CONSULTATION ON THE PRINCIPLES OF INCLUSIVE COMMUNICATION
GENERAL COMMENTS
i.
Capability Scotland works with disabled people of all ages and their families
and carers throughout Scotland to provide a broad range of flexible,
personalised care services. We are also a campaigning organisation,
committed to using the influence we have to ensure disabled people achieve
the same human and civil rights as the rest of society.
ii.
As part of the internal consultation process we held three focus groups to
discuss the communication principles. These focus groups took place at
Capability services, namely Lanarkshire Houses, New Trinity and Upper
Springland. The focus groups included individuals with sensory impairments
limited mobility and/or learning difficulties.
iii.
The purpose of the focus groups was to discuss the principles of inclusive
communication and the quality of the consultation document. The groups also
discussed how inclusive communication can be achieved and how the
consultation document could be improved.
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General Comments
1. Capability Scotland welcomes the Scottish Government’s efforts to develop
principles of inclusive communication. It is essential that public bodies
improve their communications skills if they are to tackle the social and political
exclusion that many groups experience.
2. Unfortunately, this consultation document and the principles it contains are
extremely disappointing. The document is very inaccessible and, ironically, it
fails to follow the principles which it contains.
3. There is a clear need for the Scottish Government to redevelop these
principles in partnership with the groups who most commonly experience
communication barriers, such as those with learning difficulties, sensory
impairments, literacy problems and individuals whose first language is not
English.
What do you think about the document’s accessibility?
4. Capability Scotland believes that any document claiming to set out the basic
principles of inclusive communication should be exemplary in its clarity and
accessibility. Unfortunately, we found this document to be extremely
inaccessible.
5. The purpose and content of this document are extremely unclear and its
contents do not follow a logical order. Furthermore, the document is not
written in Plain English, with jargon and professional terminology used
throughout. The content also fluctuates between being overly simplistic and
overly complicated. The following examples illustrate these concerns:

The document’s introduction contains a lot of irrelevant information.
The second sentence, for instance, states that, ‘The Independent
Living in Scotland Core Reference Group sees inclusive
communication as a priority’. We would question how many people
reading this document will know who the Core Reference Group are or
why their opinion is important. It would be more helpful to replace this
paragraph with an overview of why inclusive communication should be
a priority and why it is so important to service users.

Page two of the document begins with the following sentence; ‘This
document maps inclusive communication to the Equality Act 2010’.
This is not a clear sentence and it is not written in plain English. The
sentence also makes the purpose of the document unclear. Is it a
statement of what the principles of inclusive communication should be
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or is it a guide to communication provisions in the Equality Act? This
never really becomes clear and, unfortunately, the document doesn’t
achieve either of these objectives.

Page four then goes on to list all the organisations who were involved
in developing the document. We would question the relevance of this
list. Could this be moved to the end of the document and replaced with
a sentence stating that ‘many organisations have contributed to this
guidance including numerous voluntary and public sector organisations
(for a full list see Appendix 1)’ or similar?

Page five goes on to talk about the Equalities Act 2010. The
information in this section might be of interest to those who have a
legal understanding of equalities – but the audience for this document
is surely much wider. It would be much more beneficial to include
information on why it is important to communicate inclusively and the
impact this can have on various groups rather than focusing on
detailed legal obligations. If it is decided that the Equalities Act should
be mentioned then perhaps readers could be directed either to an
appendix or to the relevant sections of the EHRC Guidance on the
Equalities Act. The current paragraph is confusing, distracting and
unnecessary.
6. It is essential that the document and principles can be understood and used
by service users. Our focus groups confirmed that is is not currently the case.
The following question were raised by Capability service users:
-
Who is this guidance for?
Why does it use complicated words if it is supposed to be easy to
understand?
What are the pictures supposed to be of?
Do I need to understand the law it talks about?
7. We also showed the focus groups the Easy Read Guide to the Equalities Act
which was included in the consultation document. Overall, the group found the
document very confusing. They found the text difficult to follow and thought
that the illustrations were distracting and unclear. None of the group with
learning difficulties thought they would be able to understand the document
without help and support.
8. This shows just how poorly understood communication support needs are by
many public bodies. We would urge the Scottish Government to re-examine
this document in partnership with disabled people and other groups who
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experience communication difficulties. If the Scottish Government does not
fully understand the communication needs of these groups then they are not
in a position to effectively advise other public bodies.
What do you think about the principles included in the document?
9. Capability Scotland believes there is still a great deal of work to be done on
the principles contained in the document. The principles seem to have been
arbitrarily selected and we would be interested to know whether they were
developed in partnership with disabled people and other groups who
experience communication barriers.
10. There is also a need for each of the principles to be expanded upon and
explained. At present, the principles are so broad they may be of little use to
someone who is reading them for the first time or who has no background in
communication requirements. Above all, there is a need for guidance to be
provided on practical implementation of the principles.
The Individual Principles
Principle 1: Recognise that every community or group may include people with
communication support needs
11. Capability Scotland agree with this principle – as did our focus group.
However, it was also felt that in order for the principle to be successfully
applied there is a need for the reader to have a good basic understanding of
what is meant by ‘communication support needs’ and the wide range of
people who might have such needs. Many of our focus group members felt
that the term ‘communication support needs’ is commonly understood as only
being relevant to blind or deaf people or those whose first language is not
English. The focus group itself, however, is demonstrative of how wide
communication support needs can be. When people were asked what their
preferred method of communicating was and what support they required, their
answers were extremely varied and included:
-
Picture symbols
Having someone phone to explain the information
Having information loaded via memory card etc onto diravox so it could be
used through a reader.
Online videos explaining information
Easy Read with pictures
DVDs to overcome literacy problems
Someone to explain written information to them
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12. The group also felt that if people did not use their preferred means of
communication there was often no point in communicating at all because; “It’s
a total waste of time and money” and “You feel really stupid”. It is essential
that readers of the document understand the wide range of communication
support needs that exist if this principle is to be successfully implemented.
13. It is also essential that public bodies have a clear understanding of what is
covered by the term ‘communication’. One focus group was worried that
communication is sometimes interpreted to mean only written material such
as letters and e-mails. They felt there was a need to mention the wide range
of mediums that should be made accessible, such as telephone
conversations, face to face conversations, group discussions, presentations at
meetings or seminars, SMS text messages and social networking. Capability
believes that there is a need for this to be specifically addressed in the
document.
14. The principle should also mention the need for public bodies to address
communication needs rather than just recognise them.
Principle 2 – Communication is a two way process – understanding and being
understood.
15. Capability Scotland agree with principle two and believe that it is essential for
public bodies to establish a clear two way dialogue with hard to reach groups.
Again, however, there is a need for the document to explain how this might be
done in practice and what the benefits of establishing a dialogue are.
16. Members of the focus groups noted that it is important for public bodies to
think realistically about how different groups are supposed to respond to the
information they are given. The group questioned how people with learning
difficulties could respond to a consultation like this if they had not been invited
to a focus group. Would they be expected to give written responses or answer
the questions via e-mail? They felt that this would not be realistic for many
people with poor literacy or learning difficulties. They also thought there was a
need to invest in supporting some people to respond to information.
17. The focus group illustrated how poor communication with certain group
currently is. Several members of the group said they often felt ignored and
insisted that they wanted to heard. One commented, “I’m a person too and I
have an opinion”.
Principle 3: Ensure User Involvement from the Start
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18. Capability Scotland believe in coproduction and in involving service users –
including individuals with disabilities - as early as possible in decision making
and policy development. We therefore agree with principle three in theory.
Again, however, the principle is extremely unclear and poorly expressed.
19. Members of the focus groups also found the principle confusing. The main
question was, “What exactly should users be involved in from the start?”
Another question raised was, “How do you involve people from the start if you
don’t know how to communicate with them?”
20. The Scottish Government clearly needs to ensure that the principles
themselves are clear and make sense to service users.
Principle 4: Be flexible with the way your service is provided and remember
not to take a one size fits all approach
21. Again, we agree with this principle but feel that is unclear and poorly
expressed. Without explanation and guidance it will be extremely difficult for
public bodies to implement.
Principle 5: Communication accessibility is as important as physical
accessibility
22. We do not think this is a useful principle to include for several reasons. Firstly,
many members of our focus groups felt that communication was far more
important than physical accessibility. They felt that without the ability to
communicate, physical access is often “pointless”. The group also mentioned
that, without communication, there is no way to improve physical accessibility
or to bring it to anyone’s attention.
23. Furthermore, it was felt that many public bodies do not yet grasp the
importance of physical accessibility. One participant mentioned how difficult it
can be to find an accessible parking space or to get on a bus in a wheelchair.
The group felt that “these things are easy but still nobody does them”. Again,
emphasis should be placed on why accessible communication is so important,
rather than why it is more or less important than something else.
Principle 6: Inclusive communication does not belong to only one group
24. Capability Scotland feel that this principle is extremely unclear. It is not written
in plain English and it is not followed up with any kind of explanation.
Questions raised include, ‘Who are the groups referred to?’’ ‘Why would
communication belong to these groups alone?’ and ‘Are groups people with
particular disabilities?’
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25. We assume the point behind this principle is that the communication needs of
one person or group of people should not be allowed to overshadow the
communication needs of another person or group of people. If this is the case,
then this should be clearly stated and there should be some guidance about
how difficult decisions about balancing communication requirements can be
approached. Without such guidance and explanation the statement is
meaningless.
What changes, if any, would you make to the document?
26. We believe that the document and principles should be redeveloped in
partnership with hard to reach groups and those who experience barriers to
communication. There is also a need for the document to put more emphasis
on the potential benefits of inclusive communication both for service providers
and service users.
27. We would also suggest that the Scottish Government look to the
Communication Forum Scotland’s(CFS’s) ‘Principles of Inclusive
Communication’ in the development of its own principles. The CFS Principles
include:
-
Recognise that every community or group may include people with
communication support needs
Find out what support is required
Match the way you communicate to the way people understand
Respond sensitively to all the ways an individual uses to express themselves
Give people the opportunity to communicate to the best of their abilities
Keep trying
While similar to those put forward in the consultation document, we believe these
principles are clearer, more practical and more instructive than those developed by
the Scottish Government.
Thanks you for the opportunity to comment on this consultation.
Hanna McCulloch,
Senior Policy Advisor,
Capability Scotland
11 Ellersley Road,
Edinburgh
0131 347 1025
hanna.mcculloch@capability-scotland.org.uk
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