should circulate the summary report to focus group participants
only. The focus group members should confirm that:
116
 They have not been inadvertently identified in the write-up
 The write-up is accurate.
During the focus group the convenor should establish how participants would
like to be contacted to review the summary report and whether they will require
any support to review the summary report.
The convenor should make changes to the report as required by the
participants.
7. Distribute findings
When the participants have reviewed and confirmed the write-up, distribute the
summary report to the areas in your agency where the information could have
an impact.
Depending on the focus group topic, these might include:




The management and CEO
The Board
Continuous improvement committee or other form of quality committee
A person responsible for organising/administering training programs.
8. Follow-up
If the summary report suggested any specific changes, you may wish to followup with the relevant area of your agency to see whether any changes have
been made based on the focus group feedback. You could do this as an
automatic process, three months after every focus group. You should
document any changes or responses, and keep the records alongside the focus
group summary report. This documentation may be able to be used as
evidence of continuous improvement processes.
Guide to Engagement20
Engagement is a term used to describe the range of interactions between
people (consumers/ people with disability, staff, and management). It is an
ongoing process that can influence people’s interest, expectations and
motivation to participate. It can include a variety of approaches, such as
informal communication or information exchange, active listening, and
relationship management.
Engagement is an active process that allows:
20
Adapted from Disability Services Queensland Service User Participation Snapshot and Guide,
www.disability.qld.gov.au/quality
117
 The establishment and maintenance of relationships
 information sharing
 An increased awareness of the value of consumers/ people with disability
participation.
Why is effective engagement so important?
For consumers/ people with disability, effective engagement demonstrates that
their needs, experiences and feedback can directly influence the way that
advocacy is delivered, and that they have roles that contribute to your agency’s
planning, development and delivery. To feel motivated to participate, the
potential benefits of doing so need to be outlined to consumers/ people with
disability. It is through the later participation in your agency’s processes
(activities) that the benefits are reinforced.
Effective engagement enables your agency to build a relationship with
consumers/ people with disability that is based on the value of consumers’/
people with disabilities' feedback driving advocacy delivery, and enables a
greater understanding of consumers’/ people with disabilities' needs and what
investment is required to facilitate their participation.
Goals of engagement
 Create a foundation for participation in your agency activities.
 Identify ways to work together according to each other’s capacity and capability.
 Identify, plan and resource supports required to enable participation.
How does engagement occur?
Engagement occurs each and every day in your agency: from a consumer’s first
day at (during their orientation or initial meeting), in the information you make
available about your agency (through pamphlets or websites) and in the way
you respond to consumers/ people with disability on an ongoing basis (such as
acting on a parent’s suggestion or complaint).
All of these are examples of engagement activities. They involve the
establishment of relationships, a sharing of information, and a raising of
awareness that consumers’/ people with disabilities’ participation is valued.
How does engagement enable participation?
Through engaging consumers/ people with disability, you are able to
demonstrate to them that they are valued and are the focus of your agency.
Effective participation will be dependent to a large extent on whether
consumers/ people with disability feel valued and respected as vital contributors
by both staff/ volunteers and management.
118
Trust, respect, support, openness – these are key components in building
rapport and relationships with consumers/ people with disability and their
families.
Furthermore, it is through establishing strong relationships that consumers/
people with disability, staff and agencies are able to communicate more
effectively and gain information about how consumers/ people with disability
can participate in agency processes such as planning, development and
delivery. The diagram below represents how an environment for participation is
supported by ongoing engagement activities (i.e. investment, communication):
Environment for participation
Example: Your agency is holding a planning day (the participation activity) and
would like to have consumers/ people with disability contribute to providing
direction and decision making (their role). By using your agency newsletter
(the communication method), you can inform them (raise awareness) of their
potential role in the activity and how you will use their contribution (your intent).
You can determine what resources (the investment) are required to support
their participation in the activity based on the information you collect through
your day-to-day interactions. Results from your annual satisfaction survey
(feedback mechanism) can also be used to indirectly contribute to the planning
day and assist in measuring (evaluation) the success of the participation
activity. This activity, developed by Disability Services Queensland, asks you to
reflect on the way you engage people with disability in your agency and their
participation in planning, development and delivery.
119
Engagement
Engagement is the foundation for participation, and supports consumers/
people with disability in choosing to actively participate in your agency
processes of planning, development and delivery.
A number of key elements (domains) will contribute to the achievement of these
goals and inform the development of your engagement strategies and activities:

Roles: In identifying opportunities for participation in your agency
processes (planning, development and delivery), potential roles will need to
be identified and agreed on by consumers/ people with disability and
agencies. These roles may be contributing to agency planning or informing
the results of improvements or consulting on staff recruitment. Some roles,
such as a consumers/ people with disability representative on the Board of
management, may be formally recognised in your constitution.

Communication: Communication allows greater awareness (information
sharing) of each other’s needs and potential. By maintaining open
communication mechanisms (informal and formal) you can continue to
exchange information – as consumers’/ people with disabilities' needs and
interests change or your agency’s capacity and capability to respond to
those needs changes. The communication you establish during
engagement can then be utilised when needed according to the
participation activity (planning, development and delivery).

Investment: During engagement, there are two parts to investment. The
first is a commitment to providing opportunities for participation. Then, after
having determined potential roles and the supports required to enable
participation, you can begin to identify the investment required in terms of
funds, time, skills development, staff, resources, support aids and so on.
Engagement strategies and activities can be subtle and informal, e.g. in day-today consumers/ people with disability and staff interactions. There are also
formal processes for engagement, including:




Mission and vision statements – which could articulate your commitment to
participation
Brochures or posters – which can raise awareness of the potential benefits
of participation
Consumer assessment – which increases your understanding of their
needs, interests and motivations in order to plan your participation support
and activities
Newsletters – which could outline how consumers/ people with disability
can choose to participate in decision-making processes.
Advocacy planning
Engagement is a precursor to participation in agency processes like agency
planning. So, after considering and reflecting on ways you engage with service
users, the next step is to consider how you have involved (or plan to involve)
120
them in your planning. This might include formal processes e.g. forums,
consultations, surveys or questionnaires, focus groups, small working groups or
individual interviews. You may also establish advisory committees or reference
groups, facilitate planning or evaluation meetings, or include consumers/ people
with disability representatives on your board of management. Using information
from your complaints register is an indirect form of consumers’/ people with
disability’s participation in your planning processes.
Consider the different levels of planning – strategic, operational and individual –
at which people with disability can participate.
Advocacy development and delivery
The next step in the exercise asks you to consider consumers’/ people with
disability’s involvement in advocacy development and delivery. Consider how
consumers/ people with disability are involved in these activities and whether
the degree of involvement is appropriate to consumers’/ people with disability’s
capacity and the nature of the task.
Agency development includes developing policies, procedures, systems and
programs and all the things your agency does to make improve.
Advocacy delivery includes (but is not limited to) the activities that link directly to
providing access, support, care, advocacy etc. Advocacy delivery may include
structured processes or activities, such as how a consumer accesses your
agency or how development of individual plans occurs.
Now consider the questions in the following table and complete your agency’s
snapshot of consumer/ people with disability participation. Once the table is
complete you may use this information to identify specific areas where you
could improve participation link and link these to continuous improvement
activities.
121
Consumer/ people with disability participation
Engagement
Advocacy Planning
Investment (support and
capability)
Describe how you have
invested in the following areas
to enable participation:
* Skill development for staff or
people with disability
* Communication support *
Time
* Financial assistance
* Family support
Roles (potential)
Have you identified with
people with disability ways to
work together? If so how?
Activity
Outline the opportunities that
exist for participation in
advocacy planning activities.
From this, what are the
potential roles involved in
working together?
What contributions do people
with disability make to
planning?
Communication/Information
(range)
Outline the range of
communication methods used
to raise awareness of
participation opportunities.
Communication/Information
(actual)
Which communication
methods do you use to raise
awareness of planning
activities and results?
What information is
exchanged between you and
your people with disability to
enable participation?
What communication supports
do people with disability
access in order to be actively
involved in planning?
Describe how this impacts on
your relationship with people
with disability.
How has working together
changed your relationship?
Goals for participation
What are you hoping to
achieve by involving people
with disability in your agency?
Evaluation
Have you evaluated the level
of participation in planning
activities?
Is there shared understanding
between you and people with
disability about what you can
achieve through participation?
If yes, did the activities
contribute towards your
reaching your goals for
participation?
Roles (actual)
Describe the specific roles
around advocacy planning
activities.
Advocacy development and
delivery
Activity
Outline the opportunities that
exist for participation in
advocacy development and
delivery activities.
Roles (actual)
Describe the specific roles
around advocacy
development and delivery
activities?
What contributions do people
with disability make to service
development and delivery?
Communication/Information
(actual)
Which communication
methods do you use to raise
awareness of advocacy
development and delivery
activities and results?
What communication supports
do people with disability
access in order to be actively
involved in advocacy
development and delivery?
How has working together
changed your relationship?
Evaluation
Have you evaluated the level
of participation in advocacy
development and delivery
activities?
If yes, did the activities
contribute towards your
reaching your goals for
participation?
122
Engagement
Investment (support and capability)
Advocacy Planning
Activity
Advocacy development and delivery
Activity
Roles (potential)
Roles (actual)
Roles (actual)
Communication/Information (range)
Communication/Information (actual)
Communication/Information (actual)
Goals for participation
Evaluation
Evaluation
123
Standard 4:
Privacy, dignity and confidentiality
4.1 Sample policies and procedures
Sample Policy: Collection and Use of Information21
Collecting Consumer Information
1. Any information obtained by our agency about consumers, both past and
present, will be regarded as confidential and must not be used for any
purpose other than that for which it is given.
2. A consumer will be advised and made aware of what information is kept
about him/her, why it is kept and who has access to it.
3. Our agency will only collect consumer information that is directly relevant to
effective advocacy assistance.
4. All staff, volunteers and Management Committee members of our agency will
sign a confidentiality declaration indicating that they understand the
confidentiality and privacy requirements to which their work is subject.
Information Disclosure and Consent
1. Each consumer has the right to access any information that our agency
keeps about him/her. Any person except an advocate, approved student
advocate, approved volunteer advocate must obtain consent from the
consumer before obtaining access to the consumer's file.
2. Before any identifying information is disclosed to any individual or
organisation other than authorised advocate of our agency, consent must be
obtained from the consumer. If information of a sensitive nature must be
disclosed in order to reach the outcome requested by the consumer, then
written consent must be obtained from the consumer (e.g. a consumer
wishes information about their case to be provided to the media).
3. If another organisation wishes to make contact with a consumer, our agency
may either invite the consumer to contact the organisation or obtain consent
from the consumer to provide relevant information.
4. Identifying information in a consumer's file must not be used for the purpose
of research without written consent from the consumer.
Exceptions to confidentiality
Statistical Information
 Statistics may be gathered about consumers who use our agency for the
purposes of agency planning, accountability and systemic advocacy.
However, this information will be used sensitively and in a manner that does
not identify individuals.
 Case studies used for the purpose of community education will not contain
information which will cause a consumer to be identified (i.e. identifying
information may be altered to protect the privacy of the consumer). If there is
21
National Disability Advocacy Program Quality Improvement Toolkit, FaHCSIA 2009
124
any concern that such information might identify an individual, our agency
should seek the consumer's consent.
Supervision
From time to time, an advocate may need to seek independent professional
supervision or consultation to assist consumers in achieving the outcome they
wish. Identifying information should not generally be given to the professional
supervisor. However, if providing such information is essential, advocates/
volunteer advocates should seek the consent of the consumer. A professional
supervisor should be given a copy of this policy and agree to abide by it.
Subpoena
If a consumer's file is ordered by a subpoena, the consumer will be notified as
soon as possible. Only information ordered by subpoena will be released. In
this instance, the information may be photocopied.
Necessity
There may be an exception to confidentiality where our agency reasonably
believes that the use of disclosure is necessary to prevent a serious and
imminent threat to the individual’s life, health or safety or, a serious threat to
public health or safety.
A decision to disclose information to seek help or protect the consumer will pay
due regard to the particular consumer’s capacity to make decisions.
Any need to disclose consumer information on the basis of necessity should be
discussed with senior staff wherever possible.
Complaints processes
Should a complaint occur about the operation of our agency, a delegated
member of the Management Committee may have access to the nominated
consumer’s file in order that the Management Committee member can
participate in the resolution of the complaint.
Mandatory reporting requirements
Our agency’s staff/ volunteers may be required by legislation to disclose
relevant consumer information to the Department of Community Services (or
any equivalent body as specified by legislation) if that paid staff member has
reasonable grounds to suspect that a child is at risk of harm and that those
grounds arise during the course of or from that person’s work. Funding Body’s
Access
Our agency is required to make files available to the government funding body
for auditing purposes if the funding contract stipulates this. Our agency will
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ensure that government funding body obtain permission from individual
consumers before making any files available.
File management
Treatment of files
 A file will be created for each new person being assisted by our agency
 Files will not be duplicated, except where sections of a file have been
requested by subpoena
 Files remain the property of our agency. However, copy can be made of any
or all information for the consumer on request.
 A consumer's file will be placed into secure storage upon the consumer
ending their association with our agency. Such files will be destroyed after
five years.
Maintenance of files
 Documentation should contain objective information. Care should be taken
with the choice of language used.
 Consumer files should contain the originals of incoming documents and
copies of any outgoing correspondence.
 All incoming and outgoing correspondence must be dated.
File security
 Consumer files will be filed in lockable cabinets.
 Information kept on computer should be kept in a secure fashion.
 Only our agency’s advocates (or the citizen advocate associated with a
particular consumer) may have access to consumer files. General volunteers
or students on placement may access specific files under supervision of
advocates.
 A consumer file should not be removed from the office unless special
circumstances prevail and permission is first sought from our agency’s
Coordinator.
Personal privacy and dignity
In all decisions and dealings of our agency, our agency will ensure that people
with disability are treated with dignity and respect.
Where people with disability and/or their family members are consumers of the
agency, our agency will respect consumer’s rights to personal privacy (e.g. in
personal hygiene tasks).
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4.2 Tools
Tool: The National Privacy Principles and Information Privacy Principles –
Protecting Privacy throughout the information cycle22
Note: The National Privacy Principles (NPP) are the base line privacy standards
which some private sector organisations need to comply with in relation to
personal information they hold. The Information Privacy Principles (IPP) are the
base line privacy principles which Commonwealth government agencies need
to comply with in relation to personal information kept in their records. 23
It is a condition of the current NDAP funding agreement, and a requirement of
Standard 4 of the Disability Advocacy Standards, that NDAP funded disability
advocacy agencies must comply with the IPPs contained within the Privacy Act
1988.
22
Quality Strategy Toolkit for Disability Employment and Rehabilitation Services, FaHCSIA:
https://www.fahcsia.gov.au/sa/disability/pubs/employers/Documents/quality_strategy_toolkit
23
See Office of the Privacy Commissioner, www.privacy.gov.au
127
The National Privacy Principles and Information Privacy Principles – protecting privacy throughout the information cycle.
128
Tool: Sample Privacy Statement for Consumers24
Gippsland Disability Advocacy Inc. (“GDAI”) is committed to meeting the
requirements of the Information Privacy Act (2000) and the Health Records Act
(2001). These two pieces of legislation govern the way we handle your
information from collection through to disposal. More detailed information on
the rights and responsibilities of both consumers and the GDAI is available in
GDAI’s Privacy Policy. A copy of GDAI’s Privacy Policy can be made available
upon request.
The Gippsland Disability Advocacy Inc will:
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identify the main purpose for the collection of information from you
collect only the information required for this purpose*
not share this information without your consent*
let you see your file on request
correct file information if it is established that file content is inaccurate
provide you with access to your file, if you require it*
keep your file in a secure place
destroy your file in accordance with our statutory requirements.
We reserve the right given to us under both Acts to restrict your access to
information in your file because that access may:
 unreasonably affect the privacy of other individuals
 pose a serious threat to the life or health of any person
 expose information given in confidence by a third party
 be unlawful because other legislation requires our agency to withhold
information
 prejudice a law enforcement function by a law enforcement agency.
I acknowledge that I have read this statement and agree to my file being held
and disposed of in accordance with statutory requirements without being
notified at the end of the statutory holding period.
Consumer
(Please print full name)________________________________________
Signed
Date_____________________
Advocate
(Please print full name)________________________________________
Signed
Date_____________________
*Statistical information will be collected to meet relevant funding body
requirements and for research and analysis purposes as allowed for under
both Acts. Importantly this information is maintained in a manner which
ensures that it cannot be identified with you or your file.
24
Gippsland Disability Advocacy Inc.
129
Tool: Sample Confidentiality Agreement25
CONFIDENTIALITY AGREEMENT
This agreement is to be read and signed by each member of the Board and all
staff members This will also be a requirement for advocates, volunteers,
contractors, consultants and business partners who work with CASA and have,
or are likely to have access to information used by CASA.
CASA has a significant responsibility to protect the information it holds and
encounters in relation to its services, the work it undertakes and its
stakeholders. The undersigned recognises the importance of using information
appropriately and safeguarding information from unauthorised disclosure or
use, whether this information is directly related or incidental to their involvement
with CASA.
The undersigned agrees to:
 Ensure that confidential information which is acquired in connection with
Citizen Advocacy will not be disclosed to any person or organisation, unless
authorised to do so or legally required to do so in which case the Board shall
be notified within twenty-four hours.
 Take careful and reasonable measures to secure and maintain the
confidentiality of all information at all times. This standard of care relates to
all forms of information (e.g. verbal, written, and electronic).
 Return all information in your possession promptly to CASA if requested to
do so, including all copies of information, and notes of meetings and
conversations.
 Comply with these requirements even after ceasing to be involved with or
transact with CASA.
 Seek advice from the Program Manager or their delegate, or in their absence
the Chair of the Board, where any uncertainty exists in relation to the use,
storage, distribution or security of information.
This agreement is made between CASA Inc. and the undersigned.
Signatory’s Name:
(Please Print Name in Full)
Signature
CASA Delegate:
Signature:
Date:
25
Citizen Advocacy South Australia
130
Standard 5:
Participation and integration
5.1 Sample policies and procedures
Sample Policy: Participation and Integration26
Our advocacy agency will:
 Educate staff regarding:
o The importance of ending the discrimination, segregation and neglect of
people with disability in the community
o The importance of participation by people with disability in regular
activities in the community
 Encourage staff, volunteers and advocates to develop links between our
agency and people and groups that will benefit people with disability
 Where possible and appropriate, participate in community education or
activities to promote greater understanding and awareness of disabilities.
To enable effective integration and participation, our agency will maintain and
develop relationships with the local community, as well as coordinating with
other agencies to be an effective community partner.
Where people with disability are the consumers of the agency, our agency will:
 Provide information about resources, activities and opportunities for
consumer participation and inclusion in local community events/ activities.
Information will be filed and updated regularly, and made available for
consumers’ use
 Provide consumers with information about general community facilities and
services and how to use them
 Support people with disability to form and maintain a variety of appropriate
ties, connections and involvements in the community.
Systemic change policy
Where the agency does not undertake systemic advocacy, our agency will:
 Document the issues consumers of our agency identify
 Identify trends and any ongoing systemic issues
 Refer any systemic issues to a systemic advocacy agency and ensure follow
up with the agency.
Where the agency undertakes systemic advocacy, our agency will:
 Where possible, consult with people with disability about the systemic actions
that should be pursued. Where this is not possible, for example, in reactive
cases, inform people with disability about the actions being pursued
 Follow up systemic issues referred by other advocacy agencies.
26
National Disability Advocacy Program Quality Improvement Toolkit, FaHCSIA, 2009
131
Sample Policy – Participation and Integration27
Gippsland Disability Advocacy Incorporated recognises the valuable contribution
people with disability can make to the communities in which they live.
The Council encourages and supports each person with a disability to participate
and be involved in the life of the community.
Participation in community activities
The GDAI will facilitate the integration of people with disability in community life by
actively encouraging and supporting their participation in or use of:
 Community based Advocacy and Self Advocacy Groups, Committees of
Management, Steering and Advisory committees (e.g. Access Committees).
 Forums, workshops and seminars offered within the community.
 Community based recreation and leisure facilities and facilitate access to other
social options and activities.
 Public transport to maximise independent travel.
 Community based services and facilities available to all members of the
community.
Information regarding general community services and facilities, and how to
use them, will be available upon request from the GDAI. This information
will be available in alternate format to suit the needs of the person making
the request.
Community education and advocacy
GDAI will further the opportunity for participation and integration of people with
disability in community activities by effective advocacy, and community education
programs, which include:
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27
Extensive media coverage highlighting the abilities of people with "disabilities",
the implication of disability and disability issues.
Conducting disability awareness programs in schools and tertiary institutions
(e.g. TAFE Colleges), and guest-speaking at Service Clubs and Community
Groups.
Conducting Community Awareness forums and workshops available to the
public.
Supporting regional self advocacy groups within local communities.
Identifying and resolving issues, which are preventing or hindering further
participation of people with disability in community life, through effective
systemic advocacy by Community self advocacy groups.
Advocating for improvements to physical access within the community.
Gippsland Disability Advocacy Inc.
132
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Advocating for changes to general services and facilities so they have the
capacity to cater for the extra needs of people with disability.
Availability of policy
The Policy Manual, including the Participation and Integration Policy, is available
to all consumers and potential consumers in a suitable format.
Review of policy
The Participation and Integration Policy will be reviewed at least every 12 months,
more often if necessary.
This policy will be reviewed by staff, members of the Committee of Management
and consumers, in General Meetings or Special General Meetings or consultation
by mail or telephone.
133
Standard 6:
Valued status
6.1 Sample policies and procedures
Sample policy: Valued status28
Our advocacy agency will:
 Support people with disability to obtain the same rights as other citizens
through the advocacy process (whether on a collective or individual basis)
 Operate from a physical environment which encourages participation of
people with disability and their family members/ carers (fully accessible
premises in local community areas)
 Ensure that venues for meetings, conferences, workshops, etc. are
accessible
 Involve people with disability in the management, planning or operations of
our agency, where possible and appropriate
 Identify and respond to the needs and ideas for developing sustainable
connections and networks in the community, which will support people with
disability’s valued status
 Work with the community and in the community to foster opportunities for
people with disability to participate in ways which will be valued.
Where people with disability are the consumers of the advocacy agency, our
agency will:
 Provide consumers with real opportunities to maintain and develop skills and
capacities which will support their aspirations and strengths
 Be responsive to the individual needs of people with disability wishing to
develop and maintain valued roles in the community
 Support each person with disability to have the opportunity to develop and
maintain skills, capacities and lifestyles that are valued in the community
 Where possible and appropriate, support consumers to participate as agency
members at conferences and brief them about the purpose of the meeting
and their role as a participant.
Promoting ‘valued status’ in the community
Our agency's community education/ awareness strategy will promote the
abilities and competencies of people with disability. Our agency recognises and
promotes the inherent value of all people with disability and values the
contributions and skills of people with disability and their family members/
carers.
Any publications or promotional material produced by our agency will:
28
National Disability Advocacy Program Quality Improvement Toolkit, FaHCSIA, 2009
134
 Promote the abilities, skills and contributions to the community of people with
disability, by:
o using language that puts the person first i.e. ‘people with disability’
o referring to adults with disability as adults, not children
o describing a person’s needs (if necessary) by using terms such as ‘low
support needs’, ‘high support needs’
o advocating that labels such as ‘disabled’, ‘spastic’, ‘handicapped’,
‘retarded’, ‘mental’ and patronising terms are not used
 Not use the term ‘disability’ in a negative way to attract support, financial or
otherwise
 Present the concerns of people with disability and their carers positively to
the media, in publications, conferences etc.
 Provide the best quality information available to people from an Aboriginal or
Torres Strait Islander or Culturally and Linguistically Diverse background with
disability and their carers in a culturally appropriate way.
Within our scope and available resources, our agency will develop and/or
implement programs and activities in and with the community to promote valued
status.
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Sample Policy: Valued status -Gippsland Disability Advocacy
GDAI recognises, upholds and promotes the valued status, abilities,
competencies, and contributions of people with disability by:
 Creating a level of membership within the association, namely Full
Membership, which gives people with disability and/or carers voting rights;
 Including a rule in the Articles of Incorporation which ensures Committee of
Management is made up only of Full Members of the Association;
 Facilitating the participation and management of regional advocacy groups and
support groups by people with disability;
 Respecting and upholding the consumer and human rights of people with
disability;
 Providing services in the least restrictive and most empowering way;
 Constantly consulting with people with disability;
 Providing service within a fully accessible generic location with high quality
facilities;
 Ensuring services are provided by carefully selected and appropriately trained
staff.
GDAI will support and encourage people with disability to develop and maintain
the necessary skills and capacities, to enable them to attain a valued role in the
community by:
 providing information about, and referral to, educational and skill enhancement
services;
 providing or arranging support for people with disability to enable them to
access educational and training services.
Availability of policy
The Policy Manual, including the Valued Status Policy, is available to all
consumers and potential consumers in a suitable format.
Review of policy
The Valued Status Policy will be reviewed at least every 12 months, more often if
necessary.
This policy will be reviewed by staff, members of the Committee of Management
and consumers, in General Meetings or Special General Meetings or consultation
by mail or telephone.
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Sample Policy: Valued status - Sunshine Coast Citizen Advocacy29
SunshineCoast Citizen Advocacy will:
 Support people with disability to obtain the same rights as other citizens
through supporting People with disability to achieve ‘Valued Status’
Sunshine Coast Citizen Advocacy will:
 Support people with disability to obtain the same rights as other citizens
through the advocacy process.
 Operate from a physical environment which encourages participation of
people with disability and their family members/ carers (fully accessible
premises in local community areas)
 Ensure that venues for meetings, conferences, workshops etc. are
accessible
 Involve people with disability in the management, planning or operations of
Sunshine Coast Citizen Advocacy, where possible and appropriate.
 Identify and respond to the needs and ideas for developing sustainable
connections and networks in the community, which will support people with
disability’s valued status.
 Work with the community and in the community to foster opportunities for
people with disability to participate in ways which will be valued.
Sunshine Coast Citizen Advocacy will support and encourage citizen advocates
to:
 Provide protégés with real opportunities to maintain and develop skills and
capacities which will support their aspirations and strengths
 Be responsive to the individual needs of protégés wishing to develop and
maintain valued roles in the community
 Support protégés to have the opportunity to develop and maintain skills,
capacities and lifestyles that are valued in the community
 Where possible and appropriate, support protégés to participate at
conferences and brief them about the purpose of the meeting and their role
as a participant.
 Promoting ‘Valued Status’ in the community
Sunshine Coast Citizen Advocacy’s community education/ awareness strategy
will promote the abilities and competencies of people with disability. Sunshine
Coast Citizen Advocacy recognises and promotes the inherent value of all
people with disability and values the contributions and skills of people with
disability and their family members/ carers.
Any publications or promotional material produced by Sunshine Coast Citizen
Advocacy will:
Promote the abilities, skills and contributions to the community of people with
disability, by using language which is image enhancing and which will promote
valued social status of people with disability.
29
http://www.citizenadvocacy.com/policies/policies-and-procedures/valued-status/
137
 Not use the term ‘disability’ in a negative way to attract support, financial or
otherwise.
 Present the concerns of people with disability positively to the media, in
publications, conferences etc.
 Provide the best quality information available to people from an Aboriginal or
Torres Strait Islander or Culturally and Linguistically Diverse background with
disability and their carers in a culturally appropriate way.
 Within our scope and available resources, Sunshine Coast Citizen Advocacy
will develop and/or implement programs and activities in and with the
community to promote valued status.
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Standard 7:
Complaints and disputes
7.1 Sample policies and procedures
Sample Policy: Complaints and disputes30
Principles
Our agency supports the right of people with disability, or of the carers and
families of people with disability, to make a complaint without retribution. Our
agency will take all reasonable steps to ensure that anyone involved in making
a complaint is not victimised, and will inform complainants of how they will do
this.
Our agency’s complaints and disputes policy and procedure will be accessible
to consumers and people with disability. Copies of the complaints and disputes
mechanisms will be available, written in clearly understandable language.
Provisions will also be made for people from a Culturally and Linguistically
Diverse (CALD) background with disability to have access to material relating to
complaints and disputes policy and procedures where required. The material
explaining the complaints and disputes system will make explicit that there will
be no retribution against anyone who makes a complaint against our agency.
Sample Procedure
Step One
In the first instance, the person with disability is encouraged to discuss the
matter with the person perceived to be responsible for the grievance. If the
person with disability feels unable to discuss the matter directly with the person
involved, for instance because the allegation is a serious one such as sexual
harassment, the matter should be referred directly to the Management
Committee of our agency.
Confidentiality and privacy should be respected as much as possible.
Step Two
If the matter is not resolved by discussion with the involved parties, the
grievance should be referred to the Management Committee. The Management
Committee will form a sub-committee to address grievances.
This subcommittee will discuss with the complainant whether the complainant
requires a support person to assist them through the dispute resolution process.
Step Three
30
National Disability Advocacy Program Quality Improvement Toolkit, FaHCSIA, 2009
139
Where the dispute cannot be resolved at Committee level, the Committee will
appoint, with the complainant’s approval, an independent conciliator to assess
the grievance. The conciliator will report on the outcome to the Committee and
the consumer.
Step Four
Disputes that are still unresolved after this stage should be referred to an
external body.
Sexual harassment
Sexual harassment is unwelcome sexual attention or uninvited sexual advances
that result in you feeling embarrassed, humiliated or intimidated. Sexual
harassment may be explicit or implicit. It may be a single incident or occur over
a period of time.
Examples of behaviours that may be considered sexual harassment include:
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Sexual jokes, lewd suggestions, whistling, foul language, leering, obscene
gestures
Belittling comments about a person’s anatomy or based on sex-role
stereotypes
Persistent demands for participation in social activities or repeated requests
for dates
Asking about a person’s private or sex life, explicit sexual suggestions in
return for ‘reward’
Unwanted physical contact of a sexual nature including touching, brushing
or kissing
Display of pornographic and/or sexually suggestive pictures, screen savers,
jokes etc. and/or sexual objects
Sexually offensive written, telephone or electronic communications
Indecent exposure
Trying to force another person to have sex.
Our agency will:
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Treat all complaints of sexual harassment seriously and will deal with them
promptly, impartially and confidentially
Take steps necessary to ensure that sexual harassment does not continue,
that complainants and witnesses are not victimised in any way and that,
where possible, a fair and appropriate resolution of the problem is reached
Discipline any staff found harassing others.
Complaints about sexual harassment within our agency should use the normal
system of complaint/ dispute resolution outlined in our agency’s complaints and
disputes policy. However, the complainant may wish to omit Step One if they
are uncomfortable discussing the matter directly with the other person.
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Staff misconduct and discipline
Definitions
Misconduct is failure by an employee to fulfil their duties. Misconduct includes
the following actions carried out at agencies or during the course of an
employee’s duties:
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Theft
Physical assault
Sexual harassment
Psychological and emotional abuse (e.g. bullying)
Intoxication
Use of illegal drugs (unless prescribed by a recognised medical practitioner)
Gross negligence
Serious breach of policies/ procedures
Serious breach of safety procedures
Illegal or fraudulent acts while on agency business
Wilful or malicious damage
Wilfully disregarding/ disobeying a reasonable instruction
Inefficiency/ incompetence
Negligence/ carelessness in carrying out duties
Engaging in improper conduct
Engaging in patronage, favouritism or discrimination in the discharge of
duties
 Supplying incorrect/ misleading information in relation to their employment.
There are two possible responses to misconduct by employees: counselling/
warning or dismissal.
Staff members/ volunteers involved in misconduct or discipline procedures have
the right to notify an accredited representative of their Union or other support
person/ advocate of their choice, to organise a meeting with the appropriate
program manager and to accompany the employee at any time during these
procedures.
Allegations of misconduct should be referred to a member of the Management
Committee.
Procedures (From Employer’s First Guidelines)
The 4 step procedure outlined next, aims to get an employee [defined as any
person who has an employment relationship with agency] who has not been
performing or behaving satisfactorily ‘back on track’. The steps are designed to
ensure that the employee is treated fairly.
Step 1. Counselling and Oral Warning
The employee’s supervisor or a member of the Management Committee will
initiate a discussion with the employee about their performance or behaviour.
141
The purpose is to bring the unsatisfactory performance or behaviour to the
employee’s attention.
Before the discussion the supervisor or committee member will:
 Check the matter thoroughly and gather all the facts including any previous
performance reviews
 Ensure the employee has received any training they should have been given
to perform the job satisfactorily
 Remove any genuine obstacles to the employee performing the job properly
 Prepare an outline of main points to be covered.
During the discussion the employee’s supervisor or committee member will:
 State the specific problem
 Give the employee a chance to explain their point of view
 Consider their response and, if not satisfied, tell the employee the changes
they expect and warn that if the employee does not improve further
disciplinary action will be taken.
After the discussion, the employee’s supervisor or committee member will:
 Record in a file note the date and place of the meeting, who was present and
what was said, particularly the wording of the warning
 Seek advice from Employer’s First before proceeding to Step 2.
Step 2. Counselling and Written Warning
Before the discussion the employee’s supervisor or committee member will
follow the procedures in Step 1.
In addition, the employee’s supervisor or committee member will:
 Tell the employee that they may have a friend or other support person
present during the discussion
 Organise a program manager, the employee’s supervisor or other senior
employee to be present during the discussion to observe and assist.
During the discussion, the employee’s supervisor or committee member will:
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Review the previous discussion
Discuss the employee’s performance or behaviour during the review period
Give the employee a chance to respond and explain
Tell the employee the specific changes s/he requires
Ask the employee to confirm they understand what is expected of them
Tell the employee they will receive a written warning after the discussion and
that failure to change may put their job at risk
 Seek advice from Employer’s First before proceeding to Step 3.
After the discussion, the employee’s supervisor or committee member will:
 Give the employee a written warning which contains
o The dates of the first and second discussions
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o
o
o
Details of the problem/s
A statement of the changes s/he requires
A statement saying that if they fail to change or improve they may
jeopardise their employment and will be subject to further disciplinary
action
 Record these details in a file note and attach a copy of the written statement
to the employee to the file.
Step 3. Counselling and Final Written Warning
The committee member will:
 Follow the same procedure as in Step 2
 Give the employee a letter which states clearly that because of their failure to
improve satisfactorily following Steps 1 and 2, this final warning is now being
given and their employment will be terminated if they fail to make necessary
improvements
 Ask the employee to sign the letter, acknowledging receipt, keep copies on
file and re-state to the employee that this is their final warning
 Seek advice from Employer’s First before proceeding to Step 4.
Step 4. Dismissal
Before the dismissal, the Committee member will:
 Discuss the employee’s performance or behaviour with other management
and senior people involved before taking action
 Review all supporting documents on file, leave records, performance reviews
 Prepare an outline of the points to be covered
 Consider responses to possible questions from the employee
 Organise a program manager or the employee’s supervisor to be present
during the dismissal.
During the dismissal, the Committee member will:
 Have someone else from senior management present
 Ask the employee to come to her/his office or another private area, and allow
them to bring a support person
 Tell the employee s/he is considering terminating their employment
 Put the allegation specifically to the employee in enough detail to allow them
a fair opportunity to respond
 Ask for, and answer, any question the employee has and give the employee
a chance to put their position
 Listen to the employee’s explanation and assess whether it changes her/his
views about termination
 Take a short break to consider the employee’s explanation and if s/he
considers termination is still appropriate, prepare a letter of termination
stating reasons and any entitlements owing, including notice or payment in
lieu, then resume the meeting
 Tell the employee that the explanation has not been satisfactory and s/he is
terminating their employment, outlining the reasons with reference to
previous steps taken
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 Give the employee a dismissal letter
 Give the employee any information they need about payment,
superannuation entitlements etc.
 Explain whether the employee is to leave with notice or with pay in lieu of
notice
 If the employee is to leave immediately consider whether, for security
reasons, it is desirable for a senior manager to escort the employee to their
office and then from the premises.
After the dismissal the Committee member will:
 Write down what was said and what happened during the meeting.
Instant Dismissal
This will only be considered if an employee does the following activities at work:
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Theft
Physical assault
Sexual harassment
Intoxication
Use of illegal drugs (unless prescribed by a recognised medical practitioner)
Gross negligence
Illegal or fraudulent acts while on MDAA business
Wilful or malicious damage.
The Committee member will:
 Inform the employee promptly of the specific allegation/s against them
 Inform the employee that s/he will investigate the allegation/s promptly and
that they will have an opportunity to respond
 Inform the employee that they can have a friend or other support person
present when s/he discusses the allegation/s
 Undertake the investigation as soon as s/he is aware of the allegation/s and
speak to anyone who can shed light on them
 Consider the facts carefully after the investigation
 Discuss the allegation/s with the employee with a witness present and take
notes or record what is said
 Give the employee an opportunity to respond to the allegation/s
 Take time to consider the facts after the employee had responded
 Only terminate the employee’s employment if s/he is satisfied that the major
points of the allegation/s did take place and that the reason for termination
justifies instant dismissal from an objective point of view
 Write down what happened and what was said in the dismissal procedure
and put any notes made during or immediately after the termination in the
employee’s file
 Give the employee a letter confirming their dismissal and stating the reasons.
144
Sample Complaints Policy and Procedure - Rights in Action Inc.31
Policy
RIA acknowledges that all people seeking advocacy have the right to be heard on
issues of concern, undertakes to address all concerns and complaints made, and
to quickly work towards an outcome satisfactory to all parties. This will be done
without fear of retribution and in an equitable way. RIA believes that queries,
concerns and complaints provide valuable feedback about how the organisation
can improve its service.
People seeking advocacy have the right to:
 Have complaint pursued confidentially, objectively and with an aim towards
permanent resolution and elimination of the chance of repetition wherever
possible;
 Be told what avenues are open to them to resolve the complaint; and
 Have another person, friend or family member present to support them.
RIA Advocates have a responsibility to maintain complete confidentiality if they
provide information during the investigation of a complaint. Spreading gossip or
rumours could expose people to defamation action.
It is the responsibility of RIA staff to inform people seeking advocacy of this policy.
All people seeking advocacy will have access to the Complaints Policy.
Procedure
The following procedure ensures the efficient and accountable actions of RIA staff
and the Management Committee when responding to complaints (see figure on
following page):
 In the first instance, the person advocated for should try to address the staff
member with whom they have a complaint to negotiate a resolution.
 Where this is not appropriate or is unresolved, the person advocated for can
arrange to talk to the Service Coordinator. This contact may be made in
writing, by telephone or in person. The person advocated for can bring a friend
or family member to support them in this discussion. Written statements will be
disclosed to all parties.
 Within two working days, the Coordinator will arrange an interview with the
person. Details of the complaint and response will be documented and
documents signed by all parties
 If the complaint is still unresolved, the Coordinator will arrange a meeting
between those concerned to facilitate resolution. This should occur within 10
working days.
 If this is unsuccessful, or at the request of either party, the Coordinator may
either elect to involve a third, independent person to act as mediator or refer the
complaint to the President of the Management Committee.
31
Excerpt from Rights In Action Inc. Policy and Procedures Manual, Section 6: The Rights and Responsibilities of
People Seeking/Receiving Advocacy
145
 The person advocated for may elect to refer their complaint direct to the
President of the Management Committee.
 The President will take the complaint to a sub-committee (consisting of one
independent person and representatives of the Management Committee),
which will interview those concerned separately and privately within 10 days of
the complaint being made. The complaint and response will be documented.
 If this is unsuccessful, the sub-committee may elect to involve a third,
independent service to act as mediator. The referral for mediation must take
place within two working days.
 At any stage throughout the complaint process, the person advocated for may
seek external support and assistance (e.g. Complaints Resolution and Referral
Service, Anti-discrimination Commission Queensland, or a community
mediation service) to resolve his/her complaint. Similarly, the Coordinator
and/or Management Committee may request assistance or advice from
external parties.
(See following page for Complaint Procedure Time Frame Flow Chart)
Confidential records
Confidential records are kept of the complaint process. The documentation must
be stored securely so that the privacy of the person advocated for is protected.
People seeking advocacy may view documentation related to their own
complaint.
Extending timeframes
Timeframes for achieving stages of this procedure may be extended if there is
reasonable justification for doing so. Reasons for doing so must be clearly
documented.
Complaints Resolution and Referral Service
If the person advocated for is not happy with the way RIA addressed his/her
complaint, he/she should be encouraged to contact the Complaints Resolution
and Referral Service (CRRS) on 1800 880 052. CRRS is a service that helps
people with disability sort out complaints about advocacy services funded by the
Australian Department of Families, Housing, Community Services and Indigenous
Affairs. CRRS helps deal with complaints when a service is not meeting the
National Disability Services Standards or Disability Advocacy Standards.
When looking at a complaint, CRRS:
• Will talk to the person who makes the complaint;
• Will get the other side of the story;
• Will write a letter to the service;
• May investigate the complaint; and/or
• May hold a special conciliation meeting.
If the complaint is not solved, CRRS will inform the Department of Families,
Housing, Community Services and Indigenous Affairs. It is RIA’s responsibility to
inform the person advocated for that this service exists.
146
Complaint procedure time frame flow chart
147
7.2 Tools
Tool: Resources Complaints Handling – Guiding Principles based on the
Australian Standard on Complaint Handling (AS 4269 – 1995)32
1. VISIBILITY Information about how and where to complain should be wellpublicised to customers, personnel and other interested parties.
2. ACCESSIBILITY The complaints handling process should be easily
accessible to all complainants. This includes readily accessible information
about the process, flexibility in the methods of making complaints and special
arrangements and/or support for complainants with specific needs (including
interpreters).
3. RESPONSIVENESS Receipt of each complaint should be acknowledged to
the complainant immediately. Complaints should be addressed promptly;
complainants should be treated courteously and kept informed of the progress
of their complaint through the complaints handling process.
4. OBJECTIVITY Each complaint should be addressed in an equitable,
objective and unbiased manner through the complaints handling process.
5. CHARGES Access to the complaints handling process should be free of
charge to the complainant.
6. CONFIDENTIALITY Personally identifiable information concerning the
complainant should be available where needed, but only for the purposes of
addressing the complaint within the agency and should be actively protected
from disclosure, unless the customer or complainant expressly consents to its
disclosure.
7. INVESTIGATION OF COMPLAINTS Every reasonable effort should be
made to investigate all the relevant circumstances and information surrounding
a complaint.
8. CUSTOMER-FOCUSED APPROACH The agency should adopt a
customer-focused approach, be open to feedback including complaints, and
should show commitment to resolving complaints by its actions.
Paraphrased from the Australian Standards Customer satisfaction – Guidelines for complaints handling in
organizations (AS ISO 10002-2006), Disability Services Commission Consumer Liaison Service February 2007,
www.disability.wa.gov.au/dscwr/_assets/main/guidelines/documents/doc/australian_standards_guiding_principles.doc
32
148
9. RESOLUTION OF COMPLAINT Following an appropriate investigation, the
agency should offer a response, for example, correct the problem and prevent it
happening in the future. The decision or action taken regarding the complaint
should be communicated to the complainant as soon as the decision or action is
taken.
10. ACCOUNTABILITY The agency should ensure that accountability for and
reporting on the actions and decisions of the organisation with respect to
complaints handling is clearly established.
11. CONTINUAL IMPROVEMENT The continual improvement of the
complaints handling process and the quality of services should be a permanent
objective of the agency.
149
Tool: Setting up an Effective Complaints System33
1. Set up a group
Ask your staff/ volunteers and consumers/ people with disability and their
families about how they think the complaints system should work. You should
use this group as a resource throughout the development of your complaints
policies and procedures.
2. Show management support
You need a clear statement from the management of your agency about why
the complaints process is being set up. Outline the benefits for your agency
and for consumers. You should include this in a policy statement for your
agency.
3. Accept all complaints
There should be channels for people to complain about anything in your agency
that they think does not work or is unfair. Just by listening actively and using
good communication skills you can resolve many complaints on the spot. If you
have a complaints form, ensure that it is simple and easy to use for both
supported employees and staff.
4. Three levels of complaint handling
Informal – for simple straightforward complaints. Make clear your staff authority
to resolve such complaints as far as possible.
Formal – for more complex or serious matters which need to be referred to a
designated complaints person, a supervisor or manager.
External – for when complaints cannot be resolved internally. Consumers/
people with disability should have the opportunity to use external systems at
any time in your complaints process. For disability advocacy agencies and
employment services, the external complaints body is the National Disability
Complaints Resolution and Referral Service (CRRS).
5. Make it easy for consumers/ people with disability and others to
complain
You need to think about the accessibility of your complaints and resolution
procedures – Easy English, Auslan, interpreter, Braille, tape. Are your
procedures widely available and documented?
6. Record received complaints and comments
You should have a system for recording complaints, comments and
suggestions. This is an excellent tool for continuous improvement and helps you
keep a handle on what’s happening in your agency. It’s good to keep positive
feedback and distribute to your agency for morale.
7. Staff/ volunteer training
NSW Community Services Commission ‘An Easy To Follow Guide To Good Complaints Handling’, in Quality Strategy
Toolkit for Disability Employment and Rehabilitation Services, FaHCSIA
33
150
You should have a policy document that outlines your complaints system – both
the process and the philosophy. You need to ensure that your message is
getting across through staff meetings, newsletters, posters, training, induction
training, employment contracts and agreements.
8. Train your consumers/ people with disability
Your system is useless if your consumers/ people with disability, their families
and other members of the public don’t know about it. How can you best
communicate your complaints policy? Is it in a poster, a pamphlet, a
newsletter? Are the formats you are communicating in appropriate for the
target group?
9. Use your feedback to keep improving your agency
Monitor your complaints system – is it working? If you are not receiving
complaints, what does this mean? What are the complaints you are receiving
telling you about your agency’s operation?
151
Tool: Accessible complaints policy checklist34

Easy English. Policy is explained in easy-to-understand English, with clear
and short sentences, and in other formats appropriate to specific disability
as required (e.g. Braille). If a complex word or term is used, an easy
English definition is also provided.

Responsive and timely. Complaint is handled quickly and timeframes are
short and clear.


Process is clearly explained and easy to follow (e.g. Step 1, Step 2…).
Demonstrated commitment to resolution is in line with our agency’s vision,
aims and objectives.

Assistance is offered to consumers to lodge complaints.

Follow up. Complainant is kept informed of progress.

There is a good use of pictures that are age-specific and not childlike.

Referral and contact details are provided for external services where
complaint is unresolved or complainant chooses to go elsewhere.

Advocacy and other supports are encouraged throughout the process and
referral details provided if required

Flexible. Complaints can be received in a range of formats including
verbally.

Complainants are encouraged to try and resolve issue at the most local
level.

Policy has a statement about no retribution and that complaints are
welcomed, will be taken seriously and will be handled honestly, fairly and
without bias.

Confidential. Privacy of complainant and details of complaint is
maintained. Permission is sought from complainant if it is necessary to
discuss details with other stakeholders.

Other opportunities for feedback, including anonymous feedback, are
encouraged (e.g. suggestion box, focus groups, surveys).

There is a commitment to use information from complaints for
improvement.

Policy is regularly reviewed and the review date included.

Promotion. Policy is displayed and regular training is provided.

Record keeping. Policy has a statement about keeping all records of the
complaint, including file notes of discussions.
34
Quality Strategy Toolkit for Disability Employment and Rehabilitation Services, FaHCSIA
152
Tool: Local resolution meeting documents35
This document from the Complaints Resolution and Referral Service (CRRS)
includes an agenda, agreement form and meeting guidelines that may assist
your agency when you have a meeting to resolve a complaint.
MEETING AGENDA
Date:______________________________________________________
Venue: ____________________________________________________
Present:___________________________________________________
Purpose:

To come together in an atmosphere of cooperation, trust and
willingness to resolve the complaint.
To listen to, and gain a better understanding of, each other’s
views.
What has happened in the past cannot be changed but what is
worked out in the present and at this meeting will affect the future.
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Welcome and Introductions

Housekeeping egg: toilets, water, mobile phones

Meeting Guidelines – Complete MEETING GUIDELINES sheet
Key Discussion Points: Take turns to discuss each point and write down all
agreements.

_______________________________________________

_______________________________________________

_______________________________________________

_______________________________________________

Future Relationship and Communication – moving forward

Follow up
35
Complaints Resolution and Referral Service (CRRS) http://www.crrs.org.au/publications.html
153
MEETING GUIDELINES
Before the meeting:


Check that the meeting room is private, quiet and accessible

Allow enough time for the meeting. Clear your diary

Enter the meeting in good faith and with a positive attitude
During the meeting: Go through each point below and tick all agreed ones.


Agree to switch off any mobile phones to avoid distractions

Check time constraints. How much time do all parties have for the
meeting?

Acknowledge and thank everyone for coming and being committed to
resolving the complaint
Discuss and agree on the following guidelines:


Agree to listen to the other person’s point of view or side of the story
without interrupting or talking over.

When talking about your side of the story remember to say how you felt
and use ‘I’ statements

Agree to be respectful when others are speaking and use respectful
language

Agree to respect each other’s privacy and confidentiality. That is, what is
said in the meeting will not be talked about to others outside the meeting

Agree to be open and honest

Be objective; that is, put yourself in the other person’s shoes

Anyone can request a break at any time

Anyone can end the meeting at any time

All parties to be given a copy of the agreement
AGREEMENT
154
Date: ___/___/___
Parties to the Agreement:
Complainant: _______________________________________________
Advocate: __________________________________________________
Support Person: _____________________________________________
Service Staff:_________________ Position:_______________________
Service Staff:________________ Position:________________________
Agreements:
1.
_______________________________________________________
_______________________________________________________
_______________________________________________________
2
_______________________________________________________
_______________________________________________________
_______________________________________________________
3
_______________________________________________________
_______________________________________________________
_______________________________________________________
4.
_______________________________________________________
_______________________________________________________
_______________________________________________________
5.
_______________________________________________________
_______________________________________________________
_______________________________________________________
Signature:______________________________________
Signature:______________________________________
Signature:
155
Tool: Sample compliment/ complaints feedback form36
About you (if you want to make an anonymous complaint or compliment,
go to the next section)
Your details — please only provide the contact details that you are happy
for our staff to use to contact you.
Name: Mr/Mrs/Miss/Ms/Dr_________________________________________
Mailing address:________________________________________________
__________________________________________Postcode:___________
Email:___________________________ Mobile number:________________
Contact phone number during business hours:________________________
Do you have an advocate you would like us to discuss your complaint
with?
Yes
Name of representative:
__________________________________
Mailing Address: __________________________________________
Phone: __________________________________________________
Email: ___________________________________________________
No: _________
Please advise our office as soon as possible if any of your contact details
change.
About the respondent (who you are complimenting or complaining about)
I am complimenting/complaining about:
_____________________________________________________________
_____________________________________________________________
36
Rights in Action Inc.
156
Have you raised this compliment or complaint before?
If yes—what was the response, if any?
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
Your compliment or complaint
Please give us details of your compliment or complaint:
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
Please tell us what you would like to see happen as a result of your compliment
or complaint:
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
We undertake to respond to your compliment or complaint within one week of
receiving it. If you have raised a complaint, the timeframe for resolving your
complaint is explained in our complaints policy and procedure, which is
attached for your information
157
Tool: Complaints Register37
Establishment of a complaints register enables your agency to monitor your internal processes to ensure complaints and concerns
raised are addressed in accordance with the principles of natural justice. Where a significant issue/ concern is raised through informal
channels (i.e. is not a formally documented complaint) an entry should still be made in the register, in order for you to evidence your
practice. Where the action you take for resolution leads to a continuous improvement activity (e.g. a change in a policy or procedure),
this should be noted in Action taken column with reference to the allocated CQI ID #.
Complainant’s Contact
name
Details
Date
Issue/
complaint
concern raised
received
Action taken
Date
action
taken
Date of
resolution
/ closure
Date of
feedback
37
Disability Service Queensland, Introduction to Quality Management:
https://www.disability.qld.gov.au/key-projects/quality/documents/section-2-intro.pdf
158
Standard 8:
Agency management
Each agency adopts quality management systems and practices that optimise
the effectiveness of advocacy for each person with disability and facilitates
continuous improvement.
As Standard 8: Agency management is about the overall management system
of the disability advocacy agency, it connects all of the other Disability
Advocacy Standards. In this section of the Toolkit, the discussion of Standard 8
has been divided into six different subject areas:



8a: Corporate governance
8b: Quality management systems
8c: Continuous Improvement
o Developing Quality Networks
o Internal audits
 8d: Policies and procedures
 8e: Duty of care
 8f: Conflict of interest
In each of these areas you will find a discussion of overall considerations,
resources and case studies.
While these are important areas to consider under Standard 8, they are not
necessarily exhaustive, and you will also need to refer to the KPIs and
examples of evidence for this Standard.
8a: Corporate governance
Corporate governance can be described as:
The system by which companies are directed and managed. It influe nces how
the objectives of the company are set and achieved, how risk is monitored and
assessed, and how performance in optimised.
Good corporate governance structures allow companies to create value...and
provide accountability and control system commensurate with the risks
involved. 38
The corporate governance framework should ensure the strategic guidance of
the organisation, and the effective monitoring of management by the governing
body which is accountable to the organisation and its stakeholders.
Accountability includes how the organisation assesses itself against quality and
financial targets. The members should be equipped with the appropriate
knowledge, skills and training to fulfil their responsibilities, act in good faith with
38
ASX Corporate Governance Council, Principles of Good Corporate Governance and Best Practice
Recommendations, March 2003
159
due diligence and care and in the best interest of the organisation and
stakeholders.39
Features of good corporate governance40
There are some key features of good governance that should be central to an
agency’s corporate governance framework and should be included in
governance related documentation which may include organisational plans,
business plans, marketing plans, policy and procedures manuals, risk
management reviews and/or QA manuals. Features are described below.
Strategy setting and planning
Planning is a critical element of good governance. Overall strategy setting and
planning for your agency must be clearly documented and communicated.
Some points for good planning include:




The Board should establish the goals for your agency, in conjunction with
management, to provide the framework for planning
The plan should be ‘owned’ by your agency
Board members and management must be actively involved
Consultation with:
o Key stakeholders, including staff and consumers
o Funding bodies and key community contacts

Assistance from a specialist facilitator (this can have great benefits, but care
must be taken to ensure that the role is kept to facilitation and that the plan
does not become ‘owned’ by the facilitator).
Good planning helps clearly set the objectives, strategies and actions for a
period. It also provides a means to monitor your agency’s performance. Plans
should be regularly reviewed and updated given changing circumstances.
Risk management
Risk management is an important concept in agency management. The Board
should consider whether it has a clear risk management framework that covers
your agency’s operations.
Risk should be thought of in terms of what, and how, losses (or gains) may
affect your agency through a wide range of sources.
The Board is not directly responsible for risk management but is responsible for
ensuring that managers and staff of your agency have an appropriate risk
management framework in place to mitigate or reduce identified risks.
39
Standards in action: Practice requirements and guidelines for services funded under the Disability Services Act, NSW
Family and Community Services, 2011
40
National Disability Advocacy Program Quality Improvement Toolkit, FaHCSIA 2009
160
You should have an ongoing process to identify risk, assess its impact, take
treatment actions to address and/or monitor risk, and report this to the Board.
If your agency has never undertaken a formal risk assessment of its operations
or key aspects of its operations, it would be advisable to do so.
Consultation
Consultation with key stakeholders is an essential feature of good governance.
It enables the stakeholders to understand your objectives and strategies and
helps them to work with your agency in achieving those objectives.
Stakeholders might include:





Your funders
Local community
People with disability and their families/ carers
Staff/ volunteers
External stakeholders.
Roles and responsibilities
Board members need to clearly understand their role and responsibilities under
relevant legislation and the rules of incorporation. Your agency should develop
a documented policy describing the roles and responsibilities of the Board, of
individual Board members and of management. The policy should be clearly
communicated and understood by the Board, management, staff, consumers
and members of your agency.
Skills, independence and resources
The Board should have the right mix of skills to manage your agency’s affairs.
As an individual Board member it is difficult to have the expertise across all
areas, but you should have experience or skills in at least one of the following:
 Business acumen/ expertise
o Finance
o Marketing
o Management
 Other
o Legal
o Disability
Your Board should include people who are independent of the agency to
provide a balanced, objective representation on the Board. There should be a
balance in the number of Board members between those who meet the criteria
of independence and those who have a keen interest and advocacy
background.
The Board needs access to adequate and appropriate resources to ensure that
it can fulfil its roles and responsibilities effectively. There should also be an
161
induction process for new members to the Board so they are aware of their role
and responsibilities and understand your agency’s objectives and operations.
Conduct and ethics
In setting a standard that you expect people in your agency to work to, it is very
important that a Code of Conduct be established, which covers the Board
members, management and staff. The Code of Conduct should be developed
with management and staff.
Performance
You should have a process for assessing the performance of Board members.
As they are largely volunteers, the requirements should not be overly
oppressive and onerous, but it is important to have some formal means of
establishing an expected level of performance and to assess if it is being
achieved.
Means of performance measurement should be established based on the
definition of the roles of each Board member.
Succession planning
At some point in the future a successor will be required to continue the
management of your agency. If possible, the current manager should be
responsible for grooming other senior staff as potential successors.
However, if your agency does not have access to these resources, the Board
should be aware of this risk and review it and act accordingly.
The selection of a manager, whether internally or externally, should be based
on specific selection criteria and their qualifications, experience and suitability
for the role. If possible, the Board should develop the selection criteria in
consultation with the previous manager.
Financial and operational reporting
Timely financial and operational reporting is important in ensuring that you are
able to assess your agency’s performance and to assist in decision making.
Reports should incorporate not just actual achievements, but projected or
budgeted targets that should have been achieved.
Reporting should be against key actions in the business plans and against other
initiatives put in place by the Board. As a Board, you should establish an
agreed format for reporting to ensure that all matters that should be reported
are in fact reported.
Reports need to be made available to you allowing sufficient time to enable you
to properly consider them before Board meetings. Management should also be
available to present their reports to the Board meetings.
162
Audit committees
An audit committee’s role is to assist the Board in fulfilling its oversight
responsibilities for the financial reporting process, the system of internal control
over financial reporting, the audit process, and your agency’s process for
monitoring compliance with laws and regulations.
For larger agencies, an audit committee of non-executive (independent) Board
members can be useful in considering audit related issues in more depth than
would normally be undertaken by the full Board. However, the audit committee
should not act as a barrier between the auditor and the full Board or presume to
overtake the functions of the full Board.
Small to medium sized agencies may not require an audit committee.
163
Tool: Better practice corporate governance—checklist41
You can use this checklist to review your agency's current features and help to
identify any weaknesses that may require action.
Better practice feature
Assessment
Board roles, responsibilities and skills
Are the powers, roles, responsibilities and accountabilities of the Board,
the CEO and management clearly identified?
Are these responsibilities clearly communicated?
Who are they communicated to (e.g. each other, key stakeholders)?
Is there a good understanding of management’s responsibilities in
relation to internal control?
Is there a sound system of procedural and financial delegations
approved by the Board?
Does it promote efficiency as well as control?
Are appropriate decision-making processes adopted by the Board?
Is there a clear distinction between what decisions should be made by
the Board and what decisions should be made by management?
Are decisions that should be made by the Board, clearly documented
and understood?
Are there processes governing policy development, implementation and
review, which ensure that the Board approves new policy?
Is there a clear separation of roles and responsibilities between the
Board, the CEO and management?
Are appointments made to the Board with regard to the skill
requirements of the Board?
Are there adequate induction processes for new Board members?
Does the Board have, collectively, a mix of appropriate skills, knowledge
and experience covering:
 business acumen/expertise
 the industry within which the agency operates
 the services/products being provided by the agency
 policy development
 executive leadership skills
 finance
41
Adapted from Corporate Governance Handbook for Company Directors and Committee Members, FaHCSIA, 2nd
edition, 2010. Available at:
http://www.fahcsia.gov.au/sa/disability/pubs/general/CorporateGovernanceHandbook/Pages/Overview.a
spx
164
 marketing
 regulatory environment
 legal
 vocational training
 disabilities.
Independence
Is the majority of the Board independent of the CEO, management team
and commercial dealings with the agency?
Are there sufficient numbers on the Board to achieve independence, but
not too many to become inefficient?
Are there appropriate policies and procedures to identify any potential
conflicts of interest?
Are there adequate policies and procedures to deal with potential
conflicts of interest, once identified?
Board meetings
Are regular Board meetings held and are financial reports tabled?
Board resources
Do Board members have access to independent professional advice to
enable them to discharge their duties?
For companies, is there a company secretary with the primary role of
supporting the Board and chairperson?
Code of conduct
Is there a written code of conduct to be followed by the Board, CEO and
staff?
Is this code of conduct communicated and understood by the Board,
CEO and staff?
Are there clear guidelines in the code of conduct in relation to conflict of
interest?
Strategy setting and planning
Is there an overall organisational plan, and is it supported by a business
plan, budgets and marketing plan (if necessary)?
Are there clearly defined performance measures (operational and
financial) incorporated into the plans?
Does the Board approve the budget set by management, including any
budget revisions?
Risk management
Is there a risk management plan that is supported by risk management
strategies?
Does the Board regularly review the risk management strategies?
165
Are there any procedures for the Board to review the strategies and
assess whether they are working effectively?
Is the risk management plan reviewed regularly to ensure new risks are
identified and risk management strategies are put into place?
Financial and operational reporting
Are there appropriate performance measures, financial and nonfinancial, which enable the efficiency and effectiveness of the agency to
be assessed?
Are reports tailored to particular levels of responsibility?
Do reports efficiently and effectively communicate key financial data?
Are the financial reports prepared on a full accruals basis as required
under the Australian Accounting Standards (a requirement of the
Department of Families, Housing, Community Services and Indigenous
Affairs (FaHCSIA) Service Agreement)?
Do financial reports show a comparison between year-to-date, budget,
last year-to-date and full-year data?
Are financial reports supported by explanations of significant variations?
Are financial reports provided to the Board at least quarterly?
Are financial reports provided to the CEO at least monthly?
Are financial reports derived directly from the underlying accounting
systems and is there a QA process over the compilation of the reports?
Do adequate accounting systems and records support financial reports?
Are financial reports provided to the Board in sufficient time to enable
review before meetings?
Do members of the management team brief the Board when financial
reports are tabled?
Does the management team include a person with appropriate financial
management expertise and experience?
Does that person have a direct reporting line to the Board?
Board performance
Are there mechanisms to monitor performance of the Board and
individual Board members?
Audit committee—for larger agencies
Is there an audit committee?
Is there a charter for the audit committee covering such responsibilities
as:
 management and financial reporting
 compliance with laws and regulations
 maintenance of an effective audit function
166
 suitable risk management and internal control
 frameworks
 membership
 frequency of meetings
 committee authority
 Board reporting obligations.
Does the audit committee include a majority of independent (nonExecutive) Board members?
Do members of the audit committee have adequate financial and
accounting expertise?
Does the audit committee have unlimited access to internal and external
auditors and to senior management?
Does the audit committee have direct access to the Chief Executive
Officer, Chief Financial Officer and external auditor and internal audit?
Does the audit committee meet at least quarterly?
Does the audit committee review the status of all internal audit and
external audit recommendations and their implementation?
Do status reports summarise recommendations, officers responsible
and implementation dates?
Does the audit committee approve and monitor policies for risk
management, reporting and internal control?
Statutory accountability
Is there a process that identifies all legislation relevant to the
organisation, and monitors changes to the legislation and new
legislation impacting on the organisation?
Does financial and management reporting encompass reporting on
critical legislative compliance obligations?
Does the Board fully understand and continually assess its contractual
requirements under the terms and conditions of service agreements with
key
stakeholders, including the Department of Families, Housing,
Community Services and Indigenous Affairs (FaHCSIA)
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Tool: Sample business planning process42
Appropriate governance related documentation should also include a business
plan which is the product of a business plan process. A business plan should
include the documented goals, the strengths, weaknesses, opportunities and
threats and key objectives and strategies of your agency — all underpinned by
budgets and, where necessary, a marketing plan. A business plan should
support the overall governance related organisational plan. The following is a
suggested business planning process:
Establish team
 sub-committee of Board or portfolio director
 key management
 outside expertise
 define responsibilities for tasks
Determine overall goals and stakeholders



identify goals of agency by reference to objectives or corporate plan
identify key stakeholders
confirm goals and key stakeholders with Board
Carry out research





perform a SWOT (strengths, weaknesses, opportunities, threats) analysis
perform market analysis and consider strategies
undertake product or service research and development
identify current operations, resources, infrastructure and personnel
consult with stakeholders
Undertake financial analysis





compile historical financial data covering three years
estimate income/ costs of new initiatives or ventures
prepare financial forecasts for next three years
identify funding needs
assess viability of existing activities, new initiatives or ventures and identify
those to be pursued
Establish and monitor business plan





identify key objectives and strategies
identify key actions to achieve objectives and strategies
allocate responsibility
establish timeframe for actions
review and update plan
42
Adapted from Corporate Governance Handbook for Company Directors and Committee Members, FaHCSIA, 2nd
edition, 2010. Available at:
http://www.fahcsia.gov.au/sa/disability/pubs/general/CorporateGovernanceHandbook/Pages/Overview.a
spx
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Tool: Draft code of conduct for the Board43
The following sample code of conduct may be a useful base to tailor for your
agency, and is adapted from the code of conduct for members of the Australian
Institute of Company Directors. Other useful sources include, for example, AS
8000:2003 Corporate Governance Standards and the ASX Corporate
Governance Principles and Recommendations, 2nd edition 2007.
Code of conduct










A Board Member must act honestly, in good faith and in the best interests of
the agency as a whole.
A Board Member has a duty to use due care and diligence in fulfilling the
functions of their office and exercising powers attached to that office.
A Board Member must use the powers of their office for a proper purpose,
in the best interests of the agency as a whole.
A Board Member must recognise that the primary responsibility is to the
agency as a whole but should, where appropriate, have regard to the
interests of all stakeholders in the agency.
A Board Member must not make improper use of information acquired as a
Board member.
A Board Member must not take advantage of being in the position of a
Board member.
A Board Member must not allow personal interests, or the interest of any
associated person, to conflict with the interest of the agency.
A Board Member has an obligation to be independent in judgment and
actions and to take all reasonable steps to be satisfied as to the soundness
of all decisions taken by the Board.
Confidential information received as a Board Member in the course of
exercising those duties remains the property of the agency from which it
was obtained and it is improper to disclose it, or allow it to be disclosed,
unless that disclosure has been authorised by that agency, or the person
from whom the information is provided, or is required by law.
A Board Member should not engage in conduct likely to bring discredit to
the agency.
A Board Member has an obligation, at all times, to comply with the spirit, as well
as the letter, of the law
43
Adapted from Corporate Governance Handbook for Company Directors and Committee Members, FaHCSIA, 2nd
edition, 2010. Available at:
http://www.fahcsia.gov.au/sa/disability/pubs/general/CorporateGovernanceHandbook/Pages/Overview.a
spx
169
8b: Quality management systems
The NDAP QA system requires disability advocacy agencies to have a
quality management system (QMS) in place as part of compliance with
Standard 8. Quality assurance (QA) provides confidence that the Disability
Advocacy Standards are being met and maintained. QA incorporates the
basic components required of a quality system by ensuring internal (selfassessment) and external (certification) assessments are undertaken, together
with the processes in place to control the components of the quality system.
With a quality management approach, continuous improvement systems are
added to QA by incorporating a quality cycle of continuous improvement. Unlike
QA, where the goal is to meet the specified standards, quality management is
seen as an ongoing journey of continuous improvement. A quality
management system is designed to provide evidence that a specified standard
of quality has been met and continuously improved.
Quality management system44
Disability Sector Quality System, Partners in Quality – Resources and Guide, Queensland. Available at:
http://www.communities.qld.gov.au/disability/key-projects/disability-sector-quality-system/publicationstools-and-resources/resources/partners-in-quality-resources-and-guide
44
170
The above diagram illustrates how QA (standards, documentation,
standardisation of process, process control and planning and evaluation)
combined with continuous improvement (leadership, consumer focus,
participation, a culture that embraces change) lead to quality management.
Quality management in agencies delivers outcomes for people with disability
which are a measure of the quality of advocacy support.
There is no set formula for a QMS for a disability advocacy agency. Factors
including the size, type, location and maturity of the disability advocacy agency
will influence the design and development of their QMS.
Quality management principles
One of the key principles of the International Standard 900045 for Quality
Management Systems is that identifying, understanding and managing interrelated processes as a system contributes to the organisation's effectiveness
and efficiency in achieving its objectives. Key benefits include integration and
alignment of the processes that will best achieve the desired results, and
providing confidence to interested parties as to the consistency, effectiveness
and efficiency of the organisation.
The driving principle is commonly accepted as customer or consumer
satisfaction. Quality is not something that occurs as an independent activity —
it needs to be designed into all elements and functions of the organisation, and
then systematically controlled. Objective evidence of a quality system is
provided through its documentation (which standardises processes and
procedures), through monitoring of how personnel within the organisation
implement and control those procedures, and from recorded feedback from
service users. A quality management system therefore recognises the
interrelatedness of the key components of paper, process and people in
contributing to quality.
Consumer satisfaction comes from agencies knowing what people with
disability want, and developing systems and processes to incorporate
responses to individual needs. Focusing on the consumer and identifying
his/her wants and needs is essential to delivering effective quality services.
Once we have documented our processes to standardise them, we then need
to continually monitor their effectiveness. Where variation is identified, or a
process is shown to be ineffective, an opportunity for improvement exists.
Significant benefits accrue through organisation-wide involvement in the quality
system, including an increased understanding of all systems of the organisation,
and their interdependence. Participation provides opportunities for service
45
http://www.iso.org/iso/iso_catalogue/management_and_leadership_standards/quality_management/qmp/qmp-5.htm
171
users, staff and management to share knowledge, skills and experiences; to
learn through review and improvement; and to share successes. This concept is
equally true for both small and large agencies.
It is important to recognise that, when you adopt a quality management
approach, quality is not something you can put in place and just forget. It is not
like an obsolete policy document on the shelf. Quality management is a journey,
not a destination. Quality viewed as a destination is really QA, where you are
aiming to meet a required standard, with no commitment to improvement. QA is
more applicable when your output is a product. However, where your output is
the delivery of support to people with disability, quality becomes an ongoing
journey. The concept of quality improvement needs to be embedded in all levels
of your agency. A good starting point is to include quality improvement as a
standing agenda item on all management committee meetings and team
meetings.
Anecdotal evidence from the disability sector suggests that many providers
believe they do provide quality support with a strong focus on consumers.
However, some of what they do is not documented or formalised. The
disadvantage of informal systems is their lack of sustainability. They are highly
dependent on the knowledge of key individuals within the agency and this
leaves your agency and its service users vulnerable. Small agencies typically
rely on informal systems, presenting a significant risk that corporate knowledge
will be lost in the event of the resignation of a key person. The establishment of
formal systems reduces your disability advocacy agency’s exposure to risk.
A quality system framework should include:
 Formalisation of your agency’s plans, policies and procedures;
 Documentation of processes and practices such as position descriptions,
work instructions, forms, schedules, meeting minutes and system controls;
 A range of formats, such as videos, electronic systems, flowcharts etc.; and
 Compliance with legislative and statutory requirements, necessitating
development of mechanisms to monitor regulatory changes to ensure that
adjustments to policy and practices are made when appropriate.
However, it is the processes adopted to implement the system which are of
critical significance in ensuring that the quality initiative is effective and
sustainable.
The ‘systems approach’
A system can be defined as inter-related processes and their support structures
(e.g. documentation, resources) put in place to achieve a specified purpose. A
system is static. It IS.
172
Processes are the series of steps, and the resources needed, to complete a
task. Processes ‘add value’, or transform the inputs of the system to create the
desired output. They are goal-oriented, with the desired outcome directing the
process. A process is dynamic. It DOES.
Disability advocacy agencies have many systems, such as a system for
accessing advocacy, individual needs and planning, information management,
grievances and complaints, financial management, maintenance, and human
resource management. Some will also have sub-systems. For example, your
human resource management system will have sub-systems for recruitment,
selection, orientation, staff training, performance management, grievances etc.,
each of which will have its own processes.
Once you start thinking in terms of systems and processes, the
interdependence of all sections of your agency become increasingly clear. The
systems model encourages a planned (rather than an ad hoc) approach. It
reminds us to set clear goals, plan what activities we need to undertake to
accomplish those goals, monitor and evaluate the effectiveness of activities,
and use evaluation findings to inform continuous improvement.
A ‘systems approach’ to management is simply a way of thinking that helps us
to link continuous improvement to all internal processes or activities. In each
stage of a system there will be processes which require monitoring for
opportunities for improvement. It is the combination of all of an organisation’s
operational systems that form the overarching ‘quality system‘. While adoption
of a quality system may necessitate considerable effort and organisational
change, it is planned change that has purpose and direction. When the
decision to adopt a quality management approach is related to perceived
benefits in outcomes for people with disability, rather than a sense of external
imposition, acceptance and involvement is likely to be higher.
What we are aiming to do in applying principles of continuous improvement is to
improve efficiency (by identifying critical points and controlling for variation) by
maximising our use of resources, and to improve effectiveness (by identifying
individual needs, and developing appropriate responses to achieve improved
outcomes). Both may require changes to existing processes in order to gain the
desired result.
173
Tool: Continuous Quality Improvement Register46
Use this template to record suggestions/ issues for improvement to your agency, who the issue was raised by and the improvement activities that will address the
issue and when the activity is complete. Where an activity does not achieve intended results, plan and record a new activity. Use this form to keep a summary
of, and track, improvements (while your continuous improvement plans will contain more details). Some examples are included in the sample below.
CQI ID#
Date
Source
Issue
Improvement activity/ies
Closure
CQI 01
30/5/04
Consumer assessment
Opportunities for consumer input
into policy development
Establish a monthly representative
consumer forum, comprised of individuals
nominated by other consumers
Date of first
forum
meeting
CQI 02
5/6/04
Complaint
Dissatisfaction with staff member
Review staff allocation rosters and replace
the member allocated to that consumer
Date of new
roster
CQI 02
18/6/04
WH&S Committee
Audit of 15/6/04 identified that
access to fire emergency exit door
was blocked by stored equipment
Clear impediments to emergency exits.
Review fire safety requirements at team
meeting of 20/6/04. To be reassessed
during next WH&S audit
Date of
satisfactory
audit
Disability Sector Quality System, Partners in Quality – Resources and Guide Queensland. Available at:
http://www.communities.qld.gov.au/disabiltiy/key-projects/disability-sector-quality-system/publications-tools-and-resources
46
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Tool: Quality Monitoring Schedule47
This template can be used to record your planned annual schedule to enable you to evidence your commitment to quality control and ongoing
quality improvement. Some examples of the major monitoring activities that require the planning and allocation of resources are included in the
sample below.
Review subject
Process
Planning
e.g. Strategic Plan
Annual management/ staff planning day
Document review
e.g. review of all policies and
procedures for continuing applicability
Performance
e.g. staff performance reviews
Suppliers
e.g. quality monitoring of suppliers
Assets management monitoring
e.g. assets management and
maintenance
Review for effectiveness and currency and re-endorse during
annual planning
Records
e.g. consumer records system
Agency quality/ improvement
Who
When
Committee and
Staff
Month due/ date
Committee and
staff
Month due/ date
CEO/ Manager
CEO/ Manager
Month due/ date
Month due/ date
Manager &
treasurer
Month due/ date
(prior to AGM)
Month due/date
Performance appraisal process
Contract review of requirements and performance
Review of Assets Register and updating of warranty details and
depreciation
Audit of maintenance schedules for continuing effectiveness
Random survey of 10% of consumer records against policystipulated content requirements, clarity of entries, security,
currency/ archiving procedures
a) Staff Satisfaction survey
Manager
Manager
Month due/ date
CEO/Manager
Month due/ date
Disability Sector Quality System, Partners in Quality – Resources and Guide Queensland. Available at:
http://www.communities.qld.gov.au/disabiltiy/key-projects/disability-sector-quality-system/publications-tools-and-resources
47
175
e.g. Staff Satisfaction/ retention rates/
levels
b) Review of retention rates/ reasons for leaving for CQI
planning
Consumer satisfaction
a) Survey of consumers/ people with disability to assess
awareness of their rights, satisfaction levels, and suggestions for
improvements.
b) consumers/ people with disability agency assessment
process
a) Review of Continuous Quality Improvement (CQI) Register
(template available in this Toolkit), Quality Improvement Plan
and minutes of meetings to ensure actions have been recorded
b) consumers/ people with disability planning forums
Program Managers
Complaints
Review Complaints Register for patterns/ trends emerging, and
actions taken for continuous improvement
CEO/ Manager
Workplace Health and Safety
e.g. staff/ consumers safety and
regulatory compliance
a) Standing agenda item for management meetings for review
of accidents/ incidents
b) Internal environmental safety compliance audits against
documented procedures
c) Fire safety environmental audits and inspection of equipment
d) Electrical equipment checking and tagging
a) Preparation and submission of reports against funding
agreement requirements
b) Annual acquittals and financial reporting to funding bodies
Management
Month due/ date
WH&S officer
Month due/ date
Fire Department
WH&S
CEO/ Manager
Month due/ date
Month due/ date
Month due/ date
CEO/ Manager
Month due/ date
Continuous improvement
Accountabilities/reporting
e.g. reporting to funding bodies
Month due/ date
Month due/ date
CEO/ Manager
Month due/ date
176
Tool: Action Minutes Format for Meetings48
A format like the one below for recording minutes of meetings ensures that decisions made are recorded in a way that facilitates follow-up in
matters arising from the previous minutes. Where an issue is raised requiring an improvement activity, it should then be transferred to your
continuous improvement plan. Tasks not completed by the due date are referred to the following meeting, under the same identification number
(ID#), until it is closed out.
Name of meeting
Date/ time
Names of those present
Apologies received
Acceptance of minutes of last meeting
Matters arising
ID #
Issue
Action to be taken
Person responsible
Date for reporting back
Person responsible
Date for reporting back
Task completed
Correspondence in/ out
Presentation and tabling of reports
New business
ID #
Issue
Action to be taken
Disability Sector Quality System, Partners in Quality – Resources and Guide Queensland. Available at:
http://www.communities.qld.gov.au/disabiltiy/key-projects/disability-sector-quality-system/publications-tools-and-resources
48
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Tool: Document Control Register49
Use this template to control your agency’s key documents e.g. policies and procedures that are part of the management system – the
register is used to record whether documents are up-to-date, where they are located and specifications for limited access.
Disability Services Queensland suggest a good strategy for effective information management is to include in the footer of each
document its electronic file path, the document control number, and the date of issue. A separate Records Register is suggested for
records which are separate to documents, and include forms, consumer files, meeting minutes, financial records etc. A Records
Register should show the type of record, its retention time, access controls, archived location and disposal method.
ID #
Policies,
Procedur
es
Document title
Name of document
Access
Any security access
codes required, or specify
limited access
Electronic file pathway
File location
Date last
reviewed
Should be
consistent
with date in
document
footer
Archived
Location of
archived
documents
Disposal
method
Disposal
method, e.g.
shredding
Adapted from Disability Sector Quality System, Partners in Quality – Resources and Guide Queensland. Available at:
http://www.communities.qld.gov.au/disabiltiy/key-projects/disability-sector-quality-system/publications-tools-and-resources
49
178
Tool: Risk Analysis Likelihood Matrix50
This risk analysis matrix enables you to analyse the potential risk of an activity/ event. By considering both the probability of an
incident, and its likely consequence should it occur, you are able to allocate a risk rating. Where the risk is extreme or high, immediate
action should be taken to mitigate the risk.
Disability Sector Quality System, Partners in Quality – Resources and Guide Queensland. Available at:
http://www.communities.qld.gov.au/disabiltiy/key-projects/disability-sector-quality-system/publications-tools-and-resources
50
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8c: Continuous improvement considerations
Continuous improvement model
Continuous improvement operates at two levels:


Individual agency levels—looking for improvements in your agency’s
processes and practices
Industry level—looking for improvements across the sector as a whole.
Ideally, these are closely related so that information about successful
innovations within one agency is shared across the sector, and areas of general
underperformance are identified so that appropriate training and support can be
provided. In this model (illustrated below), continuous improvement can be
thought of as two interacting circles: an inner circle of continuous improvement
applied in unique ways by individual agencies and another circle of sector-wide
capacity building and support.
Continuous improvement model
The diagram above refers to the linkages between ‘good’ practice and
benchmarking. The intent of ‘good practice’ is for agencies to gather insight and
information via comparison with like agencies with a view to better, more
180
efficient and effective methods and approaches to identify and implement the
good practice.
Benchmarking is one aspect of good practice. Methods can include
approaching like-minded agencies which have a similar operation, or to involve
an industry group to form a task group to review an industry wide process.
However, the transfer of good ideas and approaches has to be thoroughly
tested, including the fit into the organisation culture. Another consideration is
innovation. If everyone copies ‘good practice’ everyone may behave in the
same way. Sometimes you may want to at least trial something that is different
and innovative.51
Develop a quality network - planning for excellence
In addition to planning continuous improvement activities in your disability
advocacy agency relating to the Disability Advocacy Standards, your agency
should also consider the wider context in which you can develop quality
practices by developing a quality network.
A quality network is a group of similar organisations that works together to
continuously improve the quality of their advocacy support. Participating in a
quality network can provide opportunities to:




Discuss common problems
Work together to find solutions
Generate 'best practice' tools and ideas'
Share the cost and administration of joint events, such as:
o Training
o Information sessions
o Guest speakers
51
The rise and fall of the best practice method, Derek Stockley. Available at:
http://derekstockley.com.au/newsletters-05/042-best-practice-consulting.html
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Tool: Sample process for developing a quality network52
This sample process outlines the key steps to establishing a quality network, a
group of local agencies who collaborate for reasons including developing quality
management systems and addressing QA issues. The sample process outlines
the elements your disability advocacy agency will need to consider from
practical matters of where and when meetings will be held to issues such as the
structure or purpose of the group.
a. Determine the type of quality network that you want
For example, what do you want to achieve? Do you want to:
 work on developing a quality management system?
 address QA issues?
 work with agencies with a similar work output etc.?
Goals:
_____________________________________________________________
_____________________________________________________________
_____________________________________________________________
_____________________________________________________________
b. Identify potential agencies
Identify agencies that you would like to develop a quality network with.
Name:
Contact Information:
If you do not know any appropriate agencies to develop a network with,
contact:
 Department of Families, Housing, Community Services and Indigenous
Affairs (FaHCSIA)
 NDS (National Disability Services):
 DANA (Disability Advocacy Network Australia):
c. Decide on a structure
For example, will the quality network be:
1.
action based?
2.
for information sharing?
3.
for resource sharing?
52
Quality Strategy for Disability Employment and Rehabilitation Services, FaHCSIA. Available at:
http://www.fahcsia.gov.au/sa/disability/pubs/Documents/quality_strategy_toolkit
182
Structure:
_____________________________________________________________
_____________________________________________________________
_____________________________________________________________
____________________________________________________________
d. Set up the network
Here are some key elements to consider when developing a meeting system,
with examples of what you might choose to do.
Where: (For example, choose a mutually convenient venue, or if the agencies
in your network operate near one another, each agency could take a turn
hosting the meeting at their premises.)
When: (For example, meet once every month for one day, or 4–5 hours,
allowing for travel time.)
Who is responsible: (For example, have each agency in turn be responsible
for running the meeting and appointing a chairperson.)
What will be done at each meeting:
For example, for a quality network you could:
 have each monthly meeting focus on a particular quality theme. In this way,
you will have achieved a complete review of the quality themes within a
calendar year.
 identify which quality theme will be discussed at the meeting. Request that
all attendees bring material for discussion relating to that quality theme,
such as queries, barriers, obstacles, best practice examples and ideas for
evidence gathering. Request the chairperson of the meeting (or another
member of their agency) research and prepare an overview of the quality
theme to present to the group).
____________________________________________________________
____________________________________________________________
____________________________________________________________
____________________________________________________________
____________________________________________________________
____________________________________________________________
____________________________________________________________
e. Conduct your meetings
For example, for a quality network:
183
 chairperson presents an overview of the quality theme to the group.
 group members discuss and share their practices and experiences relating
to this quality theme.
 group members work through any tools or resources relating to the quality
theme that agencies may have (including the Toolkit).
 identify any gaps in knowledge in the group. You may wish to seek outside
help (for instance, a guest speaker, consultant or trainer) to help your
network develop in this particular area.
Agreed meeting structure:
______________________________________________________________
______________________________________________________________
______________________________________________________________
______________________________________________________________
______________________________________________________________
______________________________________________________________
______________________________________________________________
f.
Develop the network
Review the progress of your network to adapt to changes in the aims and
goals of network agencies. The focus of your network should change to reflect
new directions and changing needs.
Document future directions:
______________________________________________________________
______________________________________________________________
______________________________________________________________
______________________________________________________________
______________________________________________________________
______________________________________________________________
______________________________________________________________
______________________________________________________________
______________________________________________________________
______________________________________________________________
______________________________________________________________
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Internal audits
Continuous improvement is one of the key components of the Quality Strategy.
Continuous improvement should be part of the day-to-day life of your agency.
Although it is not mandatory, it is highly recommended that agencies implement
a system of internal audits against the Disability Advocacy Standards. Internal
audits are a means of checking that your agency’s systems processes and
procedures are working as intended, reviewed regularly and amended as
necessary. Internal audits are a strong demonstration of evidence of
continuous improvement for Standard 8.
Internal audit tips from a Certification Body
The internal audit process does not need to be complex, and can be integrated
into the operations of each disability advocacy agency, rather than as a one-off
yearly activity.
The ‘Things to Consider’ for each Standard in Section 4 are recommended as a
useful checklist for internal audits. To check that processes are implemented,
your agency could use the ‘Things to Consider’ checklist, obtain a sample of
files, check to see that what is supposed to happen is actually happening, check
that procedures are current and being followed, provide areas for improvement,
and report to management. As files generally follow the entry to exit process for
a consumer, it is far easier to follow the process flow rather than checking
standard by standard (note that standard by standard is useful to check if
documentation is in place). Process flows could be identified for a range of
processes, e.g. consumer related processes, human resource processes,
governance processes, finance/purchasing processes etc.
Tool: Sample process for systematic internal audits53
This sample process describes one systematic way of conducting regular
internal audits against the Disability Advocacy Standards.
Month-by-month actions
January:
 Arrange meeting process
 Assess your agency's performance against Standard 1: Advocacy access
 Convene an internal audit committee meeting with representation from
consumers, staff, management and the Board of your agency. At the initial
meeting you should:
o determine a regular meeting date for each month
o arrange for minutes to be taken for each meeting
o arrange for outcomes to be reported to the Board with a list of actions to
be addressed.
53
Quality Strategy Toolkit for Disability Employment and Rehabilitation Services, FaHCSIA. Available at:
http://www.fahcsia.gov.au/sa/disabiltiy/pubs/employers/Documents/quality_strategy_toolkit
185




Assess your agency's compliance. Use the self-assessment worksheets (in
Section 4) and the internal audit worksheet to assess your agency's
compliance with and continuous improvement against the Standard. Other
information you could use to assess your agency includes:
o de-identified information from your complaints register
o feedback from people with disability
o issues identified by other meetings/committees in your agency (e.g.
occupational health and safety (OH&S) committees, management
committees)
o observations contained in the report from your certification audit or
annual surveillance audit.
Develop a priority list of actions to be completed against the Standard.
Document actions to be taken on a 'continuous improvement register',
which should include the following information:
o Action to be taken
o Person responsible
o Anticipated timeframe
o Action completed?
Appoint a designated person to be responsible for updating the register at
each monthly meeting.
February:
 Assess your agency's performance against Standard 2: Individual needs.
 Follow-up actions from the previous meeting
o Convene an internal audit committee meeting.
o Assess your agency's compliance with and continuous improvement
against the Standard.
o Develop a priority list of actions to be completed against the Standard
and document them on the 'continuous improvement register'
o Follow-up actions added to the register at the previous month's meeting.
o Document the results of actions.
March:
 Assess your agency's performance against Standard 3: Decision making
and choice.
 Follow-up actions from the previous meeting.
o Convene an internal audit committee meeting.
o Assess your agency's compliance with and continuous improvement
against the Standard.
o Develop a priority list of actions to be completed against the Standard
and document them on the 'continuous improvement register'.
o Follow-up actions added to the register at the previous month's meeting.
o Document the results of actions.
April onwards:
Continue to use this process throughout the year, assessing one Standard for
each month and documenting and tracking actions taken against each
Standard.
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Internal audit worksheets
You can print out these internal audit worksheets and use them as templates to
plan and document continuous improvement activities for your agency under
each KPI of the Disability Advocacy Standards.
You may wish to distribute them among staff, management and people with
disability/stakeholders. This task could be shared out, with individuals or work
groups taking on the internal audit of specific Standards.
You may wish to attach an extra page if you need more space for your
response. It is important to think about documenting evidence of your actions
towards each KPI. You may wish to refer to the name and/or number/date of
relevant policies and procedures, or attach copies of these policies and
procedures to your worksheets, which could then be provided to your
Certification Body. Evidence should be in the form of actual outcomes and
achievements.
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Internal Audit Worksheets
Standard:
KPI:
What are our planned actions for meeting the requirements of this
KPI?
Policies, procedures and management systems
What improvements have we tried or made in the past 12 months?
Things tried or done in the past 12
months
Key learning/insights
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What are our claims about our current performance in this area?
Strengths (what we do well)
Weaknesses (areas to improve)
Do we comply with the requirements of this KPI?
Evidence that demonstrates our
compliance
Areas where we need additional evidence or
changes to our management systems
What are our priorities for continuous improvement over the next 12
months?
Planned actions
Anticipated results
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Standard:
KPI:
Using the activity of the previous page, document the continuous improvement actions your agency plans to take in relation to this KPI.
Action to be taken
Person responsible
Timeline for action
Date completed
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8d: Policies and procedures
As part of strong agency management, your disability advocacy agency should
have written policies and procedures. These policies and procedures should
relate specifically to the requirements of the Disability Advocacy Standards, as
well as other relevant operations of your agency.
Here are some considerations to help you to improve your agency's practices in
this area
Review:
Do we have a set of written policies and procedures?
Could we improve our policies and procedures?
Do our policies and procedures reflect the content of the Disability
Advocacy Standards?
Who is responsible for reviewing our policies and procedures?
How often are our policies and procedures reviewed?
How frequently are staff and people with disability trained in the
requirements of our policies and procedures?
Do we review whether policies and procedures are implemented?
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Sample Policy: Policy Format54
This is a sample policy format that can be used as a basis when developing
your policies.
Policy Number (as entered in Document Control Register):
POLICY TITLE
(N.B. Enter electronic file path and date of endorsement/ currency in the
document footer and in the Document Control Register)
POLICY STATEMENT
The policy statement/ purpose provides the direction and rationale.
SCOPE
The scope may need to be specified to clarify applicability (e.g. are any program
areas exempted from any clauses, where specific criteria may apply for their
agency type — otherwise, delete this heading).
PRINCIPLES
Explicit values which drive this policy. They may link to agency values,
constitutional objects, or principles of practice etc.
REFERENCES
Identify regulatory or situational references (e.g. QDSS, strategic plan, crossreferenced policies, legislation/ regulations, Australian standards).
ATTACHMENTS
Controlled forms mentioned in the procedures, which form part of this policy.
Delete if not applicable.
PROCEDURAL FRAMEWORK
1.
Heading
1.1
Sub-heading if more than one element to this procedure
Identification of clauses under this heading.
Disability Sector Quality System, Partners in Quality – Resources and Guide, Queensland. Available at:
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8e: Duty of care
Duty of care is a hot topic for disability agencies. Legally, we all have a duty to
take reasonable care not to cause foreseeable harm to other people or their
property. This is also known as the law of negligence.55
Key areas for consideration in relation to duty of care could include:
1. to whom do you have a duty of care?
2. what is your duty of care to everyone in, or associated with, your
agency?
3. what would you as a reasonable person do/ not do to ensure that as far
as possible there is no breach of duty of care, and that no one will suffer
harm or loss because of your actions/inactions?
4. what regular, ongoing and documented training do you provide to ensure
that individuals at all levels of your agency make informed decisions
about things that could harm them?
Simple framework for duty of care
The framework above is a useful tool for thinking through, in a group, issues
related to duty of care in your agency. The key is to balance the rights of all
stakeholders with possible risks. Training is critical to help minimise risk to all
stakeholders and to ensure all stakeholders are informed of the potential risks
and benefits involved.
It is important when considering duty of care to consult your own state or
territory legislation.
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8f: Conflict of interest
Standard 8 requires that the disability advocacy agency is structured and
operates independently in such a way as it is free as possible from conflicts with
other service provision and the interests of people with disability.
Sample Policy: Management Conflict of Interest56
Conflict of Interest Register:
Our agency will maintain a conflict of interest register, where all staff,
management Committee members and volunteers will declare any personal or
professional interests that may give rise to a conflict. The conflict of interest
register will be publicly available.
To minimise conflict of interest, our agency will:
 Not provide direct disability services (e.g. day programs, recreation,
accommodation, employment, equipment services etc.). The agency will,
however, provide disability information as part of the advocacy process. The
agency may undertake projects such as research and training, provided they
do not compromise its ability to independently advocate for people with
disability
 Ensure that Management Committee members serve as individual members
and not as representatives of other agencies (e.g. direct disability service
providers)
 If individual Committee members, staff members or volunteers are aware of
associations or situations that may potentially cause a conflict of interest they
must declare this interest and remove themselves from the decision-making
process
 Ensure that individual advocacy matters are not taken to the Committee as a
whole, nor are they discussed with individual Committee members unless a
Committee member is providing supervision or professional advice with the
consent of the consumer
 Management Committee members shall not be paid employees of our
agency. If a Committee member wishes to apply for a paid position, he or
she must first resign from the Committee. Generally, a Committee member
will not be immediately replaced in this situation and is free to re-apply to be
a Committee member if he or she is not employed
 Wherever possible Management Committee members shall not be active
operational volunteers (e.g. volunteer advocates, office support volunteers) of
our agency. However if this does occur, such Committee members should
closely adhere to our agency’s conflict of interest policy and must declare this
interest and remove themselves from the decision-making process
 People with disability and their carers are strongly encouraged to be
Management Committee members. If a Committee member is also a
consumer of our agency and they are involved in a complex personal
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advocacy matter (i.e. a high level of conflict) a Committee member may stand
down or resign from the Committee if there is a possible conflict of interest.
A Committee member should discuss any such concerns with the
Management Committee as a whole or with the President before making this
decision.
Disability Advocacy Policy: Consumer–Advocate Conflict of Interest
Where a consumer–advocate conflict of interest arises:
 The affected consumer will be made aware of the potential for conflict of
interest
 The affected consumer will be involved and consulted in any decisions about
appropriate actions
 Our agency will offer the consumer a referral to an alternative agency or
advocate.
Where either the consumer or the advocate feels that advocacy activities will be
compromised by the potential conflict of interest, the consumer should be
referred to another agency or advocate. Once the consumer has been provided
with the full information of the circumstances of the conflict of interest, the
consumer can decide to continue using our agency with the existing advocate.
Consumer – Consumer Conflict of Interest
Our agency will sometimes encounter situations where there are dilemmas for
advocates involved in assisting consumers with conflicting needs. To deal with
this issue:
 Our agency will make a check of its consumer records to see if there is a
conflict of interest before offering assistance
 If there is a conflict of interest our agency will normally assist the first person
who has come to it for assistance
 Our agency will inform the other person why it cannot assist. The agency will
then assist the person to find an alternative advocate.
Conflict of Interest – Person with a Disability – Carers
Our agency tries to assist both carers and individuals with a disability in the
advocacy process. However, if there is a conflict of advice from the carer and
person with disability, our agency will in general take the advice of the person
with disability.
Sexual Relationships with Consumers
Staff (including volunteers) should under no circumstances engage in sexual
activities or sexual contact with consumers whether such contact is consensual
or not. Staff (including volunteers) should not engage in sexual activities or
sexual contact with relatives of consumers or other individuals with whom
consumers maintain a close personal relationship when there is a risk of
exploitation or potential harm to the consumer.
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Gifts and Other Benefits from Consumers
Staff (including volunteers) should be conscious of the perception to others of
accepting gifts and other benefits. Staff must not solicit or accept anything of
value from a consumer or associate which might interfere with their
independence and the conduct of their duties and responsibilities. The very
acceptance of a gift may create the perception that staff member’s
independence and integrity has been compromised.
In general, gifts of any type should be politely declined. However, a token gift
may be accepted if there are circumstances where it would cause offence or
disrespect to the gift giver to refuse the gift or where it may jeopardise the
positive working relationship with the person. An example of a token gift might
be flowers, chocolates, home-made produce, and modest refreshments etc.
with a value of no more than $50. If a staff member is unsure about the status
of a particular gift he or she should discuss with the Coordinator.
Staff (including volunteers) should not enter into any financial transactions or
arrangements with consumers. Examples of a financial transaction with a
consumer may be purchasing agency/ equipment or accepting a loan of money/
goods. If there is any doubt, the staff member should discuss the matter with
our agency management.
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Standard 9:
training
Staff, recruitment, employment and
9.1 Sample policies and procedures
Sample Policy: Staff Recruitment, Employment and Training57
Equal Employment Opportunity Policy


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Our agency will encourage appropriately skilled and qualified people with
disability (along with people from other disadvantaged groups) to apply for
positions
All reasonable accommodations will be made to ensure that employees with
a disability are able to undertake the inherent requirements of their position
Our agency will ensure the selection process is merit-based by developing
selection criteria which are fair and reasonable and directly related to the
skills required for the job and instructing the selection panel to select a job
applicant based solely on these approved criteria.
Job Descriptions
Job descriptions for Management Committee members, volunteers and
employees will be created and maintained/ updated by our agency. Job
descriptions will include the main duties of the position as well as the skills/
competencies required of the staff member. The Management Committee will
review these job descriptions as part of the regular staff appraisal and
supervision process. This process will also ensure that staff understand the
skill/ competency requirements of their jobs.
Employment Process
Principles
Our agency will employ staff on the basis of their skills and not on any other
basis. Staff will be recruited in accordance with equal employment opportunity
legislation and all our recruitment based on the following principles:
• Clear and accurate definition and description of the requirements of the
position are provided to all applicants who request an information package
• Selection is based on merit
• Assessment of the applicant’s merit is measured against clear, predetermined selection criteria which have been supplied to all applicants who
request an information package
• Selection panel has relevant expertise and experience, and includes a
person from outside our agency as well as a person with disability
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• Confidentiality is maintained
• Affirmative action principles apply.
Advertising
Our agency will provide an information package for applicants, including
selection criteria, job description and information about our agency.
Our agency will advertise all positions, internally and externally, through agency
publications and appropriate newspapers. All advertising for positions vacant
will indicate that our agency is an equal employment opportunity and affirmative
action employer, encourages people with disability, including people from
Culturally and Linguistically Diverse (CALD) backgrounds with disability, to
apply.
Selection
To assess the applicants, a selection panel will be convened. The panel usually
comprises three people and should include a member of the Management
Committee and an independent person who is not employed by our agency.
The third member is usually the manager or supervisor of the position for
selection. The panel should have representation or input from a person with
disability.
The selection committee:
1. Considers all applications
2. Decides which applicants warrant an interview
3. Meets before the selection interviews to determine appropriate, nondiscriminatory questions to ask the applicants
4. Contacts applicants’ referees after the interviews.
All unsuccessful applicants will be notified by mail and informed that their
application will remain confidential. All unsuccessful applications are destroyed
after six months.
At the time of appointment, the successful applicant for a job is provided with a
formal letter/ employment contract detailing:

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



The position they are being offered
The date of commencement
The probationary period
A job description which includes a statement of duties
The conditions of appointment, including whether it is full-time, part-time,
casual, permanent (subject to recurrent funding), temporary, fixed term or
by negotiated contract; and including leave entitlements and notice of
termination of employment
The rate of pay, including details of the relevant industrial award and the
position classification under that award.
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Formal acceptance of the employment offer must be signed by the manager
responsible for staff and the successful applicant.
Orientation
Our agency will provide reasonable adjustment to the work environment by
supplying any aids/ equipment necessary to assist a person with disability to
perform their duties and will ensure that access to training and career
development opportunities is available on an equitable basis.
Our agency will provide training sessions, induction materials to ensure that all
staff/ volunteers are fully introduced to their new positions. Staff will be
introduced to their roles and responsibilities, as well as to any administrative
requirements of their jobs.
Staff Appraisal



Our agency will undertake a regular appraisal of staff skills/ competencies
and performance (for example, annually)
These appraisals will also include opportunities for staff members to discuss
their goals for training and development within our agency
These appraisals will be the responsibility of the immediate supervisor of
each staff member, and the finished appraisals will be reported to the
Management Committee.
Staff Development and Training



Our agency will budget for regular and appropriate forms of staff
development
Training and information will also be provided to staff and volunteers to
ensure that they understand their roles, the administration of our agency
and their accountability for their work related activities
Staff training and skills development will be identified through the appraisal
process and through forums such as staff meetings.
Volunteers
Volunteers will be oriented to our agency, as is a paid employee or Board
member, and agree to the Charter of Volunteer Rights and Responsibilities and
our agency’s Charter of Rights and Responsibilities in relation to volunteer
workers.
Charter of Volunteer’s Rights and Responsibilities
The volunteer has the right:


To be treated as a co-worker
To know as much as possible about our agency – its policies, its people, its
programs
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To a suitable assignment – with consideration for personal preference,
temperament, skills, abilities, education and employment background
To a written Job Description and written Contract of Employment Conditions
To refuse to do a task requested of them
To determine the number of hours that they will volunteer and when these
hours will be worked
To refuse to contribute anything (e.g. money, resources, etc., other than
their time, experience and skills in undertaking a job)
To relevant training for the job, which is thoughtfully planned and effectively
presented
To continuing education on the job, as a follow-up to initial training, which
provides information about new developments and other relevant matters
To supervision by someone who is experienced, well informed and who has
the time to invest in giving guidance
To a safe working environment
To promotion to greater responsibility as appropriate, and a variety of
experiences
To be heard and listened to – have a part in planning, to feel free to make
suggestions, to be shown respect for an honest opinion, to have these
acted upon when agreed to as valid statements, and to receive information
back as to the outcomes of these suggestions
To a fair and equitable Disputes Procedure if there is a problem with the
standard of the work that the volunteer worker is doing
To be free of discrimination or harassment because of racial, religious,
sexual, marital, age and ability status
To knowledge of existing or impending industrial disputes, presented in a
balanced manner, to enable the volunteer workers to make informed
choices of action
To a fair and equitable Termination Procedure (which includes reasons for
dismissal and an appeals process)
To a written performance evaluation at the end of the contract.
The volunteer has a responsibility to:

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

Support the vision, objectives and underpinning values of our agency
Be clear about what they will and will not do
Accept and adhere to our agency’s policies and procedures
Welcome supervision and seek direction as required
Respect the rights of other volunteers, paid staff and members, including
participant’s rights to privacy
Take part in a workplace culture, which is free from sexual, racial, disability
or any other harassment or vilification.
Charter of our agency’s Rights and Responsibilities in relation to volunteers
Our agency has the right:
 To employ or not employ any volunteer worker based on the needs of our
agency, its consumers and people with disability
 To expect the volunteer to meet minimum standards as defined by our
agency
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To expect the highest level of dedication, commitment and effort that the
volunteer can give, even on a short-term basis
To expect conscientious acceptance of responsibilities as to promptness,
reliability and good performance from the volunteer
To expect enthusiasm and belief from the volunteer in the work that our
agency is doing
To make a decision as to where the volunteer would best fit within our
agency, after negotiations with the volunteer
To express constructive criticism to the volunteer in a diplomatic way, and
suggest changes
To expect loyalty to our agency and only constructive criticism from the
volunteer
To expect clear and open communication from the volunteer at all times
To expect appropriate behaviour from the volunteer at all times
To expect an effective and appropriate work productivity from volunteers in
leadership positions
To expect that volunteers will not discuss any consumer’s circumstances
and details outside of our agency
To expect the worker to bring any concerns about consumers and their
circumstances to our agency for discussion
To tell a volunteer worker that their services are no longer required, and the
reasons for this decision.
Our agency has a responsibility to:

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

Have employment policies which also cover volunteers, for example, have:
o Job descriptions
o Job contracts
o Insurance cover
o Disputes procedure
o Termination arrangements
o Boundaries of levels of legal, professional liability and expertise of each
job
Properly meet and fulfil the Volunteer Worker Rights, and ensure that no
volunteer is exploited
Ensure that our agency and its paid staff address any concerns raised by
volunteers, make decisions regarding those concerns, and report this back
to the volunteers
Ensure that no volunteer is discriminated against or harassed
Ensure that volunteers work in conditions which comply with Occupational,
Health and Safety standards for the job they are performing; and that
volunteer workers receive ongoing Occupational, Health and Safety training
so as to ensure their ongoing personal safety
Ensure that volunteers are not employed in situations where an industrial
dispute is in progress. Nor should volunteers be co-opted to be involved in
such disputes
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Ensure that volunteers receive initial and ongoing training, support and
supervision
Ensure that volunteers receive some form of recognition/ rewards (instead
of money)
Ensure that volunteers are able to participate in and have access to our
annual agency review
Ensure that volunteers have a current National Police Clearance.
Training
The main forms of training and support opportunities identified by advocacy
agencies include:
•
•
•
External facilitator
o Experienced leader (with experience of audits, understands the QI
language)
o Consultant on individual agency basis, to meet agency needs.
Regional quality theme based workshops
Seminars - more formal training for staff and Board.
Other forms of training and support for quality that advocacy agencies identified
include:
•
•
•
•
•
•
•
•
Peer networks
Purposive visits – visits to other advocacy programs
Links to international networks
Organisational learning – internal workshops
Participating in external reviews
Local advocacy development – request for mentoring from other more
experienced advocacy agencies
Mentoring for staff and Board
Renewal/ time out – for agency to reflect on policies, procedures and
practice.
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9.2 Sample Templates
Template: Competency-based job description template58
You can use the fields in this template to document the skills, knowledge and
attributes required by the employee to fulfil their employment role.
Name
Job title
Background
Key responsibilities
Job Skills, Knowledge and Attitudes
Skills
Must do
58
Knowledge
Must know
Attitudes/Attributes/Aptitudes
Must be aware of
http://www.communitydoor.org.au
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Template: Job description questionnaire59
NAME
JOB TITLE
SUPERVISOR
1. In one paragraph describe the basic purpose of your job.
2. What are the key responsibilities of your job and what percentage of time do
you spend on each?
3. What are the secondary responsibilities or tasks required of your position?
4. Who do you report to?
•
•
•
•
•
•
Who assigns your work?
How often is work assigned?
How are the assignments given e.g. written, oral etc.?
Who reviews and approves your work?
What decisions are you required to make in the course of your work?
What decisions must be referred to your supervisor/manager?
5. What records or reports are you accountable for?
6. For what purpose are the records and reports used.
7. Do you have any supervisory responsibilities?
8. If you were promoted what type of education, training, job related experience
would your replacement need?
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Template: Recruitment and Selection Checklist 60
You can use this sample template as a guide for the recruitment process and as a way of evidencing your quality practice.
Process
Who is
responsible
Date task
due for
completion
Check
box
Human resource planning and analysis of skills/ competencies required
Develop job specification of skills/ competencies/ knowledge required
Develop position description that articulates duties to be undertaken
Identify the key selection criteria from the core competencies required for the position
Place advertisement, which includes the date for close of applications, and telephone contact for
provision of an applicants’ information pack
Distribute applicants’ information pack to those who inquire regarding the position. The pack
should include clear instructions regarding addressing the key selection criteria in applications
submitted
Close application period
Establish an interview panel
Train the panel in interview techniques, EEO principles, ‘Merit’ principles, awareness of
‘familiarity bias’ (the tendency to favour candidates who are similar to the panel member),
awareness of ‘primacy and recency’ effect (tendency to forget responses from candidates
interviewed first when comparing candidates’ responses to questions)
Evaluate applications according to the key selection criteria, using a scoring matrix
Short-list the candidates
Develop structured interview questions from the key selection criteria, and note your expected
Disability Sector Quality System, Partners in Quality – Resources and Guide, Queensland. Available at:
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responses
Weight key selection criteria to acknowledge the relative importance of each predictor
Notify short-listed candidates and arrange interview appointments
Notify unsuccessful candidates in writing
Conduct structured interviews with short-listed candidates using standard questions and a
scoring grid
Panel members to compare their ratings/ scores, and make a decision on the successful
applicant
Telephone referees, and verify qualifications
Notify successful candidate of offer of appointment, and confirm date appointment will take effect
and date of commencement of induction
Notify unsuccessful candidates in writing
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Template: Applicant Short-listing Matrix 61
This sample template provides a guide for short-listing applicants, based on their responses to the key selection criteria (KSC) – you
can add or delete columns based on the number of criteria. Each member of an interview panel allocates a score based on the
ratings scale for each of the key selection criteria (KSC), and then the total score should then be calculated.
NAME OF APPLICANT: ………………………………………………………………
DATE: ……..………………………………………
POSITION APPLIED FOR: ……………………………………………………………. PANEL MEMBER: …………………………………
Ratings scale
Exceptional=10
High level = 9 or 8
Above Requirements=
7 or 6
Meets
Requirements=5
Meets some
Requirements=4 or 3
Limited= 2 or 1
Does not meet
requirements=0
KSC1
KSC2
KSC3
KSC4
KSC5
KSC6
KSC7
KSC8
TOTAL SCORE: ……………………………………..
COMMENTS: …………………………………………………………………………………………………………………………………………
Disability Sector Quality System, Partners in Quality – Resources and Guide, Queensland. Available at:
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Interview Scoring Grid
This is a more complex interview scoring system. Each interview panel member makes an independent decision, based on the merit
of each candidate’s response to questions related to the key selection criteria (KSC). Once the panel has decided whether any
selection criteria are to be weighted (to acknowledge their relative importance), they allocate a ‘raw score’ out of a possible 10 (based
on the rating scale). This score is then multiplied by the weighting given to determine the total score against each KSC.
Name of applicant: ………………………………………………………………
Date of interview: …………………………………….
Position applied for: ………………………………………………………….
Name of panel member: ……………………………...
Key selection criteria
KSC 1 – Weighting =
KSC 2 – Weighting =
KSC 3 – Weighting =
KSC 4 – Weighting =
KSC 5 – Weighting =
KSC 6 – Weighting =
RATING SCALE:
10
Exceptional
SCORES:
Application:
8–9
High level
Raw score
6–7
Above
requirements
Interview:
Total
Comments
5
Meets
requirements
3–4
Meets some
requirements
Referee check:
2–1
Limited
0
Does not meet
requirements
TOTAL SCORE:
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Template: Staff/Volunteer Induction Checklist62
You can use this checklist as a reference for developing an induction process
for new staff/ volunteers. Having the checklist complete and signed by the new
staff member/ volunteer is a way of evidencing your good practice and ensuring
all steps are complete.
Personal information
• Contract of employment
• Position description
• Performance monitoring/ appraisal processes
• Code of ethics (accepted and signed)
• Confidentiality agreement (accepted and signed)
• Allocation of IT access code
• Terms and conditions of employment/ Award conditions
Documented essential practice guidelines
• Review of agency policies and documented procedures
• Quality monitoring and continuous improvement systems
• The agency’s mission, vision and values
• Consumer participation in agency management
Workplace Health and Safety
 Instruction in safe work practice
 Duty of care
 Fire safety procedures
Standard operating procedures
 Time sheets
 Leave requests/ Entitlements
 Training records/ Entitlements
Disability Sector Quality System, Partners in Quality – Resources and Guide, Queensland. Available at:
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 Mandatory training
 Premises security
 Use of vehicles
 Schedule of staff meetings
 Internal communication mechanisms
Advocacy delivery
•
Eligibility criteria for consumers, and processes for assessing prioritisation
of need
•
Principles of operation in supporting consumers
•
Rights of consumers and their nominated supports
•
Advocacy delivery orientation period completed under supervision (“buddy”
or supervisor)
I confirm I have completed my formal induction process and have understood
my responsibilities in relation to the information provided
Signed: …………………………………………
Dated: ……………
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Template: Staff Performance Appraisal and Professional Development Record63
This template could be used to help you develop a positive system for staff performance reviews that focuses on opportunities for
further professional development. Staff members can complete this sample template themselves, identifying the skills, knowledge and
abilities they need to undertake their duties proficiently, and rating themselves from not competent to highly competent in each area.
Where they feel further knowledge would be of benefit, they identify professional development goals. This is then discussed with their
supervisor, necessary amendments jointly negotiated, and timelines established for the goals to be achieved over the next twelve
months. The targets met can be ticked off as they are completed.
Assessment codes
NC = Not competent
C = Competent
HC = Highly competent
Duties from position
description
Skills, knowledge and
competencies needed
NC
C
HC
Goals
Targets
met
NC
C
HC
Disability Sector Quality System, Partners in Quality – Resources and Guide, Queensland. Available at:
http://www.communities.qld.gov.au/disabilitiy/key-projects/disability-sector-quality-system/publications-tools-and-resources/resources/partners-in-quality-resources-and-guide
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Template: Staff Professional Development Log64
Keeping a professional development log for each staff member, like the template below, is a way of evidencing your agency’s
commitment to staff development, and monitoring equitable distribution of professional development resources across staff. You
might want to document only external activities, such as programs/ conferences in this form, and record internal activities in your
annual agency training calendar.
Each staff member is responsible for maintaining and updating his/ her own professional development log. One copy may be kept by
the employee for his or her curriculum vitae, and one copy should be retained by the Executive Director in the personnel file. If the
training completed has been at the cost of the staff member, note “AOE” (At Own Expense) in the “Cost” column. If the training
program has been attended in the staff member’s own time, note “IOT” (In Own Time) in the “Hours” column when recording the hours
involved.
NAME:
POSITION TITLE:
DATE COMMENCED:
Date
Course/ conference attended
Hours
Cost
Disability Sector Quality System, Partners in Quality – Resources and Guide, Queensland. Available at:
http://www.communities.qld.gov.au/disabilitiy/key-projects/disability-sector-quality-system/publications-tools-and-resources/resources/partners-in-quality-resources-and-guide
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9.3 Tools
Tool: Step-by-step guide to good practice recruitment
This guide to best practice in recruitment is based on a document created by the
Council of Social Service New South Wales. You can compare the steps in this
guide with recruitment processes at your own agency.
This guide to a good practice recruitment process contains the following steps:

Plan for recruitment

Prepare job descriptions and selection criteria

Advertise

Shortlist

Select

Do reference checks

Make an offer of employment
Note: Recruitment is a process which leads to a formal offer of employment. As such
it is governed by legislation, particularly in relation to anti-discrimination law and
equality of employment opportunities. Ensure that you are aware of the relevant
legislation in your state/territory.
Step one: plan for recruitment
A good recruitment process takes time and is well planned. You need to prepare or
revise the job description and selection criteria, convene a selection panel, advertise,
conduct interviews and negotiate start dates. All these tasks should be scheduled in
advance. It is also important to bear in mind that you may not successfully recruit
during the first round of recruitment. The whole process can easily take months from
the decision to recruit, to when the person actually starts in the position.
The following is a checklist for managing the key steps in the recruitment process.
Before you recruit:
 Confirm funding exists for the position
 Obtain necessary approvals to staff the position
 Develop a job description if the position is new or review the existing job
description
 Establish the recruitment criteria
 Develop job-related and measurable selection criteria based on the job
description, including the minimum (essential) experience and skills for the
position
 Manage the recruitment process.
 Determine the best method for recruiting for the position including where to
advertise and who should be included on the selection panel
 Develop the advertisement using the job description, minimum qualifications and
selection criteria. The advertisement should also include:
o Deadline for applications
o Salary range and other key benefits
o Contact person for further information
o Anticipated date for interviews.
Step two: prepare job description and selection criteria
Job descriptions and section criteria are critically important to the recruitment
process. The job description describes the role—what it does, how it does it, and
reporting requirements (see job analysis below).
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The related selection criteria describes the skills, knowledge, experience,
qualifications and personal attributes that a candidate needs to meet the
requirements of the job description. The selection criteria should also clarify whether
these ‘competencies’ are essential or desirable. Clear and informed job descriptions
and selection criteria are essential for both the employing agency and prospective
candidates.
For the agency, job descriptions provide the basis for not only recruitment but also
performance appraisal and for ensuring that the work carried out by staff is aligned
with the agency’s objectives. A well- developed job description assists candidates
and job holders to understand their duties and responsibilities and also clarifies the
boundaries of their role.
If an existing job description is to be revised before recruitment, it’s a good idea to
develop it with the person currently in the job. Alternatively, the job should be subject
to a job analysis.
A job analysis typically asks the following key questions:

What is the overall purpose of the job?

What are the main duties (e.g. the five main things the job holder does)?

What are the typical working conditions (location, consumer interaction)?

What are the supervision and reporting responsibilities?
Selection criteria are based on the job description. They are the benchmarks that will
be used to screen prospective candidates and select the most preferred person for
the job. There are some key factors to consider when developing or revising the
selection criteria including:



What are the skills, experience or qualifications essential to the position?
What are the skills, experience or qualifications that are desirable?
It is also important to ensure that your criteria are specific, measurable and jobrelated.
Also ensure that the selection criteria do not directly or indirectly discriminate against
any potential candidates. This is often the stage at which potentially discriminatory
values, explanations about how a job is done, or the ‘type’ of person required are
inadvertently built into selection processes. It is useful to involve someone
experienced in recruitment but outside the particular process, to check key
documents and identify any potentially discriminatory practice
Step three: advertise
The most common way to advertise is through newspapers and more recently via job
websites. With the increasing use of IT, many services may advertise in a high
circulation newspaper but also promote the position via targeted e-bulletins or other
email listings. Each method has a target audience or ‘demographic’ so it is important
to consider who you are including (and therefore excluding) as potential job
candidates.
The information sent to prospective candidates should be accessible, including to
those people with hearing and sight impairments and/or other disabilities.
Effective strategies for responding to these needs include:

Write in plain English
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
Use job websites compatible with software that can ‘read out’ web pages (e.g.
Browse aloud) for people with literacy and visual impairments who might have
difficulty reading online.
If you are using an agent to recruit on your behalf remember they must be clear
about your requirements and act in accordance with your agency’s employment
practices and the relevant legislation.
Step four: shortlist
This part of the process should make full use of the selection criteria. It is also
desirable that the same selection panel shortlists applications and conducts the
interviews. All prospective candidates must be assessed against the essential and
desirable criteria, in the same way, and by the same selection panel. The golden rule
is to be consistent and document all decisions and the reasons for them. This
documentation should be kept in a confidential file and referred to if there are any
inquiries or complaints regarding the selection process.
Step five: select
There are a variety of ways to assess candidates against the required competencies
for a position. It is important to consider the role and to employ a selection process
or ‘setting’ that best suits the requirements of the position. The most common
method is the interview, involving the candidate and a selection panel comprised of
three to five people.
Most job interviews take approximately 30–40 minutes, but are frequently longer for
very senior positions such as CEOs or Directors. The selection panel often includes
Board members and staff, as well as one independent or external member. Typically
the candidate is asked a series of questions relevant to the position and designed to
test their knowledge, experience and skills. It is essential that all candidates are
asked the same questions and that the interview process gathers the information
required to make a decision on the preferred candidate or candidates.
Depending on the competencies being assessed, the interview may include a set
exercise for the candidates. For example, asking them to analyse a budget or deliver
a short presentation on a specific topic such as the Disability Advocacy Standards.
Psychometric testing refers to personality and/or psychological assessments that are
conducted with candidates, often prior to a formal interview. Psychometric tests are
more often used for management positions or positions where high-level specific
skills are required. Most of the tests available must be used under license to those
who developed them, with associated costs.
Step six: check references
References checks often reveal useful information and are a key part of the selection
process. They often provide information that a candidate may be unlikely to reveal
about themselves and provide another perspective on their performance in previous
roles.
Always verify the nature of the relationship between the candidate and the referee
and the length of time they have known each other. It is also essential that at least
one of the referees is a previous supervisor. Notes from referee checks should also
be documented and kept on file.
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Step seven: make an offer
Once the selection panel has received feedback regarding the referee checks, and is
satisfied that the chosen candidate is the best person for the position, then the
candidate is offered the position, usually verbally in the first instance. If the candidate
accepts the position, then the start date needs to be agreed and the offer must be
formalised in writing. It is important that the offer is accepted in writing before the
other candidates interviewed are advised of the outcome.
Once the formal offer has been accepted, then all other candidates should be
advised in writing that they have been unsuccessful. It is also likely that some of the
unsuccessful candidates may request feedback on their interview (strengths and
weakness) and it is good practice and fair to ensure they receive useful feedback
based on the notes from the selection panel.
General principles
Matters regarding sex, age, colour, race, religion, national origin, sexual orientation
or disability are inappropriate to consider at any stage of the recruitment process
(other than how people with specific needs might need to be supported to equitably
access the process).
It is also inappropriate to consider a person’s housing status, criminal record or credit
history unless these factors are relate to a specific requirement for the position, and
for which there should be separate formal processes (e.g. child protection
procedures).
Those involved in the recruitment process should be required to declare any conflict
of interest relating to any candidate. For example, those involved in any stage of the
recruitment process should make a declaration about any relationship with any
candidates.
Confidentiality must be maintained at all times. All documentation and
communications with prospective candidates should re-iterate a commitment that
applications will be treated in confidence. In addition, all recruitment files, from
applications to interview assessments and the panel’s deliberations, should be held
in secure locations with restricted access.
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Standard 10: Protection of human rights and freedom
from abuse
10.1 Sample policies and procedures
Sample Policy: Human Rights65
Human rights, as outlined in the United Nations Declaration of Human Rights,
include the rights to physical integrity, mental and moral integrity, civil rights and
legal integrity, socio economic rights, and the right to a family.








Our agency believes that people with disability have the same legal and civil
rights as other people in the community and that advocacy has an important role
in safeguarding people with disability against abuse.
Abuse and/or harassment of a person/ people with disability will not be tolerated.
Staff, volunteers or Committee Members who engage in such activity will be
liable to dismissal from employment.
Our agency will endeavour to ensure that all involved with our agency possess a
full understanding of the legal and civil rights of people with disability.
Our agency will seek potential staff, volunteers and Committee Members who
are committed to defending the legal and human rights of people with disability.
Our agency will provide adequate training for staff/ volunteers in reporting and
supporting consumers in relation to abuse.
Our agency will ensure that all staff recruited and potential advocates are
screened as a safeguard to minimise the risk of exposing people with disability to
abuse.
Our agency will source and make available relevant information and resources
which can assist in dealing with issues relating to abuse.
Our agency has a commitment to upholding the legal and human rights of people
with disability.
Where people with disability are the consumers of the agency, our agency will:


Provide information to consumers (and their families and carers, as appropriate)
about their right to live free from abuse and their entitlement to independent
advocacy and support if their human rights are infringed.
Ensure that the legal and human rights of people with disability involved with our
agency are upheld, both in the context of the advocacy undertaken and in the
community in general.
Outreach to people with disability
Where people with disability are the consumers of the agency, consistent with
our purpose and contractual obligation, our agency will:
•
•
65
Endeavour to seek people with disability who would not otherwise have come to
the attention of our agency, or may have a limited ability to access our agency
Seek out people with disability who may have been subject to abuse or neglect.
National Disability Advocacy Program Quality Improvement Toolkit, FaHCSIA, 2009
217
Our agency may seek these consumers through outreach programs.
10.2 Tools
Tool: Indicators of abuse assault and neglect66
Management, staff, volunteers, people with disability, their families, friends, carers,
and advocates all play a significant role in preventing and detecting the occurrence
of abuse, assault or neglect.
The table below provides some examples of indicators of abuse and neglect of
children and adults. It is important to remember that the indicators listed below are
not the only indicators and that the presence of one or more indicators does not
necessarily ‘prove’ that abuse, assault or neglect has occurred. This list of possible
examples should not be considered a complete list of possible indicators.
Type of abuse
Physical indicators
Behavioral signs
Physical abuse
- unexplained cuts, abrasions,
bruising and/swelling:
on face, lips, mouth, torso,
back, buttocks thighs in various stages of
healing
- unexplained burns or scalds:
cigarette burns especially on soles, palms,
back or buttocks
- rope burns on arms, legs neck or torso
- unexplained fractures, strains or sprains
- dislocation of limbs in various stages of
healing
- bite marks
- dental injuries
- ear or eye injuries
- ligature marks
- welts
- avoidance of a particular
staff member
- fearfulness or fear of a
particular person
- sleep disturbance
- obvious changes in
behaviour
- changes in appetite
- changes in daily routine
- unusual mood swings
withdrawal
- unusual passivity
- out of character
aggression
- self-abuse
- drowsiness
- inappropriate or changing
explanation of how an
injury occurred
- excessive compliance
Psychological /
emotional
abuse
- speech disorders
- in the case of a child, there may be lags
in physical development or a non-organic
- self-abuse or selfdestructive behaviour
- challenging or extreme
66
Disability Sector Quality System, Partners in Quality – Resources and Guide, Queensland.
http://www.communities.qld.gov.au/disability/key-projects/disability-sector-quality-system/publications-toolsand-resources/resources/partners-in-quality-resources-and-guide
218
failure to thrive
- injuries sustained from self-abuse or selfdestructive behaviours
- suicide attempts
- anxiety attacks
behaviours
- excessive compliance
- extreme low self esteem
- depression
- feelings of worthlessness
- lack of interpersonal skills
necessary for adequate
functioning
- extreme attention
seeking behaviour
Sexual abuse
- direct or indirect disclosure of
abuse or assault
- difficulty in walking or sitting
- pain or itching in genital and/or anal area
- vagina or penile bruising, bleeding or
discharge
- self-abusive or self-destructive behaviour
- attempts at suicide
- torn, stained or blood stained underwear
or bedclothes
- sexually transmitted diseases
- trauma to the breasts, buttocks, lower
abdomen or thighs
- unexplained accumulation of
money or gifts
- pregnancy
- sleep disturbances
- changes to eating
patterns
- inappropriate or unusual
sexual behaviour or
knowledge
- changes in social
patterns
- sudden or marked
changes in behaviour or
temperament
- anxiety attacks
- refusing to attend usual
places egg work, school,
respite
- depression
- going to bed fully clothed
- excessive compliance of
staff
Financial abuse
- no access or unwarranted restrictions to
personal funds
- no control over personal funds or bank
accounts
- no records or incomplete records kept of
expenditure and purchases
- no inventory kept of significant purchases
- person controlling the finances does not
have the proper legal authority
- misappropriation of money, valuables or
property
- forced changes to wills or other legal
documents
- persistent failure to produce receipts
- receipts indicating unusual or
inappropriate purchases
- person has insufficient
money to meet normal
budget expenses
- person is persistently
denied outings and
activities due to a lack of
funds
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Tool: Human Rights Indicators Project – Queensland Advocacy Incorporated 67
Queensland Advocacy Incorporated (QAI) has been working on a Human Rights
Indicators project – developing a set of human rights indicators for people with
disability.
“A human rights indicator is designed to be an objective measure of the degree to
which persons with disability enjoy (or experience) a particular human right or
freedom.
Over time, QAI will use its Human Rights Indicators to build a database that records
the lived experience of human rights of persons with disability in Queensland. The
database will be compiled from a range of sources, including consultations with
persons with disability and reports made by individuals and organisations.
The database will provide evidence of the key issues that need to be addressed by
governments and communities to improve recognition and respect for the human
rights of persons with disability in Queensland.”
There were a few drivers behind our project – we’d become aware of some
unscrupulous operators of boarding houses for people with disability. For example,
one boarding house had forty residents in its care although it no longer met the
service conditions.
We thought we needed to develop a set of indicators so that when someone went
into a boarding house they could easily judge whether or not it was operating in a
way that upheld the rights of people with disability. Although these services had to
be accredited to operate, accreditation alone wasn’t enough to protect the rights of
people with disability.
In developing the indicators we consulted with agencies, the anti-discrimination
board, service providers, the Office of the Public Advocate, advocacy groups and
people with disability. At the first cut we developed a set of plain English standards.
Now we have additional funding from a service provider for reviewing the first round
of indicators and to produce a publication that will be a snapshot of how people with
disability feel their human rights are being met in Queensland. It will also be a way
of testing our indicators.
We are running a set of hands-on workshops on human rights around scenarios for
human rights for people with disability, their parents and service providers. We are
taking an action learning approach and from that are hoping to develop a set of fact
sheets for people with disability to understand when their rights are not being met.
Queensland Advocacy Incorporated, http://www.qai.org.au/content/humanrights.cfm
67
220
Excerpt from Everyone has human rights Understand Yours!, 2006, Queensland Advocacy Incorporated,
http://www.qai.org.au/content/humanrights.cfm
221
Excerpt from Everyone has human rights Understand Yours!, 2006, Queensland Advocacy Incorporated,
http://www.qai.org.au/content/humanrights.cfm
222
Excerpt from Everyone has human rights Understand Yours!,2006, Queensland Advocacy Incorporated,
http://www.qai.org.au/content/humanrights.cfm
223
5.2 Case studies
Standard 1: Accessing advocacy
Rights in Action Inc, Queensland
Managing advocacy access is essential. We will never be able to provide advocacy
for everyone – we have an agreed number of people based on our funding from
FaHCSIA – so we want to make sure that we do help those who are most
vulnerable. It’s about prioritising need.
To do this we have developed a spectrum of vulnerability. The spectrum has three
components – vulnerability, capacity and urgency of the issue. Previously, we used
a numbered rating scale, but now we rank vulnerability and capacity as high,
medium, or low. And the urgency of the issue is rated as urgent, non-urgent, or an
issue that can be referred to another service.
For example, a high rating for vulnerability would include those: at risk of suicide;
homeless; with no income; living in a segregated setting (e.g. an institution); and
from an Indigenous or Culturally and Linguistically Diverse (CALD) background.
While a medium rating for vulnerability would include those with: communication
difficulties; mobility impairment; and a health or justice order.
Our view in ranking people from an Indigenous or non-English speaking background
highly in terms of vulnerability, is that they have generally had less access to
services and are more likely to have been left out of general community services.
Referrals to other local services are made by telephone and if the person can be
assisted at that time by providing information or linking them in with an existing
service, this is done immediately. Whereas referrals identified as ones we might
take up are reviewed and prioritised in regular staff meetings.
At the moment we have reached capacity and can’t accept more referrals for about
one month. That’s why it’s important we have strong networks in the community so
we know what other services we can refer people to. Also, the agency can’t become
a case manager, so it’s important to pressure existing services to assist people with
disability as they would anyone else in the community, so they are integrated into the
community.
We don’t just say ‘no sorry we can’t help you’ when we can’t take up a referral. We
try to find them the resources they need to resolve the issue themselves. It might
take a few phone calls, helping people if they get stuck along the way.
We don’t just give the person information, but try to put in place the steps they can
follow through. Often we won’t just tell them about another organisation, we send
them information or the organisation’s brochure; we might introduce them to
someone from the organisation or offer to make an appointment for them – if we
224
don’t do this people might not take up the opportunity. Although it takes some time
to do this, it is much better than the person calling back in three months in a crisis
situation that might have been prevented.
Where there aren’t other services to refer someone to in their local area, we might
refer the issue to the local MP, or take up the issue on a systemic basis, lobbying for
services in those areas.
Accessing the most vulnerable people also involves proactive outreach, such as
visiting people in group homes, nursing homes and the hospital psychiatric ward,
because most people don’t self-refer – the bulk of our referrals come from social
workers, disability service providers and legal services. We also visit our local
Australian Business Enterprise Centres and talk to people with disability there on a
monthly basis to raise awareness of the services they can access and develop some
rapport so that if a situation does arise, they have the confidence to call us.
We have had complaints from the people who have tried to access our service who
were declined because they were outside of our geographic area. When this
happens we refer people to the Complaints Resolution and Referral Service (CRRS)
so they can make a complaint and also inform the Department through our quarterly
reports so they know where there are areas of need.
Gippsland Disability Advocacy
Our agency is only funded for one EFT so it is important that we prioritise people at
risk – it’s about urgency of need.
In the last 12 months we’ve developed and introduced an intake document. We
realised that we didn’t always have the information to hand that we needed, so we
worked out the best way of getting that. We have a limited amount of time for
administration so having the intake document as a tool is helpful because it provides
a very quick snapshot.
In the past, people phoning our agency to refer someone needing advocacy often
provided little information about the person they were referring. But we find that the
more information we have about a person, the easier it is to begin working with them
on their issues.
Also, from a safety perspective, it is important for us to have as much information
about a person and their situation so that we can prepare our advocates for what to
expect before they go to an initial meeting with a consumer. Having something down
on paper is a safeguard for us and it also helps us comply with legislation.
The intake document records demographic information, type of disability, the
person’s issue, who they were referred by, and what supports they have.
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Based on the information recorded in the intake document, we can prioritise cases
for advocacy. When deciding which cases to prioritise, a range of issues come into
play. We prioritise cases where people with disability are in a vulnerable situation
and whose needs are urgent. Our promotional brochures outline the groups of
vulnerable people for whom our agency will prioritise access, which include people
who are experiencing discrimination, abuse or negligent treatment. It also includes
those who are socially isolated; because our agency covers a large regional area
and we find people who are isolated need support.
Although some people referred may have multiple issues it is not as simple as
prioritising those cases because consideration needs to be given to the urgency of
those issues. It’s important to manage practice around advocacy access because it
would be very easy to get caught up in a plethora of issues that could wait or issues
that could be dealt with by another service. Because our resources are finite, we
need to prioritise what we do and what advocacy we provide.
If someone is referred to us and they have issues that aren’t as urgent, we will link
them in with another support agency or specialist service where appropriate. It’s
important that we don’t just let them fall through the cracks. That’s why it’s important
that we have as much information as possible so that we have a sense of the issue,
the person’s situation and then the urgency of need.
Over time we will review the intake document and we may refine it, for example, we
might refine the questions we ask when completing the intake form.
A next step is also to develop a matrix for recording information about referrals for
which we don’t end up providing advocacy but we do provide information and advice
about the case.
Sussex Street Community Law Service Inc
Our agency introduced an exit survey for consumers collecting both feedback and
demographic information. The survey is given to both consumers who come for a
one-off visit and those with longer cases, and we usually receive about 20 responses
per month.
The demographic information in the survey collects includes: postcode, sex, year of
birth, country of birth and Indigenous background. The data is collated and we can
use this information for generating statistics regarding the populations accessing our
agency in terms of sex, age and cultural background. We also monitor and compare
these figures with local area demographics from time to time. That way we can see
what percentage of various populations we are reaching.
As an agency that covers a lot of the south of Western Australia, we have centres in
several outreach areas. Consumers can access the agency via the central phone
number and information service or they can contact the outreach centre in their
226
region directly. All consumers used to come through the central phone number, but
as people in the community have become more aware of the local centres most calls
are made directly to the local centre.
Local communities are more aware of the outreach centres and able to access them
directly because the centres have been active in getting out there talking to
communities and business agencies to let them know about the services we provide
and where we are and what we do. We’ve also advertised in local papers and on
local radio stations about the services.
In terms of intake, at this stage we haven’t needed a waiting list. We have been able
to meet the demand for those in the areas we cover who have issues that we can
handle. Some people who contact our agency just need us to send them information
so they understand how they can deal with the issue. We also receive some
referrals regarding issues we cannot handle, and when this happens, we’ll refer them
to another appropriate agency.
Although we don’t have the issue of a waiting list because we cover a large regional
area, our agency encounters other issues in terms of providing advocacy for
everyone referred. We know there is demand in some outlying areas where we don’t
have centres. What we do in these cases is provide information and make referrals
to local agencies that can help although they are not specific to disability.
It is good to have policies and procedures around accessing advocacy not only when
you have a waiting list but also in terms of prioritising how quickly a consumer is
seen. Based on the urgency of the case, we can prioritise how soon people get an
appointment. For example, an issue regarding accommodation, if a person is being
evicted from their home, would be prioritised. If that is the case we try to set up an
initial meeting as soon as possible, so that we can at least discuss with the
consumer who they can speak to so that they can start the process.
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Standard 2: Individual needs
Regional Information and Advocacy Council, Victoria
We approach advocacy based on the consumer’s best interests. An advocate has a
discussion with the consumer about their wishes and needs. But in some cases a
consumer’s expectations can be unrealistic. If an advocate is unclear about the
actions to take on behalf of the consumer, they’ll talk to the consumer and let them
know they are going get some advice from others in our agency.
The advocate can then talk to their team leader or the manager of the agency about
what actions will be in the best interests of the consumer, what actions are
reasonable and what expectations are reasonable. It’s important to consider
whether the consumer has given us the whole picture of their situation because if we
go in and act without the whole picture our organisation’s credibility would take a hit.
Other organisations wouldn’t want to relate or engage with us to solve problems for
our consumers – it wouldn’t do us or our subsequent consumers any good.
Consumers’ wishes and the organisation’s response are clearly documented in
consumer files. It’s important to make file notes as things happen so that if a
consumer makes a complaint or asks for a review, the file can be reviewed.
In other cases, a family or carer contacts us on behalf of the person with disability.
Before we act we have to consider whether the actions they’re asking for appear in
the best interests of the person with disability. If they are, we usually go ahead. But
if the parents/ carers interests don’t seem in the best interest of the person with
disability, we usually take the case of the person with disability. For example, issues
can occur when a person with disability reaches an age where they want some more
independence and the family/ carer doesn’t agree with this. Our response would
usually be to take up the consumer’s case. Where there are issues we can’t resolve,
we can refer the case to the public advocate’s office, the Office of the Disability
Services Commissioner, Health Services Commissioner etc.
Rights in Action Inc, Queensland
We meet with the person seeking advocacy (consumers) to get to know them,
understand what the issue is, and who the people they want to be involved are, for
example, a support person or friend. We make them aware of their rights, of possible
actions they can take and what the consequences of those actions might be. It’s a
very transparent process.
It is part of QA that all actions are discussed with the person with disability. In most
instances they also guide those actions, but in some cases what is in their best
interest must be considered because we don’t want to put the person in a worse
situation than they are in.
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We have a process for obtaining informed consent which is guided by each
individual case. Some people have reasonable literacy skills and can sign a consent
form themselves. However, others might be confused about why they even have to
sign – in our view having the documentation isn’t relevant if the consumer couldn’t
understand it. Some people might nominate a person to sign forms on their behalf.
Others, for example, a person with a severe acquired brain injury, may have legal
decision makers, such as an adult guardian who can sign consent and authority
forms on their behalf. Where the person has a formal guardian, we may not
automatically agree with the guardian’s views, we remain loyal to the person we
advocate for. If we don’t believe the action or decisions they want to take is in the
best interests of the person with disability then we provide them with information
about actions that we think would be more appropriate and might try and influence
them to change their opinion.
We develop strategy plans for each person containing information about the issue
and the actions being taken. All plans are reviewed on a three-monthly basis to
check the milestones that have been achieved and whether any barriers prevented
achievement. Plans are never developed by one person – a number of us might
come up with strategies that the advocate can then take back to their consumer to
discuss the options and possible consequences. We want to make sure we’re
implementing the best strategy.
As well as the strategy plans, we record, number and file any contact we have with
the person receiving advocacy. Keeping records and reviewing them keeps us
accountable. It shows we don’t have a fixed agenda or a one-size fits all approach
to advocacy. It’s a way of double checking that we’re doing what we say we’re doing
and is a form of evidence to back that up.
For us keeping records is just doing our jobs but it’s really about being accountable
to the person with disability, that what we agreed with them is being done.
Delivering a culturally appropriate service - Sussex Street Community Law
Service Inc
One of the important things we do, and I’d say this would be the case for other
agencies with multiple sites, is to make provisions in the budget for bringing staff
together at least once a year. There is quite a bit of money involved for travel and
accommodation so we try to organise a two day session to get the most out of it. We
allow time for general discussion of issues and also try to organise some formal
training, for example on working with people from Indigenous or Culturally and
Linguistically Diverse (CALD) backgrounds. We have received positive feedback
about the value for the staff in meeting and having the opportunity to discuss mutual
issues.
The training for working with Indigenous people was delivered by members of the
Indigenous community. It covered cultural values and beliefs; differences in how
Indigenous people might expect things to be done; and issues of abuse and
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discrimination related to race. It has impacted on how advocates feel. With the
knowledge from the training, they can be more empathetic to the situation.
We used another NDAP funded agency – the Ethnic Disability Advocacy Service – to
provide the CALD training. Training briefly covered the migration patterns to
Australia over time identifying the countries people have migrated from; how other
agencies can help us with CALD consumers; and services and supports where we
can refer CALD consumers. It’s become a valuable tool for advocates in knowing
what consumers can access and what they can refer them to.
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Standard 3: Decision making and choice
Family Advocacy, South Australia
Ensuring informed decision making and choice in advocacy is important because a
quality life for people with disability is one in which they are given the opportunity to
participate. Informed decision making and choice is key to what advocacy is about.
The definition of advocacy states that you must not act contrary to the views of the
person with disability and that you must keep their views in mind at all times in the
advocacy process.
As a family advocacy agency, we support the family member of the person with
disability. However, whenever the person with disability is an adult, we make sure
we meet with them so that we get to know them and what their preferences are. We
might not meet them in the initial interview, but we meet them early in the case. In
many cases, we get to know the whole family really well.
Sometimes it is very difficult to find out what the person with disability’s preference
is, but usually even people with profound disability are able to indicate ‘yes’ or ‘no’.
In some difficult cases, we may arrange for an advocate to support the person with
disability to ensure their voice is heard. So, depending on their capacity, we either
speak to the person with disability directly to hear what they have to say; or we
organise this with the support of an advocate for the person with disability.
As it can be difficult to find out what the person with disability is really thinking, there
are other clues we look for as to the true feelings of that person. In particular, there
are some cases where the person with disability doesn’t describe the true situation
because they are ‘seeking to please’. For example, a person who is uncomfortable
in their work situation may not say this directly, but there might be physical factors
indicating their discomfort. In this situation, we often find that family members know
the person best and can help us find out what is really happening.
On the other hand, acting according to the communicated wishes of the person with
disability can raise concerns around duty of care. There are situations where
parents approach agencies feeling distraught and disempowered because an
advocate has supported the right of the person with disability to make their own
decisions in taking drugs or other dangerous activities that have been impressed
upon them by an outsider. A previous review of advocacy found evidence of cases
where advocates were alienating the person with disability from their family.
As an agency, we believe it is important to take a holistic approach, an inclusive
approach, because family is so important. We are very careful not to alienate family
members. It is one of the most delicate and sensitive aspects of our work.
Where parents approach the agency suggesting an action that is not in the best
interests of the person with disability, for example, placing them in a segregated
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setting, we will try and work with the family. We work with them to consider the
whole situation and what the consequences might be because it is an absolute
priority that the outcomes are positive for the person with disability.
In terms of duty of care, as an agency we are mandatory reporters – if we are aware
of abuse of children under 18 we must report this to the Department. We have
lobbied for this law to include adult children with intellectual disability, but this is not
currently the case, which makes this situation more complex. Our approach is to
involve the Office of the Public Advocate in situations where abuse is evident,
whether that is physical abuse or issues around misuse of disability pensions.
In some cases, families approach us in crisis situations, where there may be limited
options available at the time, particularly in rural areas. For example, in one case,
the strength of an adult child of an ageing rural couple was endangering himself and
others around him. There were situations where he had grabbed the wheel of the
car while his father was driving. The parents approached our agency for support.
We agreed that on a short term basis he be admitted in Strathmont Centre to relieve
his parents and for his own safety. However, instead of three months he ended up
staying there for a year – it was distressing for his parents to see him in that
situation, but they were unable to bring him home.
We continued to advocate on their behalf, and he is now living in a regional centre
that his parents can access, in a house with another male his age. They both
receive a lot of support and he is involved with day activities. He is so much happier
and some of his troubling behaviours have subsided.
In terms of quality improvement, it is important to be flexible as an agency and work
with the changing trends. We need to be adaptable to meet people’s evolving
needs. This is also why staff training is absolutely essential as is providing staff with
support in their work, which can be in very emotional situations.
One such changing trend is the increased number of cases of mothers with an
intellectual disability referred to us. Department Families South Australia
approaches us to support mothers with intellectual disability who have had their
children removed by the State. We discuss with the consumer their needs and
wishes, and will advocate for them to have the most access to their children, for
example, spending critical times like Christmas together, so that children are not
alienated and get to know their mother.
The use of consumer evaluation forms is also important in guiding our advocacy
delivery, so that families can have an input into decision making on this level. When
we have completed a case, the family completes an anonymous evaluation form.
We provide a stamped self-addressed envelope so that they can fill out the forms at
home rather than in front of an advocate. If you’re going to improve your agency,
you really need feedback from the people you work with. You can think that you’re
doing the right thing but, unless you check with those people you are funded to
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support, you might be getting it wrong. We discuss the feedback at staff meetings
and consider what is working well and where changes need to be made.
Self advocacy groups - Gippsland Disability Advocacy
Gippsland Disability Advocacy covers six local government areas – it’s a huge
geographical area for our advocates to cover. We’ve recently been involved in a
project to develop and support a network of self advocacy groups in the region. We
are on the Steering Committee for the project. In our role, our advocates also rotate
with advocates from other participating agencies to attend group meetings and
support the members.
In the project’s first year, there was philanthropic funding available for a project
officer. So that the groups will not be dependent on funding, which can change, the
aim for the future is that they will be self-sustainable. But to do that they will need a
little help. This is why agencies have organised for their advocates to have a
supporting role for the groups.
The groups are a safe environment where people with disability can speak about
their experiences and do the things they need to do. They provide a forum for
people with disability to get together and talk about issues they are facing in their
local community and how to manage them.
In the start-up phase, meetings were held in day centres for people with disability.
Members were mainly people living both in residential care and in the wider
community, with minimal support, coping with issues including social isolation and
economic disadvantage. People’s attendance at these groups increases our
capacity to reach people with disability who may otherwise be hidden within a
community.
Sometimes families can be very supportive but often there is little or no family to
offer support. Also, there are occasions when families are the issue.
It is basically a community development project. The idea is to support community
groups’ capacity to support people with disability and to support people with disability
to be involved in their communities. People with disability have ownership of their
group. They are empowered to speak out about what they think should happen in
their community and the issues each group focus on are specific to their community.
Supporting advocates help link the group to local organisations, as needed to work
on solutions to issues. For example, one group is working on the lack of transport in
their local area, and they have been able to link in with local council.
An advocate attending either community advocacy or self advocacy groups improves
access to services for these people, with an added benefit that people with disability
will get to know the advocate and therefore feel more comfortable approaching them
for support i.e. a familiar face.
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Supporting these self advocacy groups’ work on advocacy issues in their local
community means that our advocates are more available to work on individual
advocacy cases. The people in the groups are also developing leadership skills and
learning to network, which are key skills for their participation in the community.
One of the self advocacy groups’ achievements to date is having organised a
regional advocacy forum, which they were able to do with minimum help from
advocacy agencies. They formed a Steering Committee to oversee the organisation,
with one member from each group as a representative on the committee. They
organised speakers, including relevant Members of Parliament. The forum was open
to the general public and about 170 people attended.
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Standard 4: Privacy, dignity and confidentiality
Gippsland Disability Advocacy
Gaining trust of people with disability is integral to advocacy so that we can work with
them and build their confidence. We aim to provide an environment where
consumers have the confidence to say what they want, are involved in directing
advocacy actions and feel supported. One way of building consumers’ confidence
and trust in us is having them sign a privacy document, which shows that we respect
their rights and personal information.
The consumer is given the privacy form in our initial meeting. The information on the
form is brief, only a paragraph, and in plain English. It explains that their personal
information will be collected and held by our agency and that it is our practice to
disclose information to government departments for reporting and accountability, as
well as other relevant parties.
The advocate reads the form to the consumer and makes sure that they have
understood the form before they are asked to sign. At the same time we explain that
their information will be held securely – we have locked filing cabinets and our
computers are password protected.
As well as asking the consumer if they have understood the form, we might also ask
them to feed the information back to us. We do this because often people will say
they have understood when they haven’t. Where someone hasn’t understood we will
break the information down for them into sections, always using appropriate
language. The exact words we use depend on the capacity of the particular
consumer.
These practices are so important to building confidence and trusting relationships
with consumers. It’s important that they understand a form before they sign it and
understand their privacy rights. So we’re also explaining that with rights come
responsibilities, which is important for them to be able to transfer this knowledge to
another situation. It may take a bit of repetition and explaining, but taking the time to
do this is really important.
Now, we have also developed a specific agency privacy policy that documents how
as an agency we adhere to the Privacy Act. We haven’t always had this but we had
a new staff member who wasn’t used to dealing with privacy issues and she
approached other staff about our practice in this area. Sometimes it’s something as
simple as this that triggers a change in our practice. Something that makes us stop
and think about how we can get better at what we do. We realised how important it
is to remember that not everyone will be used to working in this context and aware of
how to adhere to the Privacy Act – we decided we needed our own document.
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We need to be good at what we do but we also need to be good at showing we’re
doing what we say we’re doing.
Privacy training, Nova Employment and Training, NSW
We have a three tier approach to privacy. Firstly, staff are trained in what privacy
means, using scenarios to emphasise important points. Secondly, the physical layout
of our organisation has been altered to allow for private spaces. Thirdly, we have
ongoing training participants/supported employees relating to their rights to privacy.
Staff are trained to deliver information on all the Disability Service Standards,
including privacy.
Consider these questions:



Do all staff members understand their obligations relating to privacy? How do we
know?
Do all participants/supported employees understand their rights relating to
privacy? How do we know?
Do we offer induction and refresher training in privacy issues?
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Standard 5: Participation and integration
Indigenous Disability Advocacy Service (IDAS)
As a community service, we make sure that we keep our consumers informed of
what is going on in their local communities. We keep them up to date with
events and what is available. For example, we might let them know about men’s
groups, carer’s meetings and workshops or training to help them work with their
children. Then there are events like NAIDOC week to get involved in. We run
information stalls to promote our service and invariably new consumers are
enlisted on these days. There might be sessions in communities where a
representative from the Ombudsman’s Office speaks to Indigenous people with
disability about making complaints. IDAS has a complaints process which is
explained to our consumers and which would end with the Ombudsman if no
resolution could be found.
We know the local communities and what is going on there. We’re always
networking in the community and with other organisations – we’re made aware of
lots of events through networking. We also find out about things through email
and the web. The web is fantastic because we’re getting information all the time.
We keep our eyes open for things that are coming up and, as soon as something
does, we let consumers who would be interested know about it. If there is
something in their area and relevant to them, we encourage them to get involved.
We try to keep our consumers knowledgeable of what they can access and
assist with support. IDAS is currently developing a consumer-friendly service
directory which should be in circulation within the next few months. One of our
consumers participated in “Shoulder to Shoulder” an initiative of the NSW
Government, Stronger Together.
We think of our agency as a family. Because we know our consumers on a
personal level, we don’t have to search through our entire database to know who
would be interested in a participating and who wouldn’t. Our personal
relationship with our consumer, in keeping them informed, builds rapport and
reassures them that they are important to us, which fosters the consumer’s
confidence in IDAS doing our utmost for them.
Knowing our consumers well also means they always lets us know what is
happening and whether they are getting the right service. If our consumers are
not happy with the agency, they feel confident in letting us know. This is
something we encourage. We assure our consumers that complaints are
welcome as they only serve to better our agency. IDAS has a good reputation
and we intend to keep it.
Our advocacy work is very relationship based. Our practice involves respectful
listening – by being heartfelt in our communications, our consumers know that
we care and they feel that they are being heard. Quality listening is an important
aspect of our service as Aboriginal people’s needs are complex; it’s like throwing
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a pebble in a pond, there is never just one issue, issues keep spiralling outwards.
Respectful listening means that we can get to the bottom of our consumer’s
issues. For example, issues around not having a voice, not being heard when
accessing mainstream services. As Aboriginal advocates our role is to speak up
for our consumers to ensure their voices are heard.
Aboriginal people have different ways of communicating and thinking. When
accessing mainstream services, some consumers feel misunderstood; not
educated enough; that their voice is not being heard; and that the service does
not understand our Aboriginal “way of being”. Feelings of intimidation and fear
due to past history can stand in the way and keep our consumers from using
mainstream services. That’s why individual advocacy is so important because
we can act for our consumers and get the results that they cannot achieve on
their own.
People often ask me how they can better communicate with Aboriginal people. I
can teach the way things are done but essentially one needs to be Aboriginal to
understand. IDAS staff are Aboriginal people and, as such, we understand that
providing time for consumer’s stories to come out is essential. Most times we sit
with a consumer for several hours before the main issue surfaces. For example,
one of our consumers didn’t want her child to undergo an intrusive assessment
that was required by a disability service agency to continue to provide services.
The agency didn’t want to take the support away, but they needed the
assessment. Through sitting with, and listening to, the consumer, I eventually
got to where the problem lay. The mother thought that her child was the only
one who had undergo this procedure; she didn’t understand that it was standard
practice.
In this case, I was able to act as a go-between. In assuring the mother that all
the other children had to have the assessment done she was then happy to
cooperate and the services were able to continue. Basically we act on any issue
that the disabled consumer is experiencing. In some cases, it might be as simple
as liaising with an electricity or telephone company in regards to overdue
accounts and making an alternative arrangement rather than having their
electricity cut off.
Individual advocacy is the most appropriate form of advocacy for people with
disability from Indigenous communities. We have consumers who have tried to
self advocate, but have not been able to get results. They feel as though they
haven’t been listened to and they haven’t got a voice. There are a lot of issues
around this and I couldn’t say for sure what the explanation is, but it could have
to do with people’s perceived ideas of Indigenous people. Once we step in and
act on our consumer’s behalf in most cases the consumer gets the desired
results. We do make a big difference in improving their lives.
Quality management in our agency is important to us. We care about our people
and want to get the best outcomes possible. When our consumers turn around
and tell us with heartfelt thanks that we have been a “blessing”, it truly makes all
the hard work worth every moment.
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Standard 6: Valued status
Disability Advocacy Network, NSW
There are so many things that make up valued status. It relates to integrity and
treating people with disability the same way as other people – no more, no less.
Promoting valued status just takes a common sense approach. As advocacy
agencies, there are many ways that we can promote valued status.
Over a decade ago, we started thinking about ways to celebrate the International
Day of People with a Disability. What began as a small party within the deaf
community in Wagga has grown to a large Dance Party for people with disability of
all kinds from across the region that our agency covers. We have had
approximately 300 people attending for the last three years.
We applied for and now receive a community development grant from the local
council. We work with a very small budget and we work hard to raise funds or to get
businesses to donate products like food and drink for the party. In 2008, we also
received a contribution from FaHCSIA. Funding helps pay for the venue, bus
transport for people in the outreach areas, and carers for some of those attending.
You don’t have to have a lot of money to do something like this, just commitment.
We form a “Celebration of Ability” steering committee each year to organise the
party. We include people with disability on the steering committee to help make the
decisions. Our staff and staff from other disability services organise the party in their
own time. We could get paid but we don’t want to, doing it voluntarily shows how we
value people with disability. A high profile community member, like an MP (state or
Federal) or the Mayor or whoever is available opens the night's proceedings and
guests are able to talk to them.
The party celebrates and includes people with disability and shows that they can do
these things too. It celebrates their ability. Even the people in wheel chairs dance! If
we as advocacy agencies don’t give people with disability opportunities to
participate, how will they be appreciated and valued by the community?
Another thing we do is talk to people with disability at disability employment agencies
and group homes, so that they know their rights and have the confidence to
complain when necessary, or to access other services if they need to. This helps
ensure that they can be independent and have confidence to do the things that they
need to. If consumers are not successful in achieving this, it leads to poor personal
outcomes and self-worth, as well as enforcing the stigma associated with people with
disability in the community.
We also run community education presentations at schools and TAFE about
disability awareness. People with different types of disability and disability agencies
representatives (e.g. Vision Australia, Better Hearing, Mental Health, Carer Respite)
talk to the students.
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We bring wheelchairs, walking aids, hearing aids, a hearing loop and glasses that
simulate vision impairment so that the students experience what it would feel like to
have a disability. We talk about myths and stereotypes and tips for communicating
with people with disability.
Valued status is more or less about communication and inclusion. If someone
ignores you or speaks disrespectfully to you, that’s not valuing your status. We talk
to the students about communication – not treating a person with disability as if they
were a child, not yelling at them. If we impress this attitude on students then
hopefully they will communicate well with people with disability.
In terms of communication, it’s also important to think about the language you use –
communicate clearly and don’t use a lot of jargon. Print your agency’s information
and pamphlets in plain English and in other languages that are relevant to your local
community. If people can’t understand the information that is supposed to be for
them, they won’t feel valued.
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Standard 7: Complaints and disputes
Sussex Street Community Law Service Inc
When consumers come to an initial interview, they are informed about our
complaints procedure and where they can access more information. They also
receive a hand-out outlining the complaints procedure. Where a consumer has
made a complaint and is unhappy with the result they can also arrange to speak
directly to the General Manager about the matter if they would like.
About twelve months ago, we introduced exit surveys. If a consumer comes for a
one-off visit they are given the form at the end of that visit, while consumers assisted
over a period of time are given the form at the end of their case. Consumers get the
survey and a stamped, addressed envelope to take home and return anonymously.
As well as some basic demographic information, the survey asks consumers to
comment on our agency. Questions include: how easy was it to contact the agency;
how quickly did we respond to them; how did we treat them; did they understand the
advice we gave; and did they find that advice useful? The responses allow
consumers to choose between a range of answers and also allow room for them to
provide further comments to support their answer.
If consumers wish to make a complaint, there is also a feedback folder in reception
where they can take a form and submit it. We weren’t getting much in there, which is
one of the reasons we introduced the exit survey. People can take the survey home
and reflect on whether they have something to complain about. It’s more confronting
for people to submit a complaint in the reception area. Some consumers are
disgruntled rather than extremely upset and they don’t want to make a fuss so they
wouldn’t submit a form, but they might take the survey home to fill out.
We can’t expect everyone to return the survey, but we generally receive about 20
per month. The surveys are collated monthly and staff are given general feedback.
However, where there is a negative comment, we generally wouldn’t wait until the
end of the month to deal with it.
If an individual raises a particular issue, it is discussed with the relevant advocate.
Addressing the issue straight away makes it easier to deal with because we can
identify the context and discuss what we can do. For example, if a consumer
comments that we were slow to respond, we consider whether we were particularly
busy at that time and what could have been done. If a consumer was
uncomfortable, we might consider whether there is something we can change in
terms of our procedures.
If a broader issue comes through in a few surveys, we’ll address it on an agency
level. For example, there was a period where there was difficulty with phone calls
getting through to the agency. People complained about having to wait too long
before being transferred so we changed the phone system, making it quicker to
divert from one phone to another.
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The survey is a very useful tool to do something automatically. It might identify a
problem we wouldn’t have been aware of otherwise. It is a really good tool for
continuous improvement.
Feedback is a real pointer to how your business is going. It’s easy to get lots of
positive comments on a regular basis and not look deeper into your practice. If
you’re continually patted on the back, you don’t necessarily stop to think about
whether you’re pleasing all of your consumers. You might not stop to see that a
minority of them are disaffected.
With the exit survey, more often than not, we do get really positive comments and
that’s important for the advocates to see where they’ve helped or been particularly
understanding.
Targeted feedback and investigating feedback trends68
We believe that having a strong mechanism for complaints and feedback is
necessary for the organisation to be able to improve. Our feedback system used a
survey sent out to all participants and employers asking them to rate the organisation
on a 1–5 scale in different areas. We found that the positive responses were
unreasonably high, which did not allow us to get the information we needed about
where we could improve. Our strategy was to begin to target questions towards
areas of potential weakness or negativity to try and bring issues more to light. We
also began to investigate trends in the middle of the 1–5 scale, that is, areas that
were described as “OK” by participants and employers. This allowed us to make
better use of our feedback for the organisation.
Job Support NSW,
Disability Employment Services provider
Consider these questions:




Do we have an organisational culture that values complaints and feedback?
Do we link complaints to continuous improvement?
How useful is the feedback we receive?
Could we target our feedback mechanisms to explore areas where we feel
there are organisational weaknesses?
*68 Quality Strategy Toolkit for Disability Employment and Rehabilitation Services, FaHCSIA:
https://www.fahcsia.gov.au/sa/disability/pubs/employers/Documents/quality_strategy_toolkit
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Standard 8: Agency management
8a Corporate governance
Defining Board/CEO Roles
Aware Industries, NSW
Australian Disability Enterprise
We were concerned that our Board should have its own separate sphere of
operation from our management and CEO. We use a system called the “policy
governance model”, which defines the specific and separate responsibilities of the
Board and CEO, as well as how they engage with one another. The aim of this is to
allow the Board to hold the CEO accountable regarding financial and quality
measures, while giving the CEO and management sufficient creative freedom to
perform his/her own job. We have found that this structured approach to Board–CEO
relations works well to eliminate inefficient overlap, and allows both the CEO and
Board to do better at fulfilling their own functions.
We have also found it effective to set a work program for the Board at the start of
each year. This way, Board members know when particular issues will be covered,
allowing them to work through issues in a more systematic way.
8b Quality management systems
Regional Information and Advocacy Council, Victoria
It’s important to put the foundations in place before you build. Good agency
management means clear management roles and responsibilities; sound
administration practices; formal systems not dependent on individual staff members;
and taking opportunities to improve.
It’s important that it’s more than rhetoric; that there are solid practices to back us up.
It takes time to do things properly. To continue providing better advocacy, we need
to focus on good management systems, not only current advocacy provision.
Four years ago, we started looking at our management systems, beginning with the
Board; working from that overall organisational level down.
There was a lack of clarity around management roles and responsibilities so we
implemented an annual corporate governance program for the Board – a corporate
governance trainer now spends one day a year with the Board. So the Board is
clear about their role in providing strategic management, and about operational
management issues that aren’t in their role to consider. Having the annual update
tops up existing Board members’ knowledge and educates new Board members.
Next, over a seven month period, we put resources into getting a comprehensive
suite of policies and procedures together. So these remain up-to-date, the Board
reviews them annually. Each of our three offices (Shepparton, Bendigo and Swan
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Hill) can access policies and procedures electronically via a shared drive. Each
office also has a hard copy, which is updated when changes are made.
The distance between offices can be a challenge, but we focus on making sure the
communication flows evenly between offices. We organise face-to-face team
meetings monthly, which are important to cover issues, reinforce policy and practice,
and provide debriefing for advocates. As we have grown and have more employees,
we’ve also made sure there is a structure in place for management and clear lines of
reporting to ensure clarity and accountability.
It’s important to have the basics right, for example, having good administration
practices in place. We’re disciplined about keeping an organised filing system,
updating consumer files, and documenting important information in consumer files.
All consumer files include an Intake form which includes details relating to the
consumer, the issue they are seeking assistance with and details including their
consent for their information to be shared and with whom.
Good management also involves finding more efficient and effective use of time and
resources – making good use of the resources we have. For example, thinking
about the way we collect consumer data centrally so that we can adapt it to use for
all of our
different reporting requirements to funders.
In terms of improvement, we’re just beginning a quality improvement partnership. We
identified two other Victorian advocacy agencies that are on the same page as us
and approached them about the partnership – they were very enthusiastic. We held
our first meeting in February and will meet on a monthly basis to progress.
We will work to develop performance standard measures for each year for an initial
three year period. The plan is to develop a set of minimum standards and self and
peer assessment tools we can each use to assess our agencies.
Once it is developed, each agency will be able to use the self-assessment tool to
assess their compliance with the performance standards. The Manager/CEO of one
quality improvement partnership member agency will conduct a peer review of
another member agency in March each year using the peer assessment tool.
Following the review, a report will be forwarded to the Board Chair and
CEO/Manager for rectification and each July, the three Board Chairs and
CEOs/Managers will meet to verify the rectification is complete.
The kinds of things we’ll assess are policies, procedures, practice and reporting.
The idea behind the peer review is that although we think we’re doing pretty well,
another agency might see a hole that we haven’t considered. By giving the results to
the agency’s Board they will be able to see where things are working and where
there are problems.
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Citizen Advocacy South Australia
We have developed and documented a vision of where we want to be in the next five
years and how we want to get there. Working towards this vision keeps everyone
focused on a united goal and on where we’re going.
Planning and review are also key to management. We undertake strategic planning
every three years; annual forward planning; annual Board program review; annual
relationship review; bi-annual work flow review that preserves the focus on
developing and sustaining citizen advocacy relationships and the organisational
capacity to respond to the needs of vulnerable people with intellectual disability.
Our practice evolves based on learning and environmental changes, for example, in
relation to contemporary management practice. In reviewing our practice, where we
find a weakness, we work to address that and identify the resources we need to help
us do this. We think about the skills we need and seek out people with experience to
advise us and to learn from.
As a program we also focus on change management; identifying and seeking out
people to advise us who may later become program associates who contribute to
ensuring longevity. These associates may provide advice to the Board in areas
including management, policy and government. As with anyone associated with
CASA other than staff, they give their time freely because they believe in what the
program is doing. We have found that having program associates around us helps
to remain informed on some of the broader issues and to minimise staff time away
from the core function.
From time to time, we have engaged paid professionals for some issues. For
example, we needed someone with experience to lead us through our strategic
planning process so we hired a consultant. The OHS&W Audit was conducted by a
registered auditor and a 12 month implementation plan was produced for Board
consideration.
In our view, Standards for Citizen Advocacy Program Evaluation (commonly referred
to as CAPE) is also an important part of practice review. In our experience, CAPE
assesses what a citizen advocacy program is doing, where the strengths and
weaknesses are and makes recommendations that are designed to improve the
program’s implementation of citizen advocacy over time. It encourages continuous
improvement and contributes toward quality improvement. It all comes back to
strengthening the probability that vulnerable people with disability will be matched
with the most suitable citizen (the advocate), who will be supported by a program
that is clear on its own role, independent and knows what it’s doing. It all impacts on
the person with disability.
The CAPE process we have undertaken has been a five day process, conducted by
a team of six made up of a team leader (who is experienced in CAPE evaluation
leadership) and other members who may be a mixture of coordinators and/or Board
members from other citizen advocacy programs. We look at it as peer review –
inviting people who do the same work as us in other places to come and listen to
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what we are doing, talk to people being supported by the program and then give us
some honest feedback. Sometimes when you’re heavily involved with what you’re
doing, you can be missing something, and as humans we all tend to focus on what
we’re doing well.
As part of the process, staff are interviewed extensively, and all Protégés, Citizen
Advocates, Advocate Associates, Program Associates and Board members are
given the opportunity to participate and be interviewed by members of the CAPE
team. The team rate the program against criteria in three categories: adherence to
the principles of citizen advocacy, office effectiveness, program continuity and
stability. After the evaluation is completed, the CAPE team leader compiles a written
report of the team’s findings and recommendations for the Board’s consideration.
8c – Continuous improvement considerations
Quality Improvement Partnership (QIP)
In 2008 the Regional Information and Advocacy Council (RIAC) which operates in
regional Victoria, was keen to assess the quality of its policies, procedures and
practice by benchmarking with advocacy agencies with similar interests in quality
improvement.
It commenced the process by speaking with and identifying possible partners
interested in participating in a network. After receiving a generally positive response
the following steps were taken to design how the Quality Improvement Partnership
(QIP) would work:
Step one – design a Memorandum of Understanding to outline how the QIP would
operate- this included each agency signing the MOU. The general principle
established was for an equal sharing in the work of the QIP and for individual
member agencies to be responsible for any costs associated with the QIP. The MOU
also contained a Complaints Resolution procedure.
Step two- It was agreed that each QIP member would participate in bi-monthly
teleconferences, with the responsibility of organising the teleconference (and paying
for it), developing an Agenda and taking Minutes. The teleconference was used to
discuss policy, procedure and practice issues facing QIP members and would often
result in the sharing of information (and policies and procedures) between member
agencies.
Step three – the development of a QIP Peer Assessment toolkit with which to
undertake annual peer assessments of QIP members. The QIP toolkit was initially
developed using the Draft Disability Advocacy Standards, and now uses the final
Disability Advocacy Standards. Each year (in approximately April) a QIP member
would visit another QIP member and undertake a peer assessment of the QIP
member’s compliance with the standards. (This is not as rigorous as a NDAP QA
audit as it does not involve interviewing consumers). The cost of the peer
assessment is borne by the assessing agency. The assessor is to provide a report to
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the agency to be assessed detailing its compliance in relation to the standards. All
QIP members are assessed at a similar time.
Step four – In approximately August of each year, the Managers and Chairpersons
of the QIP members to meet together to confirm that any deficits identified during the
Peer Assessment had been corrected, and to develop a work plan for the QIP for the
following year. This meeting has proven valuable as it has developed a network
among Board Chairs to share information relating to Board training, Managers
Performance Evaluation, etc.
Membership
Currently the membership of the QIP consists of the following members:
 Regional Information and Advocacy Council (RIAC);
 Disability Advocacy and Information Service (DAIS);
 Disability Advocacy NSW;
 Advocacy Tasmania;
 The Speakout Association of Tasmania; and
 People With Disabilities Inc (PWD)
Conclusion
The QIP has proven to be a very effective means of ensuring a continuing focus for
all members on the need for continuous improvement. It provides a means for the
sharing of information and has made the development of policies and procedures an
easier and more efficient process. It has also meant that through the annual QIP
Peer Assessment evaluation member agencies have become very familiar with the
Standards and audit processes. All members participated in a 1 day auditing training
course in Victoria in 2011.
The QIP encourages the development of similar networks of advocacy agencies to
assist with the preparation of policies, procedures and practices and the NDAP QA.
It has been the consistent view of the QIP that compliance with the Standards should
be the major focus of all agencies in ensuring that consumers and staff are
effectively and appropriately supported, and by so doing the NDAP QA audit
becomes a far smaller issue.
In 2012 some of the QIP members will be undertaking an exchange of Advocates
between member agencies.
For further information please contact Steve Doran, Chief Executive Officer, RIAC on
0358 221 944.
8d – Policies and procedures
This section contains ideas and practices related to Standard 8 that have been put
into place by different disability service providers. Although these are not disability
advocacy agencies, the learnings from these disability employment services are
useful. They are not intended to be prescriptive, but may help you think of ideas to
develop your own policies and procedures
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Disability Services Australia, NSW
Australian Disability Enterprise and Disability Employment Services provider
We have done substantial work to make the Disability Services Standards the centre
of our corporate policies. Our policies detail the organisation's responsibilities against
each Standard. That also means that whenever we create an operational procedure,
it automatically rubs up against the Standards.
We have centralised all of our policies, procedures and forms in a private intranet
site. This site mirrors the organisation's shape, so that everyone can find what they
need to do their jobs, as well as finding out what applies in different parts of the
organisation. This ensures consistency in the organisation and also makes certain
that no one is using out-of-date forms.
Tulgeen Disability Services, NSW
Australian Disability Enterprise
When we were first going through QA Certification back in 2003 we decided to
rewrite and replace our existing policies and procedures manual with 12 stand-alone
manuals based around the 12 Disability Services Standards. The advantage of
presenting policies and procedures manuals this way is, when our staff look at the
policies and procedures, they are looking at the Standards at the same time, so it's
all integrated. Each of the 12 manuals include information about additional
supporting resources as well as a copy of all forms staff will need, and they are all
cross referenced to the other relevant manuals, this way staff get to see the big
picture. The handbooks are also displayed in a hanging file system, which means
they are easy to handle and to pick up and read.
Phoenix Society, SA
Australian Disability Enterprise
Because we comply with multiple quality systems, we have tried to find the most
efficient system possible for dealing with the different requirements. What we have
found works is to integrate all the different elements into our own internal policy and
procedures manuals. Then, on the relevant pages of the manual, we have a
reference to explain which quality system element this procedure relates to. That
way, when it comes time to gather evidence for an audit process, we know where we
need to go for the information. Where a particular quality system has something
idiosyncratic, we explain that too, in a separate paragraph. Not all of our systems
can be completely integrated this way, but we do manage to consolidate a large
amount of material. For instance, our complaints manual contains both information
relevant to Disability Services Standard 7, such how to contact advocates as well as
the Complaints Referral and Resolution Service, and information about where to go
for complaints about OH&S issues.
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Standard 9: Staff, recruitment, employment and training
Citizen Advocacy South Australia
To attract and retain staff, Citizen Advocates and volunteers (i.e. Board members,
Program Associates, Advocate Associates) we believe that it is important to be open
and transparent; to have a clear vision and build on a shared sense of belief in the
work, its importance and a commitment to seeing it done well.
A lot of our work relies on networking and building relationships in our community –
with Citizen Advocates, developing personal contacts of staff, Board contacts and
people who have been identified as supporters and friends of the Program. In recent
years, the same has been the case when recruiting staff i.e. ‘head hunting’ or going
to people known in the broader network who are considered to have some of the
skills and qualities believed to be important to be able to fulfil the role.
Before hiring staff, we also consider what skills or knowledge we don’t currently have
within the agency and seek to appoint someone who can bring a new set of skills
and experiences thus broadening the skill base within the Program.
With the current staff, all have worked in one capacity or another within the field of
intellectual disability. We believe that such experience gives us an insight into the
universal issues confronting people with intellectual disability and a greater
awareness of the challenges and limitations service systems and providers face.
When combined with taking the time to understand each individual in terms of their
needs, identity, strengths, aspirations, such knowledge contributes significantly to
determining the most suitable person to become the Citizen Advocate.
In the main, Citizen Advocates are identified through our network which is constantly
being built upon as Coordinators move throughout the community doing the work.
The process of Citizen Advocate recruitment commences when we believe we have
identified the most pressing need of the person with intellectual disability (Protégé).
In this way, recruitment of prospective Citizen Advocates is highly personalised to
the identity, needs and skills of the Protégé and the probability of a good ‘fit’ with the
identity, skills and interests of a suitable citizen.
Like Protégé recruitment, determining Citizen Advocate suitability is a very strategic
and carefully considered process. Potential Citizen Advocates are offered the
opportunity to learn more about a person in their community and what it would take
to become that person’s Citizen Advocate. Called orientation, the process typically
unfolds over a period of about 4–6 weeks (longer if necessary) and is conducted in
people’s homes and the CASA office. CASA does not expect people to make a
commitment straight away.
Orientation is not only information sharing, it is the beginning of relationship building
with the prospective Citizen Advocate. A relationship that will need to become
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strong so that the Citizen Advocate will openly seek the support of the Program
regardless of whether things are going well or not.
The goal of orientation is to determine the suitability of this person or persons for the
role identified for a specific Protégé. The process is done in such a manner as to
give prospective Citizen Advocates all the information they need to make an
informed decision about their capacity to undertake the role outlined by staff. Should
a person be deemed unsuitable by staff, the person does not become a Citizen
Advocate. Additional to this process is the 2008/09 funding agreement requirement
that all people involved in the program, including Citizen Advocates undergo a
national police clearance.
CASA orientation typically involves four 1.5–2 hour sessions. We present material in
a logical sequence using overheads. All people taking part in the process receive a
copy of the material in a manual to refer to. In recognition of the importance of the
prospective Citizen Advocate to be supported in their future role at home, spouses
and/or partners are invited to take part. In so doing, they too come to understand
how important the role of Citizen Advocate is and they can be supportive of it, thus
further maximising the probability of Citizen Advocate longevity. This strategy has
resulted in more husbands and wives both becoming involved with the Protégé and
therefore broadening the Protégés support base.
Advocate recruitment is so important because, at the end of the day, it’s about doing
the very best we can on behalf of the person with intellectual disability. Citizen
Advocacy staff should have the time needed to carefully think through the process
and then determine the best possible person to invite to become a Citizen Advocate.
However, no matter how much planning a Citizen Advocacy program may put into
the ‘matching process’, things can still go wrong. When this happens, we have
processes in place to try and determine the role we played in things not working out
and why. It’s important to reflect on what role we had in the relationship not working
i.e. what could be done differently next time; was there anything we missed etc. In
so doing, we can work towards minimising the chances of something similar
happening again; recognising, however, that all people are different and their
situations unique.
Performance management including appraisals of all staff as well as a commitment
to ongoing training for Citizen Advocates and other Program volunteers is important
to increase the likelihood of better outcomes for Protégés. Training and
development includes visiting other Citizen Advocacy Programs, including peer
training with other Coordinators; formal training sessions (e.g. governance and
management training for the Board and staff); attending and presenting at
conferences; and being a part of the national and international Citizen Advocacy
network.
Citizen Advocacy Program Evaluation (CAPE) is a great training ground for staff.
Being involved in your own Program’s CAPE is an excellent learning and teaching
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process. Our involvement in internal and external review mechanisms of other
Citizen Advocacy Programs has positively influenced and even changed the way we
think about your own practice.
Ongoing training is important so to minimise the possibility of complacency creeping
in to the practice. For example, staff attend Social Role Valorisation (SRV) training
periodically which reminds us of the universal issues facing people from devalued
groups in our society which in turn challenges our thinking; to become more aware
and more in tune with the things in the community that devalue people with disability;
and to think of ways we can counter this. Citizen Advocates and Program volunteers
are also offered this training opportunity.
Employment appraisal, Edge Employment Solutions, WA
Disability Employment Service
Every time a member of our staff has an employment appraisal, we contact either
three participants they are assisting, three family members and three employers that
they have worked with. That means that for every appraisal, nine people are
surveyed about how the service is working for them. We orient the questions we ask
towards the Disability Services Standards. We use this information not only in the
staff appraisal, but also in a collated form to help us improve organisational
performance overall. This gives us robust evidence about the needs of our
stakeholders, and it also allows us to collect information gradually and continually for
ongoing improvement.
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Standard 10: Protection of human rights and freedom from
abuse
Villamanta Disability Rights Legal Service Inc.
The necessity to protect human rights is one of Villamanta Disability Rights Legal
Service Inc’s foundation beliefs. It underlies everything that Villamanta does. Our
whole service is built on the belief that people’s human rights are paramount. The
reason our service exists is to help people with disability, in particular people who
have an intellectual disability, to get to know their rights and the relevant law and to
learn how to use the law to protect those rights.
The protection of human rights informs all of our policies and procedures. We
believe that having clear, well thought out policies and procedures about how we
manage our service is vital to ensuring we consistently recognise and protect our
consumers’ human rights. The Management Committee would not sign off on a
policy, procedure or document without consideration of human rights. We recently
reviewed all of our policies and procedures as a whole, drawing on a range of
resources for guidance.
When we are writing policies and procedures we do not just make them up, we go to
respected sources. We have drawn on resources from the Eastern Community
Legal Centre (Victoria), which received a grant for a consultant to develop a policies
and procedures manual; the Federation of Community Legal Centres; VCOSS
whose website has some example policies and procedures; and the Law Institute of
Victoria. In Victoria, we also have a Disability Advocacy Resource Unit (DARU),
which is in the process of developing, and setting up, a library of resources which
advocacy agencies can draw on.
We also believe that it is extremely important that we ensure our staff members and
volunteers always treat consumers (and others) with the utmost respect and dignity.
One of the questions we ask people who want to work or volunteer for Villamanta is
“what, if any, are your views on human rights?” We also ask whether they have
experience working with people with disability. That is not to say that people who do
not have that experience cannot work for Villamanta, but they may need training in
that regard before they are able to do a good job for our consumers. Workers and
volunteers need to understand where our agency is coming from. We are not
providing a charitable service for the “down and out”. Our consumers have human
and legal rights and dignity. Our job is to stand up for the rights of people with
disability – and support them to stand up for their own rights - and to redress the
imbalance in society, so that people with disability have the same rights and
opportunities as other people in the general community.
A number of our service’s activities promote the human rights of people with
disability. We provide community legal education (CLE) for people with disability and
their carers. We also provide training on disability related issues for service
agencies as well as the general community. At the CLE sessions we hold for people
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who have an intellectual disability, we provide participants with a free copy of our
booklet ‘Your Rights Your Choices’, produced in plain English, so that they are
aware of, and understand, their rights. The sessions we run for others in the
community aim to teach them about the rights of people with disability and what they
need to do to avoid infringing those rights.
We also work on systemic advocacy issues. For example, in response to the overrepresentation of people who have an intellectual disability in the criminal justice
system, we recently got funding to research and produce a publication to be read by
people working in the criminal justice system (police, courts, judiciary, lawyers and
corrections) to ensure better understanding and treatment of those people who have
an intellectual disability.
Much of our work is done on individual legal cases where the human rights of a
person with disability are not being upheld. It is Villamanta’s view (and that of many
other people) that the rights of a person with disability cannot be met if that person is
placed in an institution. There is an extensive history of abuse of people living in
institutions which clearly illustrates that people’s human rights cannot be protected in
such a setting. For those rights to be fully met the person should be living in the
community with appropriate levels of support. Today there are many community
residential units (CRUs) dotted throughout the community which have gradually been
replacing the large institutions.
We are frequently involved in cases where a CRU placement of a consumer who has
a disability is failing, often including physical abuse. In these cases it is sometimes
suggested that the best option is to place either our consumer, or another resident of
the CRU, in an institution. In such cases we strongly oppose this suggestion. We
have found that when a residential placement is not working it is often because there
has been an inappropriate placement. For example, one person in the residence
may be abusing others who are more vulnerable and unable to defend themselves.
In some cases the abuse comes from a direct care worker. In some cases,
increased and better trained staffing can solve the problem. In other cases, where
this is not so, we lobby the Department of Human Services, or other relevant service
provider organisations, to arrange an alternative and more appropriately supported
CRU placement for the person whose behaviours are causing the problem. We
would always oppose the placement of any of the residents of the CRU in an
institution. We also consider issues of negligence and victims of crime in these
matters.
As a legal advocacy agency, we are different from many other advocacy agencies
that advocate in the ‘best interests’ of people with disability. We are consumer
directed and act on the consumer’s instructions and wishes. Our service considers
that there will always be someone there, such as a parent/ relative or a public
advocate, to indicate what would be in the consumer’s ‘best interests’; we are there
at a tribunal or talking to a service agency to indicate the wishes of the person with
disability. It is about ensuring their voice is heard and they have their human and
legal rights recognised and acted upon. We always aim to communicate with our
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consumer in person using whatever means of communication works best for them.
In cases where it is impossible for us to communicate with the person with disability,
or they have limited capacity, we find families often know how best to communicate
with the person and what their wishes would be. In some cases a guardian is
appointed to make decisions on the person’s behalf and we may receive instructions
from them. We are always careful to check out whether families might have an
ulterior motive for trying to ensure a certain outcome.
If we did not protect the human rights of people with disability, we would be failing in
our work both morally and ethically and we would be doing our consumers a grave
disservice.
Queensland Advocacy Incorporated
The definition of advocacy is to protect, promote and defend people’s human rights.
This comes through in the key elements of advocacy (functioning by speaking out,
acting or writing; minimal conflict of interest; sincerely perceived interests; promotion
of person’s welfare, wellbeing and justice; vigour of action; and costs).
Considering quality practice in this area involves unpacking what things mean. For
example, acting in ‘best interests’ is not about taking away a person’s rights; and
there are differences between expressed need, perceived need and fundamental
need.
Where an action is not considered in someone’s ‘best interests’, a paternalistic
approach would be to block or deny that action; but, as advocates, we work with the
person, discuss the issues and the possible consequences of the actions. It is the
person’s right to be involved in decision making. Also, it’s important to recognise
that the way we perceive a need does not necessarily make it right. As advocates
we must stop and ask ourselves if we’re really pursuing an action in a person’s ‘best
interests’?
There are a range of tools we can use in considering our practice in relation to
human rights – the Convention on the rights of persons with disability (CRPD) social
justice principles; community development principles; and social role valorisation
theory.
Personally I find the vulnerability schema, developed by David Massy, a useful tool
in planning advocacy strategies that recognise, from a systems point of view, how
society is affecting the life situation of the person with disability (e.g. how they are
portrayed by people in power). Other people might not relate to this or certain tools
I’ve mentioned – what is important is finding a tool that best articulates things for you
to help you consider your practice. The issue here is to understand that the
common response to vulnerable people in social policy, political motivated
responses is always to locate the problem in the individual 'blame the victim' as
opposed to understanding the problem genesis arising from exclusion, prejudice,
rejection, fear and hatred of people with disability.
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With increasing workloads, it’s not as easy as it once was, but it’s important to find
the time to reflect on your practice. We try and make time for this in staff meetings.
Or, where there is a particular issue, we may organise a meeting and involve the
staff available.
We also try to organise an external peer review every five years. Where the budget
is not available for this, we’re considering engaging an external consultant to run
some workshops to get feedback from our stakeholders and people with disability
because you have to engage people face-to-face to really get feedback.
Over the last few years, our agency has also developed a set of human rights
indicators for people with disability in consultation with a range of stakeholders,
including people with disability. Now we also have the UN Charter of Rights for
People with Disabilities (CRPD). When we started the project, there wasn’t a set of
human rights indicators for people with disability anywhere, which is surprising
considering there are indicators for women, children and other groups. The human
rights indicators are now another tool we can use in considering our practice as
agencies as well as informing how you shape your advocacy strategies.
Advocacy often is the last resort; the last stop for vulnerable people. Advocacy is
ultimate safeguard for people with disability’s fundamental need and human rights
being upheld in the community and by government. As we will never be able to
provide enough advocacy, it’s important that the advocacy we provide is strong,
clear and coherent.
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5.3 Links to other resources
Standard 1: Accessing advocacy
Policy Templates and Procedures on Community Door
Policy Templates and Procedures relevant to Standard 1 have been developed by
the Department of Communities, Queensland specifically to assist organisations as
they implement the Standards for Community Services. They are a good place to
start for developing policies for this Disability Advocacy Standard (Accessing
Advocacy) and to tailor them to your agency’s needs. The templates and guidelines
are available on the Community Door website.
Culturally Inclusive Service Delivery
This Culturally Inclusive Service Delivery resource is part of the QUT Centre of
Philanthropy and Non-Profit Studies, Developing Your Organisation website.
Access and Equity Policy Template
Here is a link to an Access and Equity Policy which has a strong cultural diversity
consideration component.
MDAA developed resources – Working with multicultural consumers with
disability
MDAA has produced a range of resources to assist you in working with people from
a NESB with disability. The “building Cultural Competence” publication is a brief
standard-by-standard guide including cultural competence across all of the
standards for disability services in NSW.
Standard 2: Individual needs
Multicultural Disability Advocacy Association of NSW, among the resources
available on this website, including information in 10 community languages on their
different communities understanding of disability related issues, there are several
resources prepared specifically to help agencies work with people from Culturally
and Linguistically Diverse (CALD) backgrounds, including a manual on cultural
competency.
National Ethnic Disability Alliance, the national peak organisation representing the
rights and interests of people from CALD backgrounds with disability, their families
and carers nationally. Resources include publications and fact sheets.
Standard 3: Decision making and choice
Policy Templates and Procedures on Community Door
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Policy Templates and Procedures relevant to Standard 3 have been developed by
the Department of Communities, Queensland specifically to assist organisations as
they implement the Standards for Community Services. They are a good place to
start for developing policies for this Disability Advocacy Standard (Decision making
and choice) and to tailor them to your agency’s needs
How To: A Practical Guide to CALD Consumer Participation
The link provides a work sheet that has different strategies to encourage effective
participation from CALD consumers.
An Introduction to consumer participation by the National Resource centre for
Consumer Participation in Health, 2002.
This fact sheet covers definitions, benefits, models and methods, barriers to
participation, and evidence of effectiveness.
Effective Engagement
The Victorian Government has produced three downloadable books to “assist
service users to take part in making decisions that affect them”:
Standard 4: Privacy, dignity and confidentiality
Information Privacy Principles, Australian Government, Office of the Privacy
Commissioner, Public Sector Information Sheet - Information Privacy
Privacy Act 1988 (latest version), including Information Privacy Principles, ComLaw,
National Privacy Legislation for Not-For-Profits
This link provides useful information for not-for-profit organizations including a
‘privacy checklist’.
Privacy Templates and Information
Our Community is a world-leading social enterprise that provides advice and tools for
Australia's 600,000 not-for-profit community groups and state, private and
independent schools, as well as practical linkages between the community sector
and the general public, business and government. A range of information around
privacy considerations, including sample templates are provided.
Policy Templates and Procedures on Community Door
Policy Templates and Procedures relevant to Standard 4 have been developed by
the Department of Communities, Queensland specifically to assist organisations as
they implement the Standards for Community Services. They are a good place to
start for developing policies for this Disability Advocacy Standard (Privacy, dignity
and confidentiality) and to tailor them to your agency’s needs.
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Worksheets for the National Privacy Principles (NPP’s)
The Quality Strategy Toolkit for Disability Employment Services provides worksheets
designed to develop a working knowledge of the NPP’s. The worksheets also
compare the National Privacy Principles with the Information Privacy Principles
(IPP).
Standard 5: Participation and integration
Inclusion Works – a community organisation that aims to build better communities
through the inclusion of people with disability. The publications/ articles page has a
range of information resources on community inclusion that you may find useful.
Nican – provides information on its website about recreation, tourism, sport and the
arts for people with disability nationally, with the aim of creating links that improve
access to recreation experiences for people with disability and their communities.
Community Development and Community Education guidance is available on
the Community Door website.
Community Inclusion is discussed on the Our Community website with reference to
a wide variety of resources.
Standard 6: Valued status
Disability WA, Disability Services Commission has a range of training resources
around their Disability Services Standards, including Valued Status.
Standard 7: Complaints and disputes
Policy Templates and Procedures on Community Door
Policy Templates and Procedures relevant to Standard 7 have been developed by
the Department of Communities, Queensland specifically to assist organisations as
they implement the Standards for Community Services. They are a good place to
start for developing policies for this Disability Advocacy Standard (Complaints and
disputes) and to tailor them to your agency’s needs. The templates and guidelines
are available on the Community Door website.
The Complaints Resolution and Referral Service
VOICE – Valuing Organisational Improvement and Community Excellence
This resource has a special emphasis on Indigenous managed organisations, and
has an excellent template for a complaints policy and consumer feedback sheet.
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Complaints Handling System – Developing Your Organisation
Collecting Feedback – Community Toolbox - this American website has some
simple and creative ideas to collect consumer feedback.
Standard 8: Agency management
Corporate Governance Handbook for the Board, FaHCSIA, 2nd edition, 2010, for
more information on corporate governance:
The Council on Quality and Leadership - has resources on leadership and Board
development available on their website.
Disability Services Queensland, for tools and resources
The Disability Advocacy Resource Unit (DARU), Victoria
The National Association of Community Legal Centres’ National Management
Committee Guide for Community Legal Centres
Volunteering Queensland, a range of resources for organisations recruiting and
involving volunteers
Community Door has an extensive range of generic templates and guidelines
addressing corporate governance.
Victorian Employers’ Chamber of Commerce and Industry (VECCI) produce
training on Corporate Governance which has been highly recommended by disability
advocacy agencies.
Our Community website provides further information on corporate governance:
Standard 9: Staff, recruitment, employment and training
Best Practice guidelines for creating a productive workplace environment were
created by the Human Rights and Equal Opportunities Commission (HREOC – now
known as the Australian Human Rights Commission - AHRC). You can use them to
assess the systems and practices at your agency and consider how you could
improve.
Employing People – DYO managed by the QUT Centre of Philanthropy and NonProfit Studies, the DYO site deals with Employing People and has subsections under
Recruitment of Staff, and Employment Issues.
Recruitment Policy Template – Our Community
The Our Community Policy Bank website has a nine page recruitment policy.
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Volunteers (Help Sheet)
The Australian Institute of Community Practice and Governance website provides a
help sheet on why screening of volunteers is important.
Standard 10: Protection of human rights and freedom
from abuse
Queensland Advocacy Incorporated, Human Rights Indicators Project, Easy
English booklet on Human Rights ‘Everyone has human rights Understand Yours!’
Public guardianship bodies in all states/territories
In each state and territory there is a body which facilitates the appointment of a
public guardian in situations where an individual may lack decision making capacity.
Where necessary, you should refer to the relevant Office in your state/territory.








ACT: Office of the Community Advocate
Queensland: The Adult Guardian
Northern Territory: Office of Adult Guardianship
NSW: Office of the Public Guardian
South Australia: Office of the Public Advocate
Tasmania: The Office of the Public Guardian
Victoria: Office of the Public Advocate
Western Australia: The Public Advocate
Information on the Convention on the Rights of Persons with Disabilities
Australian Human Rights Commission
National Anti-Discrimination Information Gateway
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Section 6: Complaints handling
mechanisms
6.1 Complaints associated with the NDAP Quality
Strategy
Strong and impartial complaints and appeals processes are vital components of the
Quality Strategy.
The following contacts may be important where disability advocacy agencies wish to
make a complaint about certification or issues relating to their relationship with their
funding body.
The Easy Read Guide to Quality Assurance and auditing of the National Disability
Advocacy Program (available on the FaHCSIA website) provides advice to people
with disability about how they can complain about aspects of the audit process
Australian Government Department of FaHCSIA
What it investigates: The Department of Families, Housing, Community Services
and Indigenous Affairs (FaHCSIA) has complaints handling mechanisms which
disability advocacy agencies can access. The types of issues disability advocacy
agencies may complain to FaHCSIA about include:
1. funding issues
2. complaints about the Complaints Resolution and Referral Service
3. complaints relating to departmental contract management
How to contact them:
FaHCSIA National Office Complaints Team
Phone: 1800 634 035
Fax: (02) 6133 8442
fahcsiafeedback@fahcsia.gov.au
Further information about the types of complaints that can be made by the public
about FaHCSIA’s service(s), or the services of a FaHCSIA funded service provider
can be found on the FaHCSIA website.
Certification Bodies
Types of complaints: Certification Bodies are required to have an internal
complaints handling system. The types of complaints that disability advocacy
agencies might make to a Certification Body could include (in the first instance):
•
•
complaints about audit results
complaints about certification revocation or suspension
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
complaints about the conduct of an audit team.
How to contact them:
Refer to the JAS-ANZ website for details of accredited Certification Bodies.
Joint Accreditation System of Australia and New Zealand (JASANZ)
Types of complaints: You can contact JAS-ANZ with a complaint about a
Certification Body if you are not satisfied with the outcome of the Certification Body's
complaints process. The types of complaints might include:



complaints about audit results
complaints about certification revocation or suspension
complaints about the conduct of an audit team. JAS-ANZ does not have
authority to overturn a certification decision, although it can question the
judgement of the Certification Body and reassess its accreditation status if
accreditation requirements have not been met.
How to contact them:
Tel: 02 6232 2000
Fax: 02 6262 7980
Mail: GPO Box 170 Canberra ACT 2601
Administrative Appeals Tribunal (AAT)
What it investigates: If you are not happy about a decision FaHCSIA has made
under the Disability Services Act 1986 (Cth) you may be able to lodge an appeal with
the AAT. The AAT provides independent review of a wide range of administrative
decisions made by the Australian Government and some non-government bodies.
How to contact them:
Tel: 1300 366 700
Email: aatweb@aat.gov.au.
Postal contact details for Offices in each state are available from the AAT website.
Commonwealth Ombudsman
What the Ombudsman investigates: The Commonwealth Ombudsman can
investigate complaints about the actions and decisions of Commonwealth
departments and authorities to see if they are wrong, unjust, unlawful or
discriminatory or unfair. The Ombudsman also seeks remedies for those affected by
defective administration, and acts to improve public administration generally. This
means that the Ombudsman can look at complaints raised by service providers
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about the way FaHCSIA has dealt with them. The Ombudsman cannot override the
decisions of agencies, or compel them to comply with his or her recommendations.
However, agencies generally do accept the Ombudsman's recommendations.
How to contact the Ombudsman:
Tel: 1300 362 072
Postal contact details for Offices in each state, and an online complaints form are
available from the Commonwealth Ombudsman's website.
6.2 External referrals
Although most complaints from people with disability should be handled by disability
advocacy agencies in the first instance, particular complaints may require an
external referral.
In the case of complaints that have not reached a resolution through the agency's
internal systems, the Complaints Resolution and Referral Service (CRRS) will often
be an appropriate external referral.
This section provides information about the CRRS and some other complaints
handling bodies that may be useful to you when seeking to make an external
referral.
The Complaints Resolution and Referral Service (CRRS)
What it investigates:
CRRS is an independent organisation funded by the Australian Government to
resolve and investigate complaints about service providers relating to the Disability
Advocacy Standards, Disability Services Standards (FaCSIA) 2007 and Disability
Services Standards (DEWR) 2007. The CRRS encourages and supports the local
resolution of complaints, but can facilitate conciliation between parties or investigate
complaints when local resolution is not appropriate.
How to contact the CRRS:
Phone: free call 1800 880 052
Fax: 02 8412 7199
TTY: free call 1800 301 130
Mail: PO Box 126 St Leonards NSW 2065
Email: crrs@workfocus.com
National Relay Service: Call 1800 555 677 and ask them to call the CRRS for you.
Translating and Interpreting Service: Call 13 14 50 and ask them to call the CRRS
for you.
The CRRS website has further information
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The National Disability Abuse and Neglect Hotline
What it investigates: The Hotline is a single contact point for anyone to report
claims of abuse and neglect in government funded services. The Hotline refers
complainants to other relevant agencies, such as FaHCSIA or the police. Its role is to
provide support and a link between the complainant and the service.
How to contact the Hotline:
Phone: Free call 1800 880 052
Fax: 02 8412 7199
TTY: Free call 1800 301 130
Mail: PO Box 126 St Leonards NSW 2065
Email: hotline@workfocus.com
National Relay Service: Call 1800 555 677 and ask them to call the Hotline for you.
Translating and Interpreting Service: Call 13 14 50 and ask them to call the Hotline
for you.
The Hotline website has further information.
Police
When to contact them: Any issue that arises at a service where there may have
been a criminal act should be referred to the police. This might include:
 any action that in the normal community sense would involve reference to the
police
 sexual assault/harassment
 alleged physical abuse
 fraud.
Where criminal activity may have taken place the case should also be referred to the
relevant department. The Department of Families, Housing, Community Services
and Indigenous Affairs (FaHCSIA) will not investigate the criminal element of the
allegation but will make sure that an agency is still meeting its contractual obligations
(including meeting the Disability Advocacy Standards).
How to contact the police:
Refer to the police service in your local area through the Government Services
section of your phonebook (by looking under 'Police'); or refer to:
NSW Police Force
Australian Federal Police
Queensland Police Service
Northern Territory Police
Western Australia Police
South Australia Police
Tasmania Police
Victoria Police
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The Australian Human Rights Commission (AHRC - formerly
HREOC)
What it investigates: The AHRC can deal with complaints about discrimination
under any of the four Acts administered by the Commission: Human Rights and
Equal Opportunity Commission Act 1986 (Cth), Sex Discrimination Act 1984 (Cth),
Racial Discrimination Act 1975 (Cth) and Disability Discrimination Act 1992 (Cth).
Each of these Acts has Specific grounds for complaint including race, sex,
pregnancy, marital status, disability, sexual reference, age and trade union activity.
How to contact them:
Phone: 1300 656 419 (local call) or 02 9284 9888
+Fax: 02 9284 9611
TTY: 1800 620 241 (toll free)
Email: complaintsinfo@humanrights.gov.au
Free interpretation and translation services are available by contacting 13 14 50 and
asking for the Australian Human Rights Commission.
WorkCover/SafeWork authorities
What they investigate: If you cannot resolve complaints about occupational health
and safety within your agency, complainants can contact state-based authorities.
These authorities provide information and complaints-handling relating to
occupational health and safety (OH&S) issues.
How to contact them:
WorkCover/WorkSafe ACT
Phone: (02) 6205 0200
Fax: (02) 6205 0336
Email: workcover@act.gov.au
WorkCover NSW
Phone:13 10 50
NT WorkSafe
Phone: 1800 019 115 (free call)
Email: ntworksafe.deet@nt.gov.au
Qld Workplace Health and Safety
Phone: 1300 369 915
SA SafeWork
Phone: 1300 365 255
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Tas WorkCover
Phone: 03 6233 7657
Fax: 03 6233 8338
Email: wstinfo@justice.tas.gov.au
WorkSafe Victoria
Phone: 03 9641 1444
Email: info@worksafe.vic.gov.au
WA WorkSafe
Phone: 1300 307 877
Switchboard: (08) 9327 8777
Email: safety@docep.wa.gov.au
Mail: PO Box 294 WEST PERTH WA 6872
State/Territory Government authorities
Health, Disability, Legal Services: Depending upon the issue, complainants may
need to contact State/Territory-based authorities in the areas of health, disability and
legal services. Please check the internet for up-to-date and relevant contact details
for these authorities.
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Section 7: Key contacts
QA Administration Contacts
Organisation/function
Contact details
Australian Government
Refer to FaHCSIA website.
Department of Families,
Housing, Community
Services and Indigenous
Affairs (FaHCSIA) State and
Territory offices – funding
body for NDAP
Joint Accreditation System
of Australia and New
Zealand (JAS-ANZ) –
accreditation body
Certification Bodies –
accredited to conduct QA
audits and grant
certification
Level 1,Members Equity Building,
11 London Circuit, Canberra, ACT 2600 GPO
Box 170, Canberra, ACT 2601
Phone: 02 2 6232 2000 (Switchboard)
Fax: 02 6262 7980
Email: contact@jas-anz.com.au
Refer to JAS-ANZ website for details of accredited
Certification Bodies.
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Complaints and Appeals Contacts
Organisation
Contact details
Administrative Appeals Tribunal
Phone: 1300 653 227 (local call
cost)
Australian Human Rights Commission
Level 3, 175 Pitt Street
SYDNEY NSW 2000
Complaints Infoline: 1300 656 419
Commonwealth Ombudsman
Phone: 1300 362 072
Complaints Resolution and Referral Service
(CRRS)
PO Box 126 St Leonards NSW
2065
Phone: Free call 1800 880 052
TTY: 1800 301 130
Fax : 02 8412 7199
Email: crrs@workfocus.com
Legal Services Commission
Refer Internet for details within
each State/Territory
National Disability Abuse and Neglect Hotline PO Box 126 St Leonards NSW
2065
Phone: Free call 1800 880 052
TTY: 1800 301 130
Fax: 02 8412 7199
Email: hotline@workfocus.com
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Disability peak bodies
Peak Body
DANA (Disability Advocacy Network of Australia)
Contact details
PO Box 96
DICKSON ACT 2602
Phone: 02 61541983
AFDO (Australian Federation of Disability
Organisations)
NCID (National Council on Intellectual Disability)
NDS (National Disability Services)
NEDA (National Ethnic Disability Alliance)
247 Flinders Lane
Melbourne Victoria 3000
Phone: 03 9662 3324
Fax: (03) 9662 3325
TTY: (03) 9662 3724
Email: office@afdo.org.au
PO Box 771
Mawson ACT 2607
Phone: (02) 6296 4400
Fax: (02) 6296 4488
Email:ncid@ncid.org.au
Locked Bag 3002
Deakin West ACT 2600
Ph/TTY: (02) 6283 3200
Fax: (02) 6281 3488
PO Box 9381
Harris Park NSW 2150
Phone: (02) 9687 8933
Fax: (02) 9635 5355
Email: office@neda.org.au
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Disability agency contacts – multicultural
Agency
National Ethnic Disability Alliance (NEDA).
NEDA is the national consumer peak for
people from a NESB with disability, their
families and carers.
ACT
Contact details
PO Box 9381
Harris Park NSW 2150
Phone: (02) 9687 8933
Fax: (02) 9635 5355
Email: office@neda.org.au
Post: PO Box 394
Civic Square ACT 2608
ACT Multicultural Council (ACTMC).
ACTMC is the ACT state member of the
NEDA network. The ACTMC provides a
source of advocacy and representation for
migrants of non- English speaking cultures,
including those with disabilities.
NSW
Multicultural Disability Advocacy Association
of NSW (MDAA).
Phone: (02) 6249 8994
Fax: (02) 6248 6767
Email: actmc@bigpond.com.au
Post: PO Box 884
Granville NSW 2142
Phone: (02) 9891 6400
MDAA is the NSW state member of the NEDA Fax: (02) 9635 5355
network. MDAA provides individual and
TTY: (02) 9687 6325
systemic advocacy supports to people from a Toll Free: 1800 629 072
NESB with disability, their families and carers. Email: mdaa@mdaa.org.au
NT
Post: PO Box 1160
Multicultural Community Services of Central Alice Springs NT 0871
Australia (MSCSA).
Phone: (08) 8952 8776
MCSCA is the NT member of the NEDA
Fax: (08) 8952 5176
network.
Email: mcsca@alicesprings.net.au
Qld
Post: 9 Chippendall Street Milton
QLD 4064
AMPARO Advocacy Inc.
Tel:
(07) 3369 2500
AMPARO Advocacy Inc is the QLD state
Fax:
(07) 3399 2511
member of the NEDA network.
Email:
amparoadvoc@optusnet.
com.au
SA
Post: PO Box 23
Multicultural Advocacy & Liaison Services of Findon SA 5023
SA (MALSSA).
Phone: (08) 8351 9500
MALSSA is the SA state member of the NEDA Fax: (08) 8152 0396
network.
Email:
malssaadmin@malssa.org.au
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Tas
Post: GPO Box 798H
Hobart TAS 7001
Multicultural Council of Tasmania
Phone: (03) 6231 5067
Fax: (03) 6231 5069
Email: mcot@tassie.net.au
Vic
Action on Disability in Ethnic Communities
(ADEC).
ADEC:
175 Plenty Road
Preston, Vic 3072
ADEC is not a member of the NEDA network.
ADEC is the peak body in Victoria for people
from a NESB with disability, their families and
carers. ADEC provides individual and
systemic advocacy supports to people from a
NESB with disability, their families and carers.
Phone: (03) 9480 1666
Fax: (03) 9480 3444
Email: info@adec.org.au
MRCNW:
45 Main Road St
Migrant Resource Centre North West Region Albans VIC 3021
(MRCNW).
Phone: (03) 9367 6044
MRCNW is the Victorian member of the NEDA Fax: (03) 9367 4344
network. MRCNW provides information and
Email: mrcnw@mrnorthwest.org.au
support to migrants and refugees.
WA
320 Rokeby Road
Subiaco WA 6008
Ethnic Disability Advocacy Centre (EDAC)
Phone: (08) 9388 7455
EDAC is the WA state member of the NEDA Freecall: 1800 659 921
network. EDAC aims to promote and
Fax: (08) 9338 7433
safeguard the rights of ethnic people with
Email: admin@edac.org.au
disabilities and their carers.
Privacy
Organisation
Privacy Commissioner
Contact details
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
TTY: 1800 620 241
Fax: (02) 9284 9666
Email: privacy@privacy.gov.au
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Section 8: Glossary
Accreditation
Process by which an authoritative body, JAS-ANZ, gives formal
recognition that a Certification Body is competent to carry out
Certification. This assessment is carried out by JAS-ANZ against
criteria set out in Requirements for Bodies Providing Audit and
Certification of Advocacy Agencies under the National Disability
Advocacy Program (Procedure 29)
Advocacy
Supporting people to exercise their rights and freedoms
recognised or declared by the United Nations Convention on the
Rights of People with Disabilities, or seeking to achieve societal
change to ensure that people with disabilities attain the rights and
freedoms recognised or declared by the Convention.
ATSI
Stands for 'Aboriginal or Torres Strait Islander'.
Audit
All activities related to the Certification of an agency to determine
whether the agency meets all the requirements of the Disability
Advocacy Standards necessary for granting Certification, and
whether they are effectively implemented. This includes
documentation review, audit, preparation and consideration of the
audit report and other relevant activities necessary to provide
sufficient information to allow a decision to be made as to whether
Certification shall be granted.
Audit cycle
A three-year cycle of annual surveillance audits, ending with a full
reassessment against all the Disability Advocacy Standards.
Audit team
A team of competent personnel identified by a Certification Body
as meeting the required team competencies set down in JAS-ANZ
Procedure 29. A person with disability will be included in the team
either as a lead auditor, or a technical expert.
Auditor
A member of an audit team who has knowledge in the area of
disability and quality management practices and skills in collecting
and analysing data. Auditors gather evidence, consumer
feedback, and have input into audit ratings.
CALD
Stands for 'culturally and linguistically diverse'.
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Certification
Process by which a third party gives written assurance that an
agency conforms to the requirements of the Disability Advocacy
Standards.
Certification
Body
A third party which assesses and certifies with respect to the
Disability Advocacy Standards.
Certification
document
Document indicating that an agency conforms to specified
Disability Advocacy Standards.
Citizen
Advocacy
A type of Individual Advocacy, which seeks to support people with
disability (also called protégés) by matching them with volunteers.
Some of the matches made may last for life.
Through citizen advocacy:

people with disability who are vulnerable, isolated and may
have no family or community supports or networks are
sought out;
 Citizen advocates(who are volunteers) are encouraged to
represent the interests of a person with disability as if they
were their own and be free from conflict of interest; and
• Citizen advocates are recruited, trained and supported by a
coordinator who manages the work of the citizen advocacy
agency.
Complaints
The independent and impartial service funded by the Australian
Resolution and Government to assist in the resolution of complaints about
Referral Service Australian Disability Enterprises, Disability Employment Services,
(CRRS)
and FaHCSIA funded advocacy agencies.
Conformity
When the requirements of a performance indicator associated
with a Disability Advocacy Standard are met.
Consumer
A person with disability who is a member of the audit team,
technical expert engaged for his/her specialist knowledge and abilities (e.g.
(CTE)
empathy with the life experience of people with disability, and
ability to plan and facilitate the effective input of people with
disability in an audit process). A CTE shall provide evidence to the
Certification Body of the CTE having been a service recipient of a
State or Commonwealth funded disability organisation in
Australia.
Note:
 every audit team must include a CTE. If appropriately
qualified, the CTE may also perform the functions of an
auditor/lead auditor
 other technical experts (with or without disability) may also
be attached to the audit team to supplement the
background knowledge of the team (e.g. where there are
273
Continuous
improvement
critical requirements and special procedures).
An agency's striving for excellence in establishing and maintaining
quality services that continually improve performance to achieve
better outcomes for consumers.
CRRS
See Complaints Resolution and Referral Service.
Cultural
competence
Cultural competence is the idea that that individuals, agencies
and systems have the capacity, skills and knowledge to respond
to the needs of a culturally diverse population.
Disability
Advocacy
Standards
The Standards under the Disability Services Act 1986 (Cth), plus
the relevant key performance indicators (KPIs), as determined by
the Minister(s). These 10 standards and 25 KPIs define the
government's requirements for quality and directly link to
outcomes required of each disability advocacy agency funded
under the National Disability Advocacy Program.
DAS
See Disability Advocacy Standards.
FaHCSIA
Department of Families, Housing, Community Services and
Indigenous Affairs
Family Advocacy A type of individual advocacy, which works with parents and
family members to enable them to act as advocates with and on
behalf of a family member with disability. Family advocates work
with parents and family members on either a short-term or an
issue-specific basis. Family advocates work within the
fundamental principle that the rights and interests of the person
with disability are upheld at all times.
Individual
Advocacy
Through family advocacy:
•
family members are provided with advice and support;
• the person with disability is assisted via the family member
being directly supported by the agency to advocate on their
behalf.
Supports people with disability to exercise their rights, through
either one-to-one support, or by supporting people to advocate for
themselves individually, through a third party, or on a group basis.
Individual advocates work with people with disability on either a
short-term or issue-specific basis.
Individual advocates:
 work with people with disability requiring one-to-one
advocacy support;
 develop a plan of action (sometimes called an individual
advocacy plan) in partnership with the person with a
disability that maps out clearly defined goals;
 educate people with disability about their rights; and
 work through the individual advocacy plan in partnership
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Internal Audit
JAS-ANZ
with the person with disability.
Internal audits are a means of checking that a disability advocacy
agency’s systems, processes and procedures are working as
intended, reviewed regularly and amended as necessary. Selfassessments check the extent to which documents in the
management system meet the requirements of the Disability
Advocacy Standards. Internal audits do this, as well as a check to
see if those processes and procedures are implemented and
followed.
The Joint Accreditation System of Australia and New Zealand.
JAS-ANZ is a not-for-profit, self-funding international organisation
established under a Treaty between the governments of Australia
and New Zealand on 30 October 1991. JAS-ANZ is the
government-appointed peak accreditation body for Australia and
New Zealand for Certification of management systems, products,
personnel, training course providers and sector-specific schemes.
JAS-ANZ accreditation of a Certification Body provides the
necessary confidence that the Certification Body has undergone
and passed a JAS-ANZ assessment to test its independence,
impartiality, integrity and competence.
Key
Measures of performance against the Disability Advocacy
Performance
Standards.
Indicators (KPIs)
Lead auditor
Same as 'auditor', but with additional leadership experience.
Responsible for organising and directing the activities of the audit
team, as well as participating in general audit activities.
Legal advocacy A type of individual advocacy, which seeks to uphold the rights
and interests of people with all types of disabilities on a one-toone basis by addressing legal aspects of instances of
discrimination, abuse and neglect.
Legal advocates may:
 provide legal representation for people with disability as
they come into contact with the justice system;
 pursue positive changes to legislation for people with
disability; and
 people with disability to understand their legal rights.
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Major
nonconformity
When the requirements of a KPI associated with a Disability
Advocacy Standard are not met, or the outcome is ineffective. A
number of related nonconformities may also constitute a major
nonconformity. The Certification Body's procedures shall ensure
that:
 verification of effective corrective action shall require a
follow-up visit by the Certification Body before Certification.
If the agency is already certified, evidence of a corrective
action plan shall be presented to the Certification Body
within five working days, and verification of effective
corrective action shall require a follow-up visit by the
Certification Body within three months
 failure to action the major nonconformity within three
months, or take action sufficient to downgrade the major
nonconformity to a nonconformity, shall result in automatic
suspension of Certification
 if the major nonconformity is downgraded to nonconformity,
that nonconformity is actioned within a further three months
(total of six months to fully action a major nonconformity).
FaHCSIA may subsequently issue such instructions as it sees fit
to the disability advocacy agency to deal with the major
nonconformity.
National
The NDAP provides people with disability access to effective
Disability
disability advocacy that promotes, protects and ensures their full
Advocacy
and equal enjoyment of all human rights enabling community
Program (NDAP) participation. The NDAP is funded and administered by the
FaHCSIA.
Nonconformity
When the requirements of a key performance indicator associated
with a Disability Advocacy Standard are not fully met, or the
outcome is only partly effective. The Certification Body's
procedures shall ensure that:
 corrective action taken is verified as effective before
Certification, or within six months if the disability advocacy
agency is already certified
 failure to action a nonconformity within six months may lead to
the nonconformity being upgraded to a major nonconformity;
and in addition, a major nonconformity may be raised with the
disability advocacy agency's corrective action process
Notifiable issue Evidence or allegations of a serious health, safety or abuse risk,
financial impropriety and/or professional misconduct. If such
276
evidence is found or specific allegations are made, the
Certification Body's procedures shall require it to record the
details of the disclosure, allegation or witnessed event, and also
to immediately notify the disability advocacy agency's manager
(unless there is justifiable reason for not doing so, such as risk of
compromising collection of evidence in subsequent
investigations), and FaHCSIA. The Certification Body is not
responsible for resolving the issue, but has a duty of care to report
the allegation. Certification cannot proceed until FaHCSIA advises
the Certification Body that the notifiable issue is resolved. If the
disability advocacy agency is already certified, the Certification
Body shall seek advice from FaHCSIA.
Observations
Opportunity for improvement or positive feedback, provided by a
Certification Body during the audit process. Observations which
are opportunities for improvement do not prevent Certification, but
they should be carefully considered by management and
addressed wherever possible, to ensure that conformity is not
compromised in the future.
Ongoing support Advocacy support that is or has been of an ongoing nature and
shall not include phone calls or requests for information that are
one off in nature only.
Person with
disability
Person with disability include those who have long-term physical,
mental, intellectual or sensory impairments which in interaction
with various barriers may hinder their full and effective
participation in society on an equal basis with others.
Privacy Act
Privacy Act 1988 (Cth) as amended 2000.
Principles and
Objectives
The Principles and Objectives of the Disability Services Act 1986
(Cth) set out the basic human rights which all services supporting
people with disability should meet. The Principles recognise that
people with disability have the same fundamental rights as do
other members of society. The Objectives relate more directly to
service delivery, that is, the way in which a service operates.
Procedure 29
The document Requirements for Bodies Providing Audit and
Certification of Advocacy Agencies under the National Disability
Advocacy Program which sets down the requirements
(accreditation criteria) for bodies seeking accreditation by the
Board of JAS-ANZ, to assess disability advocacy agencies and
certify that they meet the Disability Advocacy Standards.
Quality
A systematic way of checking that a disability advocacy agency
277
assurance (QA) meets set standards.
Quality
management
systems and
practices
Systems to establish quality policy and quality objectives and to
achieve those objectives.
Rating scale
The system used to rate conformity of a disability advocacy
agency. Each KPI associated with a Disability Advocacy Standard
is to be rated according to the scale below. A Disability Advocacy
Standard is to be rated the same as the lowest rating of any of its
associated KPIs:



Self advocacy
major nonconformity is 0
nonconformity is 1
conformity is 2.
A type of Individual advocacy, which supports people with
disability to advocate on their own behalf, to the extent possible,
or on a one-to-one or group basis.
Through self advocacy:
 advocates work with people with disability to develop their
personal skills and self-confidence to enable them to advocate
on their own behalf.
 people with disability are educated about their rights.
Self-assessment A critical review, conducted internally, that documents the extent
to which the advocacy agency’s existing management system
(policies, procedures and practices) ensures that they meet the
DAS. Self-Assessments may be conducted by peer agencies.
Surveillance
audit
An audit conducted at least annually by a Certification Body to
verify that a certified agency continues to comply with the
Disability Advocacy Standards.
Systemic
advocacy
Seeks to introduce and influence long-term changes to ensure
that the rights and freedoms of people with disability, being rights
and freedoms recognised or declared by the Disabilities
Convention, are attained and upheld so as to positively affect the
quality of their lives. The systemic advocacy agency:
 pursues positive changes to legislation, policy and service
practices in partnership with groups of people with disability,
advocacy agencies and other relevant organisations;
 seeks to address barriers and discriminatory practices to
produce long-term positive changes.
Target group for The target group for advocacy support provided by NDAP
278
NDAP
agencies, as required under section 8 of the Disability Services
Act 1986 (Commonwealth), consists of people with disability that:
a. ‘is attributable to an intellectual, psychiatric, sensory or
physical impairment or a combination of such impairments;
b. is permanent or likely to be permanent; and
c. results in:
i. a substantially reduced capacity of the person for
communication, learning or mobility; and
ii .the need for ongoing support services.
Technical expert A member of the assessment or audit team engaged to
supplement the background knowledge of the team; (e.g. where
there are critical requirements and special procedures). A
technical expert need not meet all the requirements of ISO 100112, and in this case, they should always work under the direct
supervision of an auditor, except where the particular
circumstances of interviews with people with disability preclude
this. All technical experts shall at least meet the requirements of
Clause 7 of ISO 10011-2.
279
Attachment 1
Joint Accreditation System of Australia and New Zealand
JAS-ANZ Procedure 29
Issue 2
Requirements for bodies providing audit and certification of
advocacy agencies under the national disability advocacy
program
12 July 2012
Authority to Issue
Dr James Galloway
Chief Executive
with Authority of the Governing Board
280
Contents
0
1
2
3
4
4.1
4.2
4.3
4.4
4.5
4.6
Introduction
282
Scope
284
References
284
Definitions
284
Certification body
288
General provisions
288
Organization
288
Operations
288
Subcontracting
288
Quality system
288
Conditions and procedures for granting, maintaining, extending, suspending and
withdrawing certification
289
4.7
Internal audits and management reviews
289
4.8
Documentation
289
4.9
Records
289
4.10
Confidentiality
289
5
Certification body personnel
290
5.1
General
290
5.2
Qualification criteria
290
6
Changes in certification requirements
291
7
Appeals, complaints and disputes
291
8
Application for certification
291
8.1
Information on the procedure
291
8.2
The application
292
9
Preparation for evaluation
292
10
Evaluation
293
11
Evaluation report
294
12
Decision on certification
295
13
Surveillance
296
14
Use of licences, certificates and marks of conformity
297
15
Complaints to suppliers
297
Annex A - Audit Duration
298
Annex B - Certification of advocacy agencies with multiple sites
299
Annex C - Audit planning and consumer sampling
301
Annex D - Code of Ethics
304
281
0
Introduction
0.1
Object and field of application
0.1.1
This procedure, including the attached Annexes, sets down the requirements
(accreditation criteria) for bodies seeking accreditation by the Governing Board of the
Joint Accreditation System of Australia and New Zealand (JAS-ANZ), to audit advocacy
agencies and certify that they meet the Disability Advocacy Standards (DAS) set down by
the Australian government. The advocacy agencies referred to in this procedure are those
funded under the Commonwealth Disability Services Act 1986, for the National Disability
Advocacy Program (NDAP) administered by the Department of Families, Housing,
Community Services and Indigenous Affairs (FaHCSIA).
0.1.2
The focus of the NDAP certification scheme is to ensure that advocacy agencies have
appropriate management systems in place which are used to achieve the outcomes
identified through the DAS and associated Key Performance Indicators (KPIs). The
outcomes identified through the DAS and KPIs define the elements of quality support
which should be achieved for people with disability receiving advocacy support. Advocacy
agencies will need to comply with, and demonstrate continuous improvement against the
DAS and KPIs.
0.1.3
Accreditation in conformity with ISO/IEC Guide 65 and the criteria in this procedure
acknowledges that bodies possess the necessary competence and reliability to operate a
conformity assessment system for advocacy agencies, and will thereby facilitate their
acceptance or recognition on a national basis.
0.1.4
Only those certification bodies that have been accredited by JAS-ANZ to ISO/IEC Guide
65, IAF Guidance on the Application of ISO/IEC Guide 65 (IAF GD 5:2006) and this
procedure shall carry out audits and issue certificates against the DAS. It is the
responsibility of an advocacy agency seeking certification to the DAS to verify the
accreditation status of the chosen certification body, by either requesting a copy of their
accreditation certificate (or acknowledgement of application) and scope; by contacting
JAS-ANZ; or by searching the JAS-ANZ Register, which is available on-line at www.jasanz.org.
0.1.5
FaHCSIA may review criteria or set additional criteria, in consultation with all
stakeholders. In any case, these criteria will be reviewed within two years after
implementation; or as the need arises. Revised or additional criteria will be the subject of
an agreement between JAS-ANZ and FaHCSIA and will be regarded as part of these
accreditation criteria. Where there is inconsistency between the revised or additional
procedure and this procedure, the requirements of the revised or additional procedure will
prevail.
0.1.6
The criteria against which an advocacy agency is audited shall be those outlined in the
DAS relevant to the function performed.
0.2
Background
0.2.1
ISO/IEC Guide 65 is an International Standard that sets out the requirements for
certification bodies providing audit and certification of product certification systems. The
term ‘product’ includes ‘service’ and ‘process’.
0.2.2
To facilitate the uniform interpretation and application of ISO/IEC Guide 65 for audit and
certification of advocacy agencies in Australia, this procedure incorporates the work of the
JAS-ANZ National Disability Advocacy Program Technical Committee (NDAP TC),
aligned with the requirements of ISO/IEC Guide 65, to produce normative criteria,
comprising all of this document including the Annexes.
0.2.3
The JAS-ANZ NDAP TC, whose members represent the significantly interested parties,
developed these criteria in line with ISO/IEC Guide 65 clause 4.1.3. This procedure shall
be read in conjunction with ISO/IEC Guide 65 and IAF GD 5.
0.2.4
The term ‘should’ is used in this document to indicate recognised means of meeting the
requirements of the standard. A certification body can meet these in an equivalent way
provided this can be demonstrated to JAS-ANZ.
282
0.2.5
The term ‘shall’ is used in this document to indicate those provisions which, reflecting the
requirements of the relevant standard, are mandatory.
0.2.6
All the major headings (numbers 1-15) of this procedure have been reproduced from
ISO/IEC Guide 65.
0.2.7
This procedure does not diminish any of the requirements of ISO/IEC Guide 65. The
clause numbers in this procedure are prefixed with the letter ‘J’ to indicate mandatory
criteria developed by the JAS-ANZ NDAP TC for auditing and certifying advocacy
agencies.
0.2.8
The text of ISO/IEC Guide 65 and IAF GD5:2006 is not included in this document and
shall be referred to separately.
0.2.9
References in this procedure to specific clauses of ISO/IEC Guide 65 shall be read to
mean references to ISO/IEC Guide 65 in conjunction with the IAF GD 5:2006 and the
corresponding criteria in this procedure.
283
Conformity assessment – requirements for bodies
providing audit and certification of agencies under the
National Disability Advocacy Program
1
Scope
No additional requirements
2
References
1993 National Disability Services Standards.
Disability Services Standards (Advocacy Standards) (FaHCSIA) Determination 2012 – the
Disability Advocacy Standards.
National Disability Agreement (NDA).
Disability Discrimination Act (Cwlth) 1992.
Disability Services Act (Cwlth) 1986.
IAF GD 5:2006 - Guidance on the Application of ISO/IEC Guide 65:1996; available at
www.iaf.nu.
IAF MD 1:2007 (issue 1) – IAF Mandatory Document for the Certification of Multiple Sites
Based on Sampling; available at www.iaf.nu.
IAF MD 2:2007 (Issue 1) – IAF Mandatory Document for the Transfer of Accredited
Certification of Management Systems; available at www.iaf.nu.
IAF MD 5:2009 (Issue 1) – IAF Mandatory Document for the Duration of QMS and EMS
Audits; available at www.iaf.nu.
ISO/IEC Guide 65:1996 - General requirements for bodies operating product certification
systems.
ISO 19011:2011 - Guidelines for quality and/or environmental management system
auditing.
Privacy Act (Cwlth) 1988 as amended 2000.
JAS-ANZ Procedure 03 – Rules of procedure governing the use of the accreditation
symbol.
United Nations Convention on the Rights of People with Disabilities; available at
http://www.un.org/disabilities/.
3
Definitions
J.3.1
The following definitions also apply to this procedure:
Advocacy
supporting people to exercise the rights and freedoms recognised or
declared by the United Nations Convention on the Rights of People with
Disabilities, or seeking to achieve societal change to ensure that people
with disabilities attain the rights and freedoms recognised or declared by
the Convention.
Advocacy agency
advocacy agencies funded by the Australian Government.
Advocacy agency with
an advocacy agency with one central office and multiple full-time and/or
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multiple sites
part-time sites at which activities are fully or partially carried out.
Advocacy models
any of six advocacy models currently funded under the NDAP program:
Individual Advocacy
Individual advocacy supports people with disability to exercise their rights,
through either one-to-one support, or by supporting people to advocate for
themselves individually, through a third party or on a group basis.
The types of NDAP-funded advocacy that are provided under individual
advocacy include but are not limited to: self, family, citizen, and legal:
Self-Advocacy
Supports people with disability to advocate on their own behalf, to the
extent possible, or on a one-to-one or group basis.
Family Advocacy
Works with parents and family members to enable them to act as
advocates with and on behalf of a family member with disability. Family
advocates work with parents and family members on either a short-term or
an issue-specific basis. Family advocates work within the fundamental
principle that the rights and interests of the person with disability are
upheld at all times.
Citizen Advocacy
Seeks to support people with disability (also called protégés) by matching
them with volunteers.
Legal Advocacy
Seeks to uphold the rights and interests of people with all types of
disabilities by addressing legal aspects of instances of discrimination,
abuse and neglect.
Systemic advocacy
Seeks to introduce and influence longer term changes to ensure the rights
of people with disability are attained and upheld to positively affect the
quality of their lives.
In all these models, the target group of advocacy support is the
person with disability.
Audit team
a team of at least two persons appointed to conduct an audit. An audit
team normally comprises a lead auditor and a CTE. However, while a CTE
may also perform the role of lead auditor (or auditor) if appropriately
qualified, in that case the audit team shall still comprise at least two
persons.
CB
certification body.
Central office
the office of an advocacy agency that has the responsibility to administer
its Australian Government’s advocacy funding and the right to implement
corrective actions at any site. The central office is the central point for the
administration of the common management system.
Certification audit
all activities related to the initial certification of an advocacy agency to
determine whether the advocacy agency meets the requirements of the
DAS.
Certification body
a body accredited as conforming to the criteria specified in this procedure
which audits and certifies to the DAS.
285
Close out
verification by a CB that corrective action has been implemented by an
advocacy agency to address a major nonconformity or nonconformity.
Conflict of interest
a relationship between the CB, or a person working for the CB (paid or
unpaid, staff or contractor), and an advocacy agency, disability service or
person, that threatens the impartiality of the CB. Such relationships apply
to past, present or future involvement and include:
a)
having worked with, or been a consumer of, or consulted to the
advocacy agency in the last two years, or reasonable prospects of
such work in the next two years
b)
any financial interest in the advocacy agency or relatives or friends
with a financial interest in the advocacy agency
c)
being in competition with the advocacy agency
d)
any other commercial or voluntary arrangement or directorship with
the advocacy agency
e)
having immediate family members employed by an advocacy
agency, or in any of the above situations
f)
any personal bias or inclination which would affect decisions in
relation to the advocacy agency
g)
having worked with or audited a disability service that has been
subject to advocacy from the advocacy agency.
Conformity
the requirements of a KPI associated with a DAS are met. See Rating
scale.
Consent
the voluntary agreement of a person or a person's authorised
representative about a proposed action – e.g. participate in an interview;
review personal records.
Consulting
participating in designing, implementing or maintaining an NDAP
management system.
Note: Identifying opportunities for improvement is not consulting.
Consumer
primarily, a person with disability who is receiving / has received within the
last 3 months support from the advocacy agency being audited. Consumer
may also mean family member/s or an unpaid primary carer or advocate of
that person with disability. Some advocacy agencies may use the terms
“client”, “participant”, “service user” etc. in lieu of “consumer”.
Consumer technical
expert
a person with disability, engaged for his/her specialist knowledge and
abilities; e.g. empathy with the life experience of people with disability, and
ability to plan and facilitate the effective input of people with disability in an
audit process. A CTE shall provide evidence to the CB of having been a
service recipient of a State or Commonwealth funded disability
organisation in Australia.
CRRS
Complaints Resolution and Referral Service. The independent and
impartial service funded by the Australian Government to assist in the
resolution of complaints about advocacy agencies, disability employment
service providers funded under the Disability Services Act.
CTE
consumer technical expert.
DAS
the Disability Advocacy Standards, plus the relevant Key Performance
Indicators (KPIs) define the elements of quality support which should be
achieved for people with disability receiving advocacy support from
advocacy agencies.
286
External stakeholder
in the context of Annex C, clauses C.2.10 and C.4.4, a person or other
agency that is connected with the work of the advocacy agency.
FaHCSIA
Australian Government Department of Families, Housing, Community
Services and Indigenous Affairs (FaHCSIA), including where acting as
administrator of the National Disability Advocacy Program on behalf of the
Australian Government.
Full-time site
a service location for an advocacy agency that operates on a full-time
basis – normally five days per week during normal working hours (e.g.
8:30 AM to 4:30 PM, Monday to Friday) or more.
IAF
International Accreditation Forum.
IAF GD5: 2006
IAF GD5:2006 - Guidance on the Application of ISO/IEC Guide 65:1996.
Independent advocate
an independent person who can support someone. With respect to
consumers and the audit process, an independent person who can
support a consumer to participate in the audit process. If an advocate is
required during an audit process, in this instance the independent
advocate shall not be a paid employee or volunteer of the organization
being audited.
JAS-ANZ NDAP TC
JAS-ANZ National Disability Advocacy Program Technical Committee.
KPI
the Key Performance Indicators identify the requirements which need to be
demonstrated or measured in order to achieve compliance with each
Standard within the DAS.
Major nonconformity
the requirements of a KPI associated with a Disability Advocacy Standard
are not met, or the outcome is ineffective. A number of related
nonconformities may also constitute a major nonconformity. See Rating
scale.
NDAP
National Disability Advocacy Program.
Nonconformity
the requirements of a KPI associated with a Disability Advocacy Standard
are not fully met, or the outcome is only partly effective.
Notifiable issue
evidence or allegations of a serious health, safety or abuse risk, financial
impropriety and/or professional misconduct.
Ongoing support
advocacy support that is or has been of an ongoing nature and shall not
include phone calls or requests for information that are one off in nature
only.
Other technical expert
a person other than a CTE who provides specific knowledge or expertise
to an audit team, and is engaged by the CB to participate in the audit or
relevant part of the audit.
Outcomes
outcomes for the purposes of this Procedure are those identified through
the DAS and KPIs which define the elements of quality support which
should be achieved for people with disability receiving advocacy support.
Outreach site
a service location for an advocacy agency set up in the premises of
another organisation. An outreach site is not permanently open but may
operate for a period on a regular basis such as weekly or monthly, or on
demand. Outreach sites do not include consumers’ private homes.
Part-time site
a permanent service location for an advocacy agency that regularly
operates on only some days of the working week or for part of normal
287
working hours on some days.
Person with disability
persons with disabilities include those who have long-term physical,
mental, intellectual or sensory impairments which in interaction with
various barriers may hinder their full and effective participation in society
on an equal basis with others.
Rating scale
the system used to rate conformity of an advocacy agency. Each KPI
associated with a Disability Advocacy Standard is to be rated as follows:
a)
major nonconformity rating = 0
b)
nonconformity rating = 1
c)
conformity rating = 2
A standard is to be rated the same as the lowest rating of any of its
associated KPIs.
Self assessment
4
a critical review, conducted internally, that documents the extent to which
the advocacy agency’s existing management system (policies, procedures
and practices) ensures that they meet the DAS. Self assessments may be
conducted by peer organisations.
Certification body
4.1
General provisions
J.4.1.1
If an explanation is required for the consistent application of this procedure or reference
standards, it shall only be acceptable if approved and published by the JAS-ANZ NDAP
TC.
4.2
Organization
J.4.2.1
The CB shall ensure that the structure that safeguards impartiality shall be an impartial
committee which includes a CTE and another person with disability.
J.4.2.2
The CB shall have a documented, publicly available policy on handling gifts or hospitality
offered by an advocacy agency to which it is contracted to provide certification services.
4.3
Operations
No additional requirements
4.4
Subcontracting
No additional requirements
4.5
Quality system
J.4.5.1
The CB's procedures for internal audits, required by ISO/IEC Guide 65 Clause 4.5.3 n),
shall be based on the provisions of ISO 19011.
J.4.5.2
The CB shall document monitoring procedures for all audit team members, including CTEs
and other technical experts. Procedures shall include on-site observation. The CB should
establish the frequency of observation to take account of the criticality and volume of the
work being undertaken, the experience and performance history of the audit team
members and any data obtained from other types of monitoring activity such as review of
audit reports and client feedback.
288
4.6
Conditions and procedures for granting, maintaining, extending,
suspending and withdrawing certification
J.4.6.1
For the initial certification, the CB shall confirm that the agency has:
implemented its policies and procedures
implemented a program for conducting self assessments covering its compliance with
all the DAS standards and KPIs during the certification cycle
completed at least one self assessment.
J.4.6.2
The CB shall have documented procedures that shall be made available on request for:
a) the certification, surveillance and recertification audits of an advocacy agency
(including reporting), in accordance with the provisions of ISO 19011
identifying and recording nonconformities and the need for appropriate corrective action
by advocacy agencies.
4.7
Internal audits and management reviews
No additional requirements
4.8
Documentation
J.4.8.1
CBs shall include the following in public information:
a) consumers will be offered information about the audit process and independent
advocacy support to engage in the process prior to any consent being obtained
b) participation by consumers in audits is at all times voluntary and shall be based on
the principle of consent. Where possible, a consumer’s consent for interview shall
also grant permission for the audit team to review that consumer’s file. It is
desirable to obtain consents in writing. Where the capacity of a consumer to
provide consent is uncertain, an independent advocate should be involved to
determine that capacity and to support an appropriate level of involvement by the
consumer. Where written consent is not obtained, the reason for this, and
evidence supporting the assumption that consent was sought and has been
obtained, should be recorded in file notes
c) consumers shall be invited by their advocacy agency to both the opening and closing
meetings of all audits
d) the process for transferring certification shall be in accordance with IAF MD 2:2007
4.9
Records
J.4.9.1
The CB’s records shall include the following information:
a) clear, up to date documentation of the supporting information and rationale for all
decisions to sample advocacy agencies with multiple sites
b) sufficient information to trace all on-site audit durations, and the basis for the
calculations
c) justification for, and documentation of any departure from the requirements in the
Annexes
d) the number of consumers consulted during each audit and the methods of
consultation
e) how it ensured that consumers provided their consent to participate in the audit and
for the CB to access their files
4.10
Confidentiality
J.4.10.1
The CB shall treat all information about an advocacy agency, comprising documentation,
records, data either in hard copy or electronic format, or verbal information that comes into
289
the possession of a CB or any of its representatives in accordance with the Privacy Act
and any relevant state or territory legislation.
J.4.10.2
The CB shall not disclose information about a consumer of an advocacy agency that is
identifiable directly or indirectly to that consumer without the written consent of that
person, unless required by law. Where written consent is unobtainable or impracticable,
the consumer shall be supported by a family member, carer, guardian or advocate
empowered to make an informed decision about consent.
J.4.10.3
The CB shall not use information about a consumer for any purpose other than the
assessment of conformity with the DAS.
J.4.10.4
Where the CB wishes to disclose information about an agency (other than a notifiable
issue – see clause J.10.6) to FaHCSIA it must first seek the agency’s permission. If
permission is denied it may still disclose this information to FaHCSIA if it takes the view
that to do so would be in the best interests of the agency consumers.
5
Certification body personnel
5.1
General
J.5.1.1
Auditors shall meet the guidance for competence of auditors in ISO 19011.
J.5.1.2
The CB shall have processes to ensure that personnel have appropriate knowledge. It
shall determine and define the competence required for each function in the certification
activity, including functions undertaken by management and administrative personnel, as
well as audit and certification activities.
5.2
Qualification criteria
J.5.2.1
All audit personnel shall comply with the code of ethics. See Annex D.
J.5.2.2
All audit team members shall have experience and/or training in disability services auditing
or evaluation.
J.5.2.3
All audit team members shall demonstrate that they have the following knowledge and
skills:
a) understanding of the legislative and regulatory requirements applicable to advocacy
agencies, including the DAS
b) understanding of the nature of advocacy, the NDAP quality assurance system and
the role of people with disability and other stakeholders in quality processes
c) understanding of the diversity of advocacy agency models and organisational
structures and how this impacts on management practices
d) understanding of the diversity of people using advocacy agencies and their needs in
relation to the audit process
e) ability to communicate effectively in writing or orally or using alternative
communication systems with all parties involved in the audit process
f) ability to gather, review and report on evidence against the DAS.
J.5.2.4
CTEs shall have the personal attributes listed in ISO 19011.
J.5.2.5
All auditors and CTEs shall successfully complete the training required by FaHCSIA,
which includes the nature of advocacy and advocacy models, and an understanding of the
DAS, KPIs and Evidence Guidelines, before auditing in the system.
J.5.2.6
All audit team members shall have a current national police check, along with all
necessary checks required by state or territory legislation before working with children or
vulnerable people.
J.5.2.7
Where an advocacy agency already holds a JAS-ANZ-accredited certification to another
set of standards, the CB shall consider the extent of the demonstrated conformance for
any common or significantly similar criteria and rely on this to avoid audit duplication.
290
Every audit report shall record any eligible audit report and the criteria partially or fully
relied upon.
J.5.2.8
When selecting the audit team for any on-site audit, the CB shall ensure that the skills
brought to each assignment are appropriate. The team shall:
a) as a minimum comprise two people, i.e. a two person team is required even if the
lead auditor is also a CTE. In deciding the size and composition of the audit team
and the need (if any) for other technical experts (in addition to the CTE),
consideration shall always be given to the range of disabilities and consumer
communication styles likely to be encountered during the audit
b) understand the geographic or cultural context in which the advocacy agency
operates
c) inform the CB, prior to the audit, of any potential, current or perceived conflict of
interest they have in conducting the audit
J.5.2.9
6
The CB shall provide appropriate training and support to assist the CTE to function
effectively in the audit team. Such training may include auditor training or lead auditor
training where appropriate. A supervising auditor or lead auditor shall always provide
ongoing supervision to maintain the necessary level of communication and support to the
CTE and other technical expert(s). The CB shall evaluate the competence of the CTE and
other technical expert(s) to interview consumers face-to-face or by telephone without other
members of the audit team present before authorising them to do so. The CB shall keep
records of this evaluation.
Changes in certification requirements
No additional requirements
7
Appeals, complaints and disputes
J.7.1.1
The CB shall include a CTE in each appeal hearing.
J.7.1.2
The CB shall have a documented process to receive, evaluate and make decisions on
complaints.
J.7.1.3
The complaints-handling process shall include at least the following elements and
methods:
a) an outline of the process for receiving and investigating a complaint, and for deciding
what actions are to be taken in response to it
b) a system for tracking and recording complaints, including actions undertaken in
response to them
c) a system to ensure that any appropriate corrective action is taken.
J.7.1.4
The decision to be communicated to the complainant shall be made by, or reviewed and
approved by, individual(s) not previously involved in the subject of the complaint.
J.7.1.5
The CB shall copy matters referred to it by FaHCSIA into its complaints system and action
them according to its procedures for handling complaints.
8
8.1
Application for certification
Information on the procedure
No additional requirements
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8.2
The application
J.8.2.1
The CB shall require the advocacy agency to supply the following information:
a) the scope of the management system, services delivered and location(s) of the
advocacy agency
b) a copy of its documented policies and procedures relating to its management system
c) a copy of the latest self assessment
d) a copy of its current funding agreement with FaHCSIA
J.8.2.2
The CB shall have a legally enforceable agreement for providing certification services to
the advocacy agency. The agreement shall:
a) extend to all the sites covered by the scope of a multiple site certification
b) where possible, extend to any sites and/or outlets of relevant subcontractors to the
client. Note: this depends on whether the client can obtain its subcontractors’
agreement to do this.
c) require the advocacy agency to inform it of the opening or closing of a site. A CB
may seek confirmation from FaHCSIA of the number of sites an advocacy agency
delivers services from
d) require the advocacy agency to make available to the CB the records of all
communications and action taken in relation to the requirements of the DAS. This
includes correspondence, recommendations and actions documented by the
CRRS or FaHCSIA; or correspondence with any other advocacy agency or
disability service provider relating to complaints about the advocacy agency
seeking certification.
9
Preparation for evaluation
J.9.2.1
The audit program shall include an initial audit and periodic surveillance and recertification
audits. See Clause 13.
J.9.2.2
The CB shall plan audits to allow sufficient time and resources for the activities listed at
Clause J.10.8; e.g. to report compliance against each KPI, and to fully comply with the
reporting requirements in this procedure.
J.9.2.3
The CB should commence planning with the advocacy agency as early as possible to
ensure adequate consumer participation.
J.9.2.4
The CB shall send the advocacy agency the list of suggested consumer participants as
early as possible, to ensure that the advocacy agency has adequate time to arrange
interviews.
J.9.2.5
The CB shall ensure that the CTE has discussions with the advocacy agency about the
support needs and sensitivities of the selected consumers as early as possible, to ensure
the advocacy agency has adequate time to prepare for the Stage 2 audit.
J.9.2.6
The CB shall follow up at audit any matters referred to it by FaHCSIA that relate to
conformity with the DAS or to a potential notifiable issue, and provide any further
information on them to FaHCSIA if requested.
J.9.2.7
The CB shall inform the advocacy agency of the names of the members of the audit team
who will carry out the audit, with sufficient notice to appeal against the appointment of any
particular auditor, CTE or technical expert. The CB shall seek the advocacy agency’s
agreement to the audit plans prior to conducting the audit.
J.9.2.8
The CB shall provide the advocacy agency with a list of all the disability organisations that
it audits. If the agency subsequently perceives a potential conflict of interest and wishes to
choose another CB to provide certification services, the CB shall respect the agency’s
decision.
J.9.2.9
The CB shall check that the advocacy agency has invited consumers to the opening and
closing meetings of all audits.
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J.9.2.10
J.9.2.11
10
J.10.1
The CB shall have documented procedures for reviewing applications. In particular, and
as part of the review process applied to each application for certification, the CB shall:
a)
review the outcomes of observations and discussions during any pre-audit site
visits
b)
review any legal requirements that may impact on the advocacy agency’s
management system
c)
confirm the availability of the required audit team competencies
d)
calculate the audit duration in accordance with Annex A (single site) or Annex B
(multi-site) as applicable
e)
plan its sampling of an advocacy agency with multiple sites in accordance with
Annex B
f)
make appropriate arrangements for seeking consumer feedback in accordance
with Annex C.
Where a single site advocacy agency (or any site of a multi-site advocacy agency)
provides multiple advocacy models, the CB shall always sample consumers from every
advocacy model. The time spent auditing the different advocacy models (and hence the
number of consumers / stakeholders sampled per model) should be proportional to the
level of funding provided for each model.
Evaluation
The CB shall perform the initial audit in a 2 stage process. The CB may conduct the stage
1 audit remotely. During the stage 1 audit, the CB shall:
a) review the advocacy agency’s policies and procedures for complying with the DAS
including its self assessment
b) evaluate the advocacy agency’s logistical needs and preparedness for the stage 2
audit
J.10.2
The CB shall document stage 1 audit findings and communicate them to the advocacy
agency before the stage 2 audit, identifying any areas of concern that could be classified
as nonconformities during the stage 2 audit.
J.10.3
The Stage 2 audit shall not proceed until the advocacy agency advises the CB that they
are ready to proceed and the CB agrees. In determining the interval between stage 1 and
stage 2 audits, the CB shall consider whether the advocacy agency wishes to resolve
areas of concern identified during the stage 1 audit before the stage 2 audit can proceed.
J.10.4
The purpose of the stage 2 audit is to evaluate the implementation and effectiveness of
the advocacy agency’s management system. The stage 2 audit shall take place at the
site(s) of the advocacy agency. During the stage 2 audit, the CB shall at least evaluate the
evidence to demonstrate the advocacy agency’s effective implementation of their policies,
procedures and practices to comply with the DAS.
J.10.5
The CTE shall actively participate in the following audit activities with other team members
and this involvement shall be traceable via reports or other documents on the CB's files:
a) developing and agreeing the final audit plan and reviewing the stage 1 audit findings
b) planning and preparing the methods of consumer participation in the audit and
evaluating the need for independent support for consumers
c) participating for the full duration of the stage 2 audit, including the opening meeting,
audit team review meeting(s) and closing meeting. If the stage 1 audit is done on
site, the CTE shall be present for the duration of the visit
d) engaging consumers during the audit to collect, examine and analyse evidence with
respect to the DAS
e) reviewing consumer files or following up issues with consumers
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f) reviewing audit findings, determining audit ratings and preparing the written audit
report
J.10.6
If an audit team finds evidence of a notifiable issue, the CB's procedures shall require it to
record the details, and to immediately notify the advocacy agency’s manager (unless there
is justifiable reason for not doing so, such as a risk of compromising collection of evidence
in subsequent investigations), and FaHCSIA.
J.10.7
The CB is not responsible for resolving a notifiable issue, but shall report the evidence.
Certification cannot proceed until FaHCSIA advises the CB that the notifiable issue is
resolved. If the advocacy agency is already certified, the CB shall seek advice from
FaHCSIA.
J.10.8
At all on-site audits the audit team shall hold a closing meeting with the advocacy
agency’s management and any consumers who wish to be involved, prior to concluding
the on-site audit. At the closing meeting, the audit team shall:
a) explain its initial audit findings regarding the conformity of the advocacy agency with
each standard and KPI
b) if applicable, provide the advocacy agency with documented major nonconformities
and nonconformities, including the DAS KPIs they relate to, explanatory
comments, and the close out dates
c) summarise any notifiable issue raised during the audit, unless there is justifiable
reason for not doing so - see Clause J.10.6
d) summarise any audit follow-up activities
briefly summarise all the available avenues for resolving complaints and appeals
including via the CB, CRRS or JAS-ANZ
summarise the timing of, and requirements for, preparing for and conducting
surveillance and recertification audits
11
J.11.1
Evaluation report
Written reports of DAS on-site audits require more than generic summary statements. The
content of all reports shall include:
a) a brief description of the advocacy agency, including the advocacy model(s) offered
b) the number and roles of stakeholders consulted with during each audit, including the
model of advocacy accessed by them (eg. individual, systemic, citizen etc.) and
methods of consultation
c) an executive summary of the overall findings (conclusions) of the audit, including
comments on the effectiveness of the advocacy agency's system to ensure
conformity with the DAS and a summary of major nonconformities and
nonconformities at on-site audit completion, even if the agency has addressed
nonconformities before the report is finalised
d) ratings of conformity against each KPI and each standard, in accordance with the
rating scale
e) an adequate description of the main evidence and audit trails to support the ratings
of KPIs
f) positive and negative observations; noting that while negative observations (eg.
opportunities for improvement) do not prevent certification, CBs should advise
advocacy agencies to carefully consider them and address them wherever
possible, to ensure that conformity is not compromised in the future
times allocated for stage 1 and stage 2 audits, the number and type of interviews with
consumers.
J.11.2
Where applicable, reports of surveillance or recertification audits shall document:
a) close out of each major nonconformity and nonconformity revealed previously
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b) any useful comparison with the results of previous audits
J.11.3
The CB shall prepare stand-alone reports of any follow-up audits outlining any major
nonconformity or nonconformity and clearly documenting the evidence provided to support
decisions to close them out or downgrade them. It is not acceptable to report follow up
activity as an amendment to the original audit report.
J.11.4
In an audit that covers more than one type of certification standard (e.g. ISO 9001 in
addition to the DAS), the report shall clearly identify all requirements of the DAS.
J.11.5
The CB shall provide the draft written report to the advocacy agency within 10 working
days of completing the on-site component of the audit (single site agency) or 20 working
days (multiple site agency), even if the draft decision is not to certify.
J.11.6
The advocacy agency shall have 10 working days from receiving the draft written report in
which to provide a response to the CB.
J.11.7
The CB shall consider any response provided by the advocacy agency, make the final
certification decision and provide the final report to FaHCSIA and the advocacy agency
within a further seven working days, even if the decision is not to certify.
J.11.8
The CB’s procedures shall ensure that in the instance of a major nonconformity:
a) the major nonconformity is closed out before certification or expiry of certification
b) close out shall normally require a follow-up visit by the CB. For a certified advocacy
agency, evidence of a corrective action plan shall be presented to the CB within 5
working days of the date of issue of the major nonconformity, and close out shall
normally require a follow-up visit by the CB within three months
c) the CB shall be able to justify circumstances where close out of a major
nonconformity, or downgrading the major nonconformity to a nonconformity did
not require a follow-up visit
d) for a certified advocacy agency, failure to close out the major nonconformity within
three months of the date of issue, or take action sufficient to downgrade the major
nonconformity to a nonconformity, shall result in automatic suspension of
certification
e) for a certified advocacy agency, if the major nonconformity is downgraded to a
nonconformity, that nonconformity shall be closed out within a further three
months (maximum of six months from the date of issue to fully action a major
nonconformity)
J.11.9
The CB’s procedures shall ensure that in the instance of a nonconformity:
a) the nonconformity is closed out before certification or expiry of certification
b) for a certified advocacy agency, the nonconformity shall be closed out within six
months of the date of issue
c) for a certified advocacy agency, failure to close out a nonconformity within six
months of the date of issue will result in a major nonconformity being raised with
the advocacy agency’s corrective action process
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Decision on certification
J.12.1
The CB shall make decisions on renewing certification based on the results of the
recertification audit, as well as the results of its review of the system over the period of
certification, and complaints received.
J.12.2
If an audit team submits advice of a notifiable issue to FaHCSIA, the CB shall withhold the
advocacy agency’s certification until FaHCSIA advises it in writing that certification can
proceed.
J.12.3
The CB shall advise FaHCSIA of all certification decisions within 5 working days of the
date of the decision. The CB shall provide FaHCSIA with reasons for any decisions to
vary, suspend or withdraw certification, together with a copy of the certification
document(s).
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J.12.4
The CB shall include a CTE in the certification decision-making process.
J.12.5
Certification documents shall include:
a) the effective date of certification which shall be on or after the date of the formal
decision by the CB
b) the expiry date or recertification due date consistent with the recertification cycle
c) the JAS-ANZ symbol. Refer to JAS-ANZ Procedure 3
J.12.6
13
If an advocacy agency ceases to provide advocacy support or FaHCSIA revokes its
funding for any reason, FaHCSIA will notify JAS-ANZ and the CB that issued certification
within 10 working days of revocation becoming effective.
Surveillance
J.13.1
In the context of this procedure, ‘surveillance’ includes surveillance audits in the first and
second years of a three-year certification cycle, and a recertification audit in the third year
prior to expiration of certification. The cycle begins with the certification or recertification
decision.
J.13.2
Surveillance and recertification audits are on‐site audits and shall be planned together with
any other surveillance activities so that the CB can maintain confidence that the certified
services continue to fulfil requirements.
J.13.3
Once certification is achieved, the date of the first surveillance audit shall not be more
than 12 months from the date of the last day of the on‐site component of the certification
or recertification audit. The second surveillance audit shall be conducted not more than 13
months after the last day of the first surveillance audit.
J.13.4
Surveillance audits shall include:
a) reviewing the effectiveness of actions taken on nonconformities identified during the
previous audit
b) progress of planned activities aimed at continual improvement of performance
against the DAS
c) continuing operational control
d) review of any changes to systems or personnel
e) standards 2, 7, 8, and 10 and other selected standards
f) use of marks and/or any other reference to certification
g) interviewing the responsible managers and a sample of consumers in accordance
with Annex C
J.13.5
Following a surveillance audit, the CB shall maintain certification based on demonstration
that the advocacy agency continues to satisfy the requirements of the DAS. It may rely on
a positive conclusion by the audit team leader without further independent review,
provided that:
a) for any major nonconformity or other situation that may lead to suspension or
withdrawal of certification, the CB has a system that requires the audit team
leader to report to the CB the need to initiate a review by appropriately competent
personnel, different from those who carried out the audit, to determine whether
certification can be maintained
b) competent personnel of the CB monitor its surveillance activities, including
monitoring the reporting by its auditors, to confirm that the certification activity is
operating effectively
J.13.6
The purpose of the recertification audit is to confirm the continued conformity and
effectiveness of the advocacy agency’s system against the DAS as a whole. The
recertification audit shall consider the performance of the system over the period of
certification, and include a review of previous surveillance audit reports.
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J.13.7
Recertification audit activities may need to have a stage 1 audit in situations where there
have been significant changes to the management system, the client, or the context in
which the management system is operating (e.g. changes to legislation).
J.13.8
The recertification audit shall include an on-site audit that addresses the following:
a) the scope of the management system in its entirety in the light of internal and
external changes and its continued relevance to the requirements of the DAS
b) evidence to demonstrate the advocacy agency’s effective implementation of their
policies, procedures and practices to comply with the DAS including positive
outcomes for consumers
J.13.9
14
When, during a recertification audit, instances of nonconformity or lack of evidence of
conformity are identified, the CB shall define time limits for correction and corrective
actions to be implemented prior to the expiry of certification.
Use of licences, certificates and marks of conformity
No additional requirements
15
J.15.1
Complaints to suppliers
In the context of this procedure, a ‘supplier’ is an advocacy agency. Complaints to
advocacy agencies include records of all communications and action taken in relation to
the requirements of the DAS. See clause J.8.2.2.
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Annex A - Audit Duration
A.1
Planning for an audit of an advocacy agency will typically take longer than planning for
other types of audits (such as ISO 9001) and large individual variations are likely to occur.
This is partly due to the complexities of sourcing information and obtaining the necessary
consents to arrange effective and representative consumer sampling.
A.2
The on-site audit duration for the stage 2 audit of a single site advocacy agency shall be
not less than one auditor day, and is expected to fall in the range of one to five auditor
days. The duration will depend on a number of factors. The CB shall have a procedure for
determining the amount of audit time necessary, based on the relevant requirements of
IAF MD5:2009 and the following factors:
a)
an advocacy agency’s existing accredited certification to another standard
b)
results of self assessments conducted by the advocacy agency in the last 12
months
c)
the number and type(s) of advocacy models delivered
d)
number of consumers attached to the agency, if any (see C.2.10)
e)
types of disability of the consumers
f)
geographic location of consumers
g)
consumers’ preferred method of engagement (e.g. interview at home, by
telephone, group setting)
h)
level and type of support needed by consumers to enable them to participate in
the audit including access to appropriate methods of communication
i)
ratio of staff to consumers.
A.3
The CB shall demonstrate that in planning the audit with the advocacy agency it has
undertaken a thorough analysis of the above factors and developed an appropriate
process for engaging consumers. This process shall be based on the strategy provided to
the CB by the advocacy agency. See Annex C.
A.4
Audit duration calculations (i.e. auditor days) shall be based on an 8 hour working day
including 1 hour for lunch, and exclude all activities other than auditing. The times are to
be regarded as true minimums: planning, preparation, travel time and reporting shall not
be included. Time spent conducting the document review or other stage 1 audit activities
shall not be included, even if done on-site. The same applies to on-site report writing. The
CB may arrive at the required audit duration by working part-time hours to suit the
advocacy agency.
A.5
Where two or more team members work together (e.g. auditor plus CTE or other technical
expert or another auditor), that time shall be counted as if a single auditor was involved.
When, in exceptional circumstances, CTEs work alone (see Clause J.5.2.10), that time
shall not be counted as contributing to the audit duration, unless the CTE is also
qualified as an auditor or lead auditor.
A.6
Where two or more auditors are used along with one CTE, the CB shall demonstrate that
the CTE has adequate time to conduct the required amount of consumer interviews and
meet the requirements of Clause J.10.5.
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Annex B - Certification of advocacy agencies with multiple sites
B.1
Introduction
B.1.1
Auditing an advocacy agency with multiple service outlets differs from a single-site audit.
The aim of this Annex is to establish criteria for the audit and, if appropriate, the
certification of advocacy agencies with a network of full-time and/or part-time sites, thus
ensuring that the audit provides adequate confidence in the conformity of the advocacy
agency, while being practical and economically feasible.
B.1.2
The requirements of IAF MD 1:2007 apply except as otherwise indicated in this Annex.
B.1.3
Auditing sites and/or outlets of sub-contractors relies on the sub-contractor providing the
relevant information or the CB obtaining agreement from the sub-contractor to conduct the
audit.
B.2
Structure of advocacy agencies with multiple sites
B.2.1
Advocacy agencies with multiple sites include:
a)
multiple sites delivering a single advocacy approach
b)
multiple sites delivering one or more advocacy approaches from each site.
B.2.2
Some advocacy agencies may make use of outreach sites. These sites shall be sampled
in accordance with the requirements of this Annex, but do not need to be visited if the
advocacy agency can provide evidence that services provided at the outreach sites meet
the DAS, and if information, including policies, procedures, and consumer files and
individual plans associated with an outreach site can be provided to the CB for physical
sampling remotely. If this evidence cannot be provided, the CB shall sample and visit
outreach sites as if they were full-time or part-time sites.
B.3
Eligibility criteria for the advocacy agency
B.3.1
The advocacy agency’s management system shall be centrally administered under a
centrally controlled plan and be subject to self assessment. All the sites (including the
central office) shall be assessed under the advocacy agency’s self assessment program
before the CB starts its audit.
B.3.2
The advocacy agency shall demonstrate that it has established a system that complies
with the DAS and that the entire network of sites i meets the requirements of the DAS.
B.3.3
The advocacy agency shall demonstrate its ability to collect and analyse data (including
but not limited to the items listed below) from all sites including the central office, and its
authority and ability to initiate organisational change if required:
a)
system documentation and system changes
b)
handling of complaints
c)
evaluation of corrective actions
d)
self assessment planning and evaluation of the results
e)
consumer engagement.
B.4
Sampling methodology for advocacy agencies with multiple sites
B.4.1
The site selection criteria should include:
a)
results of self assessments by the advocacy agency or previous audits by the CB
b)
records of complaints and communications (see clause J.8.2.2) and other relevant
aspects of corrective and preventive action
c)
significant variations in the size of the sites and number of consumers
d)
the advocacy models delivered
e)
modifications since the last CB audit
f)
geographical location and dispersion
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g)
whether sites are operated by subcontractors
h)
outreach sites
B.5
Size of sample
B.5.1
The minimum number of non-central office sites to be visited per audit is:
initial audit and recertification audit: the size of the sample shall not be less than the
square root of the number of full-time and part-time sites (y= x ), rounded to the upper
whole number.
surveillance audit: the size of the annual sample shall not be less than the square root of
the number of full-time and part-time sites with 0.6 as a coefficient (y=0.6 x ), rounded to
the upper whole number.
B.5.2
In all audits, the central office shall be visited at least once, in addition to the sites
sampled.
B.5.3
Where consumers are collocated with the central office, the consumer population shall be
treated as a separate site.
B.5.4
The size of the sample shall be increased where the CB’s analysis of the advocacy
agency indicates special circumstances such as might apply to any of the site selection
criteria at clause B.4.1.
B.5.5
Where one or more sites of a multi-site advocacy agency delivers more than one
advocacy model, the CB shall sample the models in accordance with Clause J.9.2.11.
B.5.6
Where the advocacy agency also has a hierarchical structure and would otherwise be
sampled at each level, the sampling model which results in the largest sample shall be
applied.
B.6
Audit duration
B.6.1
The stage 2 audit duration for an advocacy agency with multiple sites shall be not less
than two auditor days, and is expected to fall in the range of two to six auditor days. See
Annex A for requirements applying to auditor days.
B.7
Additional sites
B.7.1
Where a certified multi-site advocacy agency wishes to include new sites in the scope of
its certification, the CB shall require it to provide sufficient information to demonstrate that
its management system has been fully implemented in the new sites so as to meet the
requirements of the DAS. Each new group of sites should be considered as an
independent set to determine the sample size, with those chosen for audit to be included
during the next scheduled audit activity. The CB need not conduct additional audits, or
move forward the next scheduled audit, solely due to the operation of additional sites by
an advocacy agency.
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Annex C - Audit planning and consumer sampling
C.1
Introduction
C.1.1
Seeking direct feedback from consumers is a critical element of the audit process. CBs
shall ensure that wherever possible, consumers have been offered the opportunity to
participate in the audit process. However it is not usually practicable for all consumers to
provide direct feedback, and for this reason a sampling approach is normally required to
ensure appropriate levels and types of feedback during the audit.
C.1.2
The CB should select the sample of consumers to be interviewed. This ensures that the
sample is not influenced by other stakeholders which might inhibit the collection of
accurate data.
C.2
Sampling principles
C.2.1
Consumer sampling shall be determined at the site level on a case-by-case basis.
C.2.2
CBs may sample from all consumers who have received ongoing support, where the
agency has contact details.
C.2.3
A proposed strategy for sampling consumers should be developed by the advocacy
agency in consultation with relevant stakeholders, and negotiated with the CB, so that the
CB may quote for certification services. This strategy shall be made available to other
CBs, on request.
C.2.4
Ideally, emphasis should be placed on the agency inviting consumers to participate in the
audit and in turn, the CB should select from a list of willing participants.
C.2.5
The CB shall negotiate the proposed sample numbers and sampling approach, including
methods of communication and sampling methods (face-to-face interview, focus groups,
telephone survey, mail survey) with the advocacy agency when planning the audit.
C.2.6
CBs should maintain a flexible approach to consumer involvement methods, ensuring that
priority is given to methods encompassing direct communication.
C.2.7
In sampling consumers, the CB shall have regard to the vulnerability of some consumers
which may lead them to be unable to participate.
C.2.8
The CB shall ensure that the sampling approach is appropriate to the service delivery
context of the advocacy agency. An advocacy agency with a small number of consumers
would not need an extensive consultation mechanism around sampling.
C.2.9
The CB shall attempt to represent the demographics of the consumers assisted by the
advocacy agency, when sampling consumers. Some of the demographics to consider are:
a)
disability type
b)
gender
c)
age
d)
cultural or language differences
e)
complexity of support needs, including communication
f)
length of tenure with organisation (includes those exited).
C.2.10
Although the key focus of this Annex is on sampling consumers, in the case of systemic
advocacy, CBs will need to sample consumers who are associated with the systemic
advocacy work of the agency through stakeholder committees and groups. Where such
consumers are not available, the CB should sample other external stakeholders
connected with the advocacy work.
C.2.11
Where an advocacy agency delivers more than one advocacy model, the CB shall sample
consumers receiving each model of advocacy in accordance with Clause J.9.2.11.
C.2.12
The sampling approach does not preclude consumers talking to an audit team member if
the opportunity arises and they choose to during an audit.
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C.2.13
The CB shall verify that the advocacy agency has:
a)
developed the sampling approach in consultation with relevant stakeholders
b)
made all reasonable attempts to inform all its consumers in accessible and
varying formats of all scheduled audits and provide them with an opportunity to
participate in the process and in the consumer sample
c)
made it clear to all consumers that they are entitled to involve an independent
advocate or support person of their choice in the audit process if they wish.
C.3
Process for determining consumer sample size
C.3.1
Noting that consumers have the right not to be involved, the minimum number of
consumers to be sampled for an audit of an advocacy agency (or per site, for a multi-site
advocacy agency) is:
a)
initial and recertification audits: the square root of the number of consumers
receiving advocacy support over the last three months (y= x ), rounded to the
upper whole number
b)
surveillance audit: 0.6 times the square root of the number of consumers
receiving advocacy support over the last three months (y=0.6 x ), rounded to the
upper whole number.
C.3.2
The CB should aim for a minimum of 5, and a maximum of 10 consumers per advocacy
model and per site.
C.3.3
The CB should aim to have one to one direct contact with 50% of the proposed sample of
consumers. It is understood that in the advocacy context, many of these interviews will be
conducted via telephone or other technologies, as consumers are not normally present on
site at advocacy agencies. In using some technologies, CBs shall be mindful of the
possibility of others accessing the conversations, and shall take steps to ensure
confidentiality is maintained in remote interview situations. However, one to one face to
face interviews are preferable to remote interviews, where practicable. If the 50% ratio
cannot be achieved (e.g. refusals or clear preference by consumers for another
consultation method), the CB shall clearly document its justification for the sampling
approaches used. The remaining 50% may be sampled using other methods including:
a)
focus group
b)
written survey
c)
other innovative ways to involve consumers.
C.4
Consumer file sampling
C.4.1
Consumer file sampling aims to cross check verbal information gathered from consumers
and to confirm outcomes for consumers. However, there will be times when consumers
agree to be interviewed, but not to allow access to their files; and vice versa. While the
principles applying to consumer sampling also initially apply to file sampling, the CB may
also need to follow up on file specific issues identified during interviews with consumers or
others. This requires wider access to files, and the CB shall try to obtain appropriate
additional consents, to maximise the number of files available for review.
C.4.2
To ensure validity of the audit, files reviewed at each site should normally cover all of the
consumers sampled and should not be less than the number of consumers interviewed.
C.4.3
All file access shall be by consent by the consumer and shall comply with the provisions of
the Privacy Act and any relevant state or territory legislation.
C.4.4
Where advocacy agencies deliver advocacy models where no consumers are attached to
the agency, sampling consumer files is not applicable for those models. See clause
C.2.10. In this case CBs shall sample whatever documents or records are available to
cross-check information gathered in interviews of external stakeholders.
C.5
Traceability of audit planning and consumer sampling processes
C.5.1
A CB shall be able to justify how it samples consumers for any audit. Any reduction in the
sample size shall be justified and documented in each case (e.g. where an insufficient
number of consumer consents are received). The CB shall pay particular attention to the
302
validity of the results of the audit where the sample size is likely to be 30% or more below
the numbers which would apply using the above sampling approaches. If in doubt about
the validity, advice should be sought from FaHCSIA before the audit begins.
C.5.2
Sampling strategies shall be sufficiently documented for each audit so as to be able to
trace compliance with all the requirements of this Annex. This information may be included
in, or attached to the audit plan, or may be separately recorded.
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Annex D - Code of Ethics
D.1
Auditors, CTEs, other technical experts and staff of CBs must abide by this code of ethics
when auditing within the Disability Advocacy sector.
D.2
Audit team selection, ongoing work and training should be inclusive and supportive of the
unique needs and talents of people with disability, as per the Disability Discrimination Act.
Depending on the circumstances, this may include, but is not limited to:
a)
providing accessible information through Braille, Auslan interpreters, Easy English
or a support person
b)
providing an accessible workplace, noting that some modifications to the office
environment and equipment can be purchased under the government-run
Workplace Modifications Scheme
c)
ensuring that all CB staff are given some information on disability awareness as
part of their induction, and those who require it, such as human resources
personnel, are given more in-depth training as required
d)
working collaboratively with people with disability to ensure that they are given
meaningful roles within the organisation in which their input and feedback can be
valued and used in a positive and constructive manner. For example, this could
be achieved through offering structured peer support and mentoring, or engaging
with an independent advocate to resolve any work-related issues. An independent
advocate of a staff member's choice should always be allowed to assist them to
resolve work-related matters when requested, and all staff members should be
aware of this option
e)
developing a Disability Action Plan and submitting it to the Australian Human
Rights Commission.
D.3
CBs should document all requests for modifications and adaptations by people with
disability in an interview or as part of their job or training (e.g. asking for an interpreter or
large print documents), along with the outcomes of the requests.
D.4
CBs should be mindful of the human rights of people with disability as outlined in the
United Nations Convention on the Rights of Persons with Disabilities, in particular the
Principles and Objectives, and Articles (http://www.un.org/disabilities/).
D.5
CBs should be considerate of the working hours of advocacy agency staff when planning
the audit.
D.6
The CB should promote available complaint mechanisms to advocacy agencies and
participating consumers.
D.7
During the audit:
a)
all consumers have the right and opportunity to be involved and consulted at no
substantive cost to themselves
b)
consumers have the right not to be involved
c)
consumers' confidentiality and privacy shall be respected in all aspects of the
audit including communications in person and remote communication via
technology such as video conferencing
d)
the CB should encourage sampling methods that maximise the confidentiality of
participants
e)
the CB shall ensure that the advocacy agency has invited consumer
representation at the opening and closing meetings of all audits
f)
the CB shall ensure that the advocacy agency has advised consumers about
opportunities to participate in the audit, including opportunities for family, other
support or guardians to participate
g)
the CB shall ensure that people with disability receive timely and accessible
information about the audit process to allow for full and informed contribution
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h)
consumers have the right to independent advocacy and support to assist with
having their say
i)
consumers should have appropriate support to facilitate genuine participation.
D.8
The CB shall facilitate transfer of certification if requested by an advocacy agency it has
certified. It shall not revoke certification simply because an advocacy agency advises of its
intent to change its CB.
D.9
CBs and their staff (external or internal) should promote the benefits of the National
Disability Advocacy Program to all interested parties, and not openly criticise the
Government’s initiatives in this sector. CBs should actively participate in the continuous
improvement of the Program by identifying and raising issues with the relevant
infrastructure element, i.e. FaHCSIA or JAS-ANZ.
D.10
Auditors, CTEs, other technical experts and staff of CBs involved in audits within the
disability sector must be free of conflicts of interest.
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Attachment 2 - Consent for the Release of Information
The person giving consent needs to read this page, or have its contents explained to
him / her before signing on the next page.
Why is the information collected?
The Australian Government gives disability
advocacy agencies money to help people
with disability. In return, the Government
expects every disability advocacy agency
in Australia to follow the Disability
Advocacy Standards. These are rules that
tell them what they need to do to make
sure that they give people with disability
good quality support.
An audit team from a Certification Body
will visit your disability advocacy agency to
check if it is following the Standards. The
more the audit team can learn about your
disability advocacy agency, and what it is
you need, the better chance there is that
you will get the right type of support.
To help during these audits, the Audit
team may need to have a look at personal
files.
What information is collected?
The information listed below may be
collected from you by your disability
advocacy agency. By signing this form you
are saying it is OK for them to give
information about you to the Audit team for
the purpose of checking to see how they
provide good quality advocacy support.
The information that may be collected may
include such information as:
- Your full name;
- Your date of birth, sex, address,
and if you are an Australian citizen
or permanent resident;
- The type of disability you have;
- Who referred you to the agency;
- Why you have been referred to the
agency;
- Your individual plan with the
agency; and
- The reason why you leave the
agency.
Protection of information
Your disability advocacy agency is obliged
to observe strict privacy rules called
Information Privacy Principles which are
contained in the Privacy Act 1988. This
means that they must:
- Tell you why they need to collect
your information;
- Tell you what they do with your
information and who they will give
it to;
- Store the information securely;
- Only use the information for the
purposes they obtained it; and
- Only pass your information on when
you have been advised of the other
parties to whom your information may
be given and you have consented, or
when the law allows.
The information that is forwarded to the
audit team will be stored in a secure
manner and your personal information will
only be used or disclosed by the
certification body, as described on this
form.
The person giving consent may keep
this page for information.
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Consent Form for the Release of Information
__________________________________________________
Consent
I
Of (address)
give consent for:
the agency providing me with advocacy support, to provide some or all of my personal
information to an audit team from:
the Certification Body, or to another organisation as directed by the Commonwealth. I
acknowledge that the disclosure of some or all of my personal information to the certification
body, or to another organisation as directed by the Commonwealth, will occur for the purpose
of checking to see how the agency provides good quality advocacy support.
Client’s (or legal guardian’s)
Signature
Date:
Compliance with Information Privacy Principle 2
I (name of
Authorised officer)
Of (agency name)
have explained to the person giving consent, and I believe they understand that
 personal information is collected for the purpose of determining access to and delivery of
advocacy support under the Disability Services Act 1986 through a disability advocacy
agency; and
 this disability advocacy agency may be required, from time to time, to pass some or all of
their personal information to the certification body, or to another organisation as directed by
the Commonwealth.
Signature
(Authorised officer)
Date
307
Attachment 3 - Disability Advocacy Standards, key performance indicators and examples of evidence
Standard
Key Performance Indicator
Examples of Evidence
Standard 1: Accessing
advocacy
1.1 The advocacy agency adopts, applies
and promotes non-discriminatory
policies in respect of age, gender, race,
culture, religion, disability or living
arrangements, consistent with the
contractual obligations and purpose of
the advocacy agency and the relative
need and available resources.
All agencies
 Purpose statement that makes it clear who the agency works with to promote,
protect and defend the welfare of and justice for people with disability.
 Evidence of staff participation in anti-discrimination and cultural awareness training
and/or evidence of links with relevant specialist agencies as appropriate, such as
MOUs or participation in joint projects with multicultural or indigenous advocacy
agencies.
 Evidence that the organisation is aware of demographic information/ABS statistics
and match of this to the profile of people with disability who receive advocacy
support.
 Documented and implemented non-discriminatory practices and policies for
identifying and/or responding to requests for information, referral and/or advocacy
support.
Each person with disability
has opportunities to access
advocacy on the basis of
relative need and available
resources.
1.2 The advocacy agency has processes to
determine how the individuals or issues
supported are chosen and prioritised
based on relative need and available
resources.
1.3 Each person with disability is informed
about how decisions are made in
relation to access and advocacy issues.
Agencies undertaking individual advocacy/ legal advocacy
 Documented and implemented entry and exit policies and procedures highlighting
non-discriminatory practice, which may include ongoing access for people with
disability who receive advocacy support after their issue/case is closed.
Agencies undertaking systemic advocacy
 Documented and implemented practices and/or policies for deciding and
communicating which systemic issues the agency will work on.
 Documented and implemented practices and policies showing how people with
disabilities influence/contribute to the prioritising processes that determine which
issues receive attention.
Agencies undertaking citizen advocacy
 Annual protégé recruitment plan that reflects diversity and level of vulnerability of
people with disability.
 Consistent practice of “seek-out” recruitment of people with a disability who need
advocacy, but who would not ordinarily come to the attention of the agency if it relied
solely on (self- or other-initiated) referrals.
 Established Advisory Support Group (e.g. Sub-Committee), which can assist in the
implementation of the appropriate Protégé entry and exit policies and procedures.
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Standard 2: Individual
needs
Each person with disability
receives advocacy that is
designed to meet their
individual needs and
interests.
2.1
The advocacy agency has a process
for determining and documenting
the advocacy objectives that reflect
the wishes, needs or interests of
each person with disability.
2.2
Advocacy activities are directed to
meeting the advocacy objectives of
each person with disability.
2.3
Each person with disability engaged
in determining advocacy objectives is
provided with opportunities to involve
a support person of their choice.
2.4
In meeting the needs of a person
with disability, the advocacy agency
avoids, where possible, any conflict
of interest or the perception of any
conflict of interest in relation to the
conduct of its advocacy work, and
deals with any conflict or perceived
conflict transparently.
2.5
The advocacy agency helps to
empower people to advocate for
themselves or their family or others
with appropriate strategies (e.g.
information, training, mentoring,
support).
All agencies
 Evidence of practice of supporting/educating people with disabilities to advocate for
themselves and/or of supporting/educating families to advocate on their behalf.
 Examples of how the agency has taken into account the specific needs of people
from Indigenous and CALD backgrounds, people with specific disabilities such as
hearing impairment, people with literacy difficulties.
 Interpreters are provided where requested or where a need is identified.
 Agency promotional material that makes it clear the extent, if at all, the agency
provides training and support.
 Documented and implemented policies and practice of responding to the information
needs of people with disabilities/families and providing referrals as appropriate.
 Agency policy on conflict of interest.
 Documented and implemented practices and policies for identifying and
transparently dealing with conflicts of interest that arise for the organisation, Board
and staff, for example, a Conflict of Interest register maintained for staff and Boards
of Management, or evidence in minutes of a standing agenda item that flags the
need to declare any conflict of interest.
 Management, staff and volunteer training in recognising and dealing with conflicts of
interest.
Agencies undertaking individual advocacy/ legal advocacy
 Documented and implemented policies and practices for developing and
implementing individual advocacy plans in partnership with people with disability
and/or their families/guardians (as appropriate).
 Evidence of collecting and reviewing feedback about the extent to which the needs
of the person with a disability are met.
Agencies undertaking self advocacy

Observations of people with disabilities receiving support to develop advocacy action
plans to address their wishes, needs or goals.
Agencies undertaking systemic advocacy
 Documented and implemented practices and policies showing how people with
disabilities influence the choice of advocacy objective.
 Evidence of reporting of outcomes / review of advocacy process.
 Evidence of advocacy plan, actions taken and people/agencies involved, or file notes
detailing progress or justification for not having a plan in place.
 Policies and procedures to address how the agency selects and prioritises the
systemic issues it addresses.
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Agencies undertaking citizen advocacy






Standard 3: Decision
making and choice
Each person with disability
has the opportunity to
participate as fully as
possible in making
decisions about the
advocacy activities
undertaken.
3.1
3.2
The advocacy agency’s policies
support each person with disability
to direct, within the limits of their
capacity or interest, the advocacy
activities undertaken to meet their
advocacy objectives.
In all circumstances the advocacy
activity is informed by ethical
guidelines.
Documented and implemented practices and policies for developing confidential
individual written profiles detailing ‘need’ and seeking advocates based on their skills
in relation to these needs.
Observations of individual being given opportunity to discuss their advocacy needs
and advocate role.
Details of completed relationships, and/or those being rematched or awaiting
rematching.
Documented and implemented practices and policies for reviewing the extent to
which the needs of the person with a disability are being met.
Practice of one-to-one (or near one-to-one) matching of people with a disability with
advocates to ensure that the individual needs of the person with the disability
remains the focus of the advocacy relationship.
Practice of recruiting advocates whose role is strictly voluntary, thereby avoiding any
conflicts of interest arising from receipt of monetary and/or in-kind payments.
All agencies




Observations of the way advocates interact with people with disability in making
decisions about advocacy activities.
Evidence of the involvement of people with disability in agency decision-making (e.g.
representation on the Board, participation in consultations that feed into agency’s
strategic plan or lead to improve practices, involvement in surveys that inform
agency policies and procedures).
Evidence of the involvement of people with disability in the agency’s quality
assurance activities.
Observation of information, strategies and ideas presented to people with disabilities
and families in ways that they can understand.
Agencies undertaking individual advocacy/legal advocacy


Ethics guidelines for supporting people with disability in making decisions about
advocacy activities.
Procedures are established and implemented for the regular review of advocacy
actions and these require review of the extent to which the agency promotes the
person’s choices and decisions.
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

Feedback is sought from people with disability on the extent to which the agency
promotes choice and decision making.
Documented and implemented practices and policies for determining a decision on
behalf of a person who has impaired decision making capacity e.g. consultation with
them, documenting factors taken into account including knowledge gathered over
time.
Agencies undertaking citizen advocacy



Evidence of induction and or training that orientates advocates to the need to
support people with a disability, where appropriate, to make decisions and choices.
Practice of supporting advocates tofacilitate the process, where appropriate, of
decisions and choices made by people with a disability.
Evidence of feedback gained from people with disability about how they are
supported to make their choices.
Agencies undertaking systemic advocacy



Documented and implemented practices and policies that demonstrates that people
with disabilities influence decision making about advocacy activities.
Observations of individual people with disability and/or their families becoming
involved in systemic advocacy activities of their choice.
Ethical guidelines inform systemic advocacy policy and practice.
Agencies undertaking family advocacy

Standard 4: Privacy,
dignity and confidentiality
The right of each person
with disability to privacy,
dignity and confidentiality is
recognised and respected.
4.1
The advocacy agency complies with
the Information Privacy Principles of
the Privacy Act 1988 in order to
protect and respect the rights of each
person with disability.
4.2
The advocacy agency promotes
privacy, dignity and respect for each
person with disability.
Documented and implemented practices and policies for encouraging families to
include the views of the person with disability in advocacy efforts where appropriate.
All agencies
 Observations of the way advocates and agency staff talk and write about people with
a disability.
 Clear privacy policy ensuring compliance with relevant State/Territory and Federal
legislation.
 Documented and implemented practices and policies for obtaining consent where
relevant and possible, examples could include consent to use photographs for
publicity or to share information.
 Confidential information safely stored e.g. locked filing cabinets.
 Staff [and volunteers and contractors] sign confidentiality agreements.
311




Evidence that information about right to privacy is provided to people with disabilities
and their families when they receive advocacy support.
Evidence that the feedback from people with disability who receive advocacy support
is used to influence the development of policies, procedures and practice of the
agency.
Feedback from people with disability who receive advocacy support about the
attitude of agency staff to people with a disability.
Feedback from external observers on the attitudes of the advocacy agency to people
with disability.
Agencies undertaking citizen advocacy
 Feedback from people with disability who receive advocacy support about the
attitude of agency staff to people with disability.
 Feedback from people with disability who receive advocacy support on the attitudes
of the advocacy agency to people with disability.
 Feedback from people with disability who receive advocacy support.
 Content and practice of orienting advocates to the importance of recognising and
respecting the right of people with disability to privacy, dignity and confidentiality.
Agencies undertaking family advocacy
 Documented and implemented practices and policies for encouraging families to
obtain the approval of the person with disability before sharing information about the
person with disability in the pursuit of advocacy efforts, where appropriate.
312
Standard 5: Participation
and integration
Each person with disability
is supported and
encouraged to participate
and be involved in the
community.
5.1
Through advocacy, opportunities for
participation and involvement in the
community are promoted.
5.2
Where appropriate, the advocacy
agency takes action to introduce,
influence or produce positive
systemic change in the community.
All agencies
 Purpose statement that makes it clear that the agency seeks to promote participation
and inclusion.
 Examples of barriers to community participation being raised with other agencies
and authorities for the purpose of promoting change.
 People with disability connected to the organisation report that they feel valued and
accepted by agency staff.
Agencies undertaking individual advocacy/legal advocacy
 Evidence of advocacy taken on behalf of individual people with disabilities aimed at
increasing their participation and inclusion in the community.
Agencies undertaking citizen advocacy
 Examples of activities people with disability who receive advocacy support and
advocates are involved in – while recognising that the citizen advocates and the
person with a disability make their own decisions outside of the control of the funded
agency.
 Observation that community participation is covered in citizen advocate orientation.
 Practice of recruiting advocates who—by virtue of being non-service, “ordinary”
members of the community—can facilitate the participation and integration of people
with a disability.
 Content and practice of orienting advocates to their potential role in facilitating the
participation and integration of people with a disability.
Agencies undertaking family advocacy /systemic advocacy/ self advocacy
 Examples of events /activities hosted or engaged in which promote the inclusion of
people with disabilities as valued and contributing members of community.
 Examples of evaluation forms from events or activities hosted by the organisation.
313
Standard 6: Valued status
The intrinsic value of each
person with a disability is
recognised and each
person is supported and
encouraged to enhance
their valued status in the
community.
6.1
Through advocacy, the aspirations
and strengths of each person with
disability is promoted.
6.2
The advocacy agency promotes the
intrinsic value and the valued status
of each person with disability in all its
activities.
All agencies
 The valued status of people with disability is promoted in reports and promotional
material.
 Details of public speaking at conferences, lectures and professional gatherings to
promote a positive image of people with disabilities.
 Examples of issues raised or referrals made to systemic advocacy agencies and/or
other agencies and authorities.
 Examples of activities and issues that the agency engages in that supports the
valued status of people with a disability.
Agencies undertaking citizen advocacy


Standard 7: Complaints
and disputes
Each person with disability,
who has a complaint or
dispute with the advocacy
agency, is encouraged to
raise it, and have it
resolved, without threat of
retribution.
7.1
7.2
The advocacy agency informs each
person with disability about how to
raise a complaint or initiate a
dispute about any areas of
dissatisfaction with the advocacy
agency, without threat of retribution.
The advocacy agency seeks to
resolve complaints or disputes
raised or initiated by each person
with disability, with access to both
internal complaints resolution
mechanisms and external
complaints resolution mechanisms.
Examples of activities people with disability who receive advocacy support and
advocates are involved in that promote the intrinsic value and the valued status of
people with disability– while recognising that the citizen advocates and the person
with a disability make their own decisions outside of the control of the funded
agency.
Citizen advocacy orientation documentation includes information about valued status
and what this means in practice.
All agencies
 Documented complaints policy and procedures.
 Documented and implemented practices and policies for investigating and resolving
complaints – cover both internal and external complaints resolution mechanisms,
including the Complaints Resolution and Referral Service (CRRS).
 File review demonstrates that the agency completes complaints investigations in
accordance with its complaints procedures.
 People with disability who access the advocacy agency are provided with information
about the agency’s complaints policy and procedures.
 The agency reviews its complaints policy, procedures, processes and practices to
ensure implementation is appropriate to complainants.
 Service user feedback about the complaints mechanism.
 Complaints register.
314
Standard 8: Agency
management
8.1
The advocacy agency has clearly
stated aims and objectives that
communicate to each person with
disability and other relevant
stakeholders the scope and
limitations of the advocacy agency.
8.2
The advocacy agency has
governance and management
systems in place that facilitate quality
management practices and
continuous improvement.
8.3
The advocacy agency operates
independently and is structured in
such a way that it is as free as
possible from conflicts with other
service provision and the interests of
each person with disability.
Standard 9: Staff,
recruitment, employment
and training
9.1
The advocacy agency ensures that
its staff have relevant skills and
competencies.
Each person who has an
employment or volunteer
relationship with the
advocacy agency has
appropriate skills and
competencies.
9.2
The advocacy agency provides
opportunities for the appropriate and
continuing training and skills
development for each staff member.
Each advocacy agency
adopts quality management
systems and practices that
optimise the effectiveness
of advocacy for each
person with disability and
facilitates continuous
improvement.
All agencies
 Documented agency aims and objectives.
 Documented and implemented practices and policies for promotion and
communication of agency aims and objectives with people with disability who receive
advocacy support and stakeholders.
 Reviews of agency management systems involving service users (eg. people with
disability who receive advocacy support, family members, citizen advocates) –
including documented annual self assessments and continuous improvement plans.
 Clear governance arrangements.
 Documented and implemented policies and practices for performance and risk
management are undertaken.
 Documented policy on agency independence.
 Agency management and staff can provide practical examples of how they operate
to ensure they are as free as possible from things that conflict with the best interests
of people with disability.
 Policies and procedures include referral to another agency if required to prevent a
conflict of interest.
 Evidence of the involvement of people with disability in the agency’s quality
assurance activities.
 Minutes of management committee meetings.
 Documented roles and responsibilities of management committee office bearers.
All agencies
 Current list of all people who have an employment relationship with the advocacy
agency.
 Position descriptions of all paid and unpaid staff that describe skills and
competencies needed for their role.
 Documented and implemented practices and policies for recruitment & induction that
ensure paid and unpaid staff have the necessary skills and competencies for their
position, including relevant qualification (where appropriate).
 Staff appraisals conducted at least annually.
 Training and development plans for all staff.
Agencies undertaking citizen advocacy
 Independent evaluations of practices for developing the capacity of citizen advocates
to assist people with disability meet their advocacy objectives.
315

Standard 10: Protection
of human rights and
freedom from abuse
The advocacy agency acts
to prevent abuse and
neglect and to uphold the
legal and human rights of
each person with disability.
10.1
The advocacy agency takes all
practical and appropriate steps to
prevent abuse, neglect and
discrimination of each person with
disability.
10.2
The advocacy agency upholds and
promotes the legal and human rights
of each person with disability.
Regular opportunities for the staff and board of management to avail themselves of
Citizen Advocacy-related training, including participation in the independent
evaluation of other Citizen Advocacy agencies, as a means to enhance conceptual
and practical knowledge.
All agencies
 Staff knowledge and skills in recognising and reporting criminal activities, abuse and
neglect.
 Evidence of staff knowledge/learning about human and legal rights.
 Agency management and staff can provide practical examples of how they act to
prevent abuse and neglect – (eg an outreach program which seeks out people with
disability who are abused or neglected and who would not normally come to the
attention of other agencies; community education to raise awareness about abuse of
people with disabilities and strategies to prevent and respond to it, etc).
 Documented and implemented policies and procedures around responding
to/reporting in situations of abuse and neglect. Examples could include a flow chart
on who to notify and/or stages of reporting sequence/steps.
 Documented and implemented policies and procedures reflect prevention of abuse
that could occur internal to the agency and external to the agency.
 Evidence of advocacy agency activities to promote and uphold the legal and human
rights of people with disabilities on either an individual or systemic basis.
Agencies undertaking citizen advocacy
 Practice of recruiting advocates for people with a disability who are isolated and
otherwise vulnerable, in order to ensure their protection of human rights and freedom
from abuse, consistent with the mission of Citizen Advocacy.
 Content and practice of orientating advocates to their role in ensuring the protection
of the human rights, and prevention from abuse, of peoples with a disability.
 Practice of supporting advocates in their role of ensuring the protection of the human
rights, and prevention from abuse, of people with a disability.
316