British Broadcasting
Corporation
Disability Equality
Scheme
1
Foreword by the Chairman of the BBC........................................................... 4
Foreword by the Director-General of the BBC ............................................... 6
Summary of the Disability Equality Scheme ................................................... 8
1 Introduction ............................................................................................ 16
1.1 The BBC ............................................................................................ 16
1.2 Review and Extension of the Disability Equality Scheme – 2010-11 .... 17
1.3 Application of the Disability Equality Scheme to Northern Ireland, the
Channel Islands and the Isle of Man ........................................................ 18
2 The Disability Equality Duty ..................................................................... 19
2.1 The Disability Discrimination Act 1995 (as amended) (DDA) ............... 19
3 The BBC’s Disability Equality Scheme ....................................................... 21
4 Key elements of the BBC’s Disability Equality Scheme .............................. 22
4.1 Involvement – a statement of how disabled people have been involved
in developing the Scheme ....................................................................... 22
4.2 Action plan ....................................................................................... 26
4.3 Performance monitoring – arrangements for gathering information
about the performance of the BBC on disability equality .......................... 28
4.4 Assessment – arrangements for assessing the impact of the activities of
the BBC on disability equality and improving these when necessary ......... 38
4.5 Formal review for 2010-11 ............................................................... 40
5 Implementing the Disability Equality Scheme ........................................... 41
6 Monitoring and evaluation ....................................................................... 42
6.1 Disability Equality Scheme Performance Summary 2009/2010 ........... 43
7 Feedback and update .............................................................................. 62
8 The BBC’s broader approach to promoting disability equality ................... 63
8.1 BBC Diversity Strategy ....................................................................... 63
9 Action Plan ............................................................................................. 73
Action Plan 1: TV licensing function ........................................................ 73
2
Action Plan 2: The BBC Trust in relation to certain functions under the BBC
Charter and Agreement (relating to involvement)..................................... 89
Action Plan 3: The BBC in relation to certain functions under the BBC
Agreement.............................................................................................. 96
Section (i): The BBC’s obligations in relation to digital switchover
(Agreement Clauses 34–41) .................................................................... 96
Action Plan 3: The BBC in relation to certain functions under the BBC
Agreement............................................................................................ 118
Section (ii): Other functions of the BBC in relation to certain functions under
the BBC Agreement (Agreement Clauses 12, 59–60, 74, 81) .................. 118
Annex ...................................................................................................... 122
The BBC’s public functions .................................................................... 122
3
Foreword by the Chairman of the BBC
Around one in five people living in the UK have some form of disability. This is
not a homogenous group, but a range of people with distinct and diverse needs
and views. The Trust’s commitment to BBC audiences is that the BBC should
offer value to everyone in the UK, whatever their background. This Disability
Equality Scheme is just one way in which the BBC contributes to enhancing the
lives and meeting the diverse needs and expectations of its disabled audiences.
The BBC published its first Disability Equality Scheme in December 2006. It was
revised in 2007 and now again in 2010. The scheme outlines the framework for
how the BBC will develop, implement, monitor and review its work towards
achieving equality for disabled people (and their carers) in relation to its relevant
public functions.
It is the BBC Trust’s responsibility to both assess and hold to account the BBC
Executive’s performance in delivering the BBC’s services and activities. This
includes the BBC’s performance in meeting all of its equalities duties. The Trust
is fully committed to the principles behind the equality scheme, which seek to
eliminate unlawful discrimination and promote equality and positive
relationships and takes its role of overseeing the BBC Executive in this area very
seriously. The Trust recognises that for the Equality Scheme to really make a
difference the focus needs to be on how the BBC changes as a result and in ways
which improve the lives of disabled people. The Trust will continue to work with
the BBC Executive on this.
The recent review of the Disability Equality Scheme gave the BBC as a whole the
opportunity to reflect on its performance in meeting its objectives and actions
over the last three years. Each of the BBC’s public function areas (e.g. Digital
Switchover, Television Licensing, regulatory functions of the BBC Trust and
miscellaneous collection of activity, including emergency and defence
announcements) captured in the scheme were required to review their objectives
and actions on the basis of progress, involvement with key stakeholders and
evidence gathered to date. In addition, the different public function areas were
asked to review the sections on implementation and monitoring progress,
capturing their performance and outcomes achieved during the past three years.
The Trust recognises that progress has been made in a number of areas across
the BBC. For example reaching the 100% target of subtitled content, including
the BBC’s iPlayer; exceeding the target across all network and Children’s
4
channels for both signed and audio-described content and both Television
Licensing and the Digital Switchover Help Scheme working closely with voluntary
sector organisations to ensure that their services are accessible and appropriate
for the wide range of licence fee payers different needs. However, based on
what people tell us we know that more could be done. The Trust will, therefore,
be monitoring those areas marked for improvement over the forthcoming year.
The Trust also welcomes all the other activity which the BBC Executive
undertakes to ensure that it is fulfilling its Charter responsibility to serve the
needs of all audiences. Through the annual reporting of the BBC Executive’s
Diversity Strategy we will make sure that this good work continues.
Following the enactment of the Equality Bill this year, the BBC will be working on
a Corporate Equality and Diversity Plan to replace this and its two other Equality
Schemes (Disability and Gender) in Spring 2011. The bringing together of the
new and existing equality strands into one accessible document will be an
important project for the BBC over the course of the year, and one which the
Trust will be closely involved in.
It is a huge challenge to meet the needs of all licence fee payers and the Trust
will work hard to engage with the diverse range of disabled people to assess
how well the BBC is serving them – a commitment which is reflected in the
Trust’s own set of objectives. The Trust is committed to extending the range of
tools it uses to listen to the public, so as to ensure that it reaches those who
may feel disconnected from the BBC.
As the Chairman of the BBC Trust I am personally committed to ensuring that we
get the best out of the BBC for all licence fee payers and will continue to
challenge the BBC Executive to ensure that it finds the best way to provide
distinctive services of the highest quality to all the people and all the
communities across the UK.
Sir Michael Lyons
5
Foreword by the Director-General of the BBC
I am delighted to join Sir Michael in introducing our Disability Equality Scheme,
which was recently reviewed and extended for the next 12 months while we
await new duties under future equality legislation.
The BBC is deeply committed to ensuring that diversity is embedded within every
aspect of what we do. Responding meaningfully to our responsibilities under
the Disability Equality Duty is one part of Diversity Strategy, and our Disability
Equality Scheme sets out our commitments across those of our public services
which are subject to the duty.
I am extremely proud of what we have achieved over the last three years, both in
relation to the Disability Equality Duty and our broader commitment to diversity.
We have consistently exceeded our targets for providing access to our services
through subtitling, audio description and BSL interpretation and we have been
subtitling 100% of our programmes across our services since 2008.
Our portrayal of disabled people’s lives has been commended though awards
from Ability Media International, Mind Mental Health Media, RADAR and the
Cultural Diversity Network. Our work off-screen and off-air was also recognised
by Personnel Today’s Diversity Award for our Extend programme, which offers
disabled people six-month paid work placements in the BBC.
Making sure that no one is left behind in the switch to digital television is a
critical responsibility for us, and developing measures to ensure that those
delivering services on our behalf do so in an inclusive and non-discriminatory
way has also been a key feature. Challenges for this year include maintaining
high quality services to users of the Switchover Help Scheme and anyone
arranging their licence fee, and building in accessibility from the start when
developing new technology.
Last year we undertook a major piece of audience research in partnership with
Channel 4, Talking Disability, where we heard directly from disabled people on
what they thought about access to our content, as well as the content itself.
Their insights have led to improvements including greater accessibility to our
programmes on the BBC iPlayer, and EastEnders’ first regular adult character
with a visible disability to be played by a disabled actor, David Proud.
6
There is more to do of course; our audiences and the BBC Trust have high
expectations of us and rightly so. Diversity should be an integral part of how we
operate precisely because of how we are funded. We look forward to preparing
our Corporate Equality and Diversity Plan, based on our Diversity Strategy and
informed by our diverse audiences, which we will publish in April 2011.
In the meantime my directors and I will remain vigilant about our progress on
disability equality through the BBC Diversity Board, which I chair.
Mark Thompson
7
Summary of the Disability Equality Scheme
Review and Extension for 2010-11
The BBC was due to review in full its Disability Equality Scheme and, in advance
of the Equality Bill, develop a Corporate Equality and Diversity Plan to replace all
three of its equality schemes. However, keen to understand fully any new duties,
the BBC has decided to wait for the new legislation to pass before setting a new
three year plan.
This document represents a reviewed Disability Equality Scheme which has been
extended for 12 months. This process has involved reviewing each of the
objectives and actions on the basis of progress, evidence gathered to date,
involvement and consultation. It also contains progress reporting for the third
year of the DES and an update of the substantive document.
The BBC will develop a single plan on the breadth of its equality and diversity
commitments and activity. A Corporate Equality and Diversity Plan will be
developed to respond to the new equality duty, ready by 1 April 2011 (these
timings are based on the proposed legislative timetable which is yet to be
finalised by government). This plan will enable the organisation to
communicate how it is:

Meeting new legal requirements in the shape of a new equality duty

Keeping diverse audiences at the heart of everything the BBC does

Presenting a positive and coherent picture of the complete range of our
equality and diversity activity
Overview of TV Licensing
‘TV Licensing’ is a trade mark of the BBC and is used under licence by companies
contracted by the BBC to administer the collection of television licence fees and
enforcement of the television licensing system.
Outcomes from the BBC’s involvement of disabled people in the development of
the Disability Equality Scheme heavily informed TVL’s commitments to
promoting disability equality in its activities.
As a result, a comprehensive Action Plan has been established to ensure that
disabled people experience and receive appropriate and accessible TVL
information, advice and targeted support services.
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TV Licensing objectives
1 To communicate with disabled people, wherever practicable, in a way that is
accessible and appropriate to facilitate a clear understanding of television
licensing obligations.
2 To ensure that all BBC TVL staff and contractors fully understand their duty to
promote disability equality and are active in implementing actions identified.
3 To continually review and, wherever possible, improve or develop service
supports (including technology) to provide maximum access to support and
advice services for all disabled people.
4 To develop and maintain a strategic and systematic approach to integrating
disability equality into all TVL activities.
5 To maximise the potential for data and information management systems to
enhance and promote disability equality.
6 To develop and maintain strategic leadership and commitment to the broad
implementation of the Disability Equality Scheme and the TVL Action Plan.
7 To ensure that all payment methods and processes are accessible and
appropriate for a range of needs.
8 To ensure a strategic approach to integrating disability equality into all TVL
procurement activities.
Supporting each of these objectives is a list of specific actions. Examples of
some of these are:

Conducting equality impact assessments on relevant communications and
policies which are being developed or reviewed.

Continuing to make communications representative and available in a range
of styles, formats and languages.

Partnership working with organisations which represent and are run by
disabled people to inform TVL activities.

Continuing to impose contractual obligations on contractors to comply with
legal obligations including the Disability Equality Duty and this Scheme and
monitoring their compliance.
9
Overview of the BBC Trust
The BBC Trust is the governing body of the BBC. The Trust is here to make sure
the public who own and pay for the BBC get the best out of the BBC. The Trust
sets the strategy for the BBC and holds the Executive to account. The Trust’s
work includes deciding whether or not to allow the BBC to launch a new service
or significantly change an existing one; reviewing the performance of the BBC’s
services and setting the BBC’s complaints framework. When carrying out these
activities the Trust takes into account the views and needs of audience groups in
their full diversity. The Trust does this by commissioning new and reviewing
existing audience research, carrying out consultations, drawing on the work and
insight of the Audience Councils and holding public and stakeholder meetings.
Preparing for this revised version of the Disability Equality scheme involved a
combination of monitoring the information collected, reviewing and assessing
performance and evidence gathered over the last three years and internal and
external stakeholder involvement.
The following set of objectives and actions
have been developed based on the insight this activity has provided.
BBC Trust objectives
Objective 1
We will operate in a way that means that anyone can have their say and
contribute to our work. Our processes will be accessible and we will tackle the
barriers for audiences wanting to engage with us.
Objective 2
We will be proactive in reaching audiences, including minorities and the seldom
heard..
Objective 3
In our work we will carefully consider the full range of contributions and
evidence so that our decisions are fair, independent and impartial and do not
discriminate against any audience groups. To further this we will take action to
address key issues that have emerged, so that, where appropriate and
necessary, we and the BBC Executive deliver change in the interests of all
audiences.
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Objective 4
We will share our findings and conclusions in a way which is accessible, open
and transparent.
Supporting each of these objectives is a list of specific actions. Examples of
some of these are:

Where possible use alternative and more tailored methods for reaching those
disabled people who do not routinely participate or are unable to participate
in our online consultations

An Equality Impact Assessment will be conducted prior to us commencing
any new policy/project/review which is carried out as part of a public
function.

Ensure that our website meets the statutory and BBC's accessibility
requirements and that all published public documents are screen reader
accessible.

When handling appeals the Complaints Manager will identify and provide the
necessary advice and support required for those persons who are unable to
submit their appeal in writing and/or who may lack literacy skills or the
confidence to submit their appeal through the usual channel
The BBC Agreement
In addition to the Royal Charter, the BBC has entered into a Framework
Agreement with the Secretary of State for Culture, Media and Sport. This
Agreement deals with a number of the BBC’s public functions, including:
1 Digital switchover, including the Digital Switchover Help Scheme, and
2 Some others – in particular, access to UK public services
Overview of digital switchover, including the Digital Switchover Help Scheme
(i)
In September 2005, the Government announced that digital switchover
(changing the television broadcasting network to digital) would take place
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between 2008 and 2012. The television broadcasting network is changing to
digital-only, and the public will have to convert or upgrade their TV and
recording equipment to receive digital television. Digital UK is the independent,
non-profit organisation set up at the request of the Government to manage all
communications with the public regarding digital switchover. Digital UK provides
impartial information on what people need to do to prepare for the move to
digital television. Digital UK is owned by the UK’s public service broadcasters
and the transmission companies SDN and National Grid Wireless.
The BBC and Digital UK are fully committed to involving disabled people in
making sure that the communication needs of disabled people are listened to
and properly considered in the planning, implementation and review of digital
switchover rollout. The BBC and Digital UK have worked together to develop this
Disability Equality Scheme, informed by the BBC’s involvement of disabled
people, and over the last three years have put into place systematic processes
for assessing the communications and information needs of diverse
communities and for monitoring progress in meeting those needs.
To help ensure that everyone can switch more easily to digital TV, the BBC will
manage a help scheme for people who need it, most focused on providing
practical assistance and support for people aged 75 years and over, people who
receive Disability Living Allowance, Attendance Allowance and other qualifying
benefits, and people who are registered as blind or partially sighted. Involving
disabled people is a key principle which has underpinned the development and
delivery of the Help Scheme. The BBC has set up a subsidiary, Digital Switchover
Help Scheme Ltd (DSHS Ltd), to deliver this function.
BBC objectives relating to the Digital Switchover Help Scheme
1 To ensure that the Help Scheme engages all eligible people in need of
assistance, and supports them through their customer journey.
2 To ensure that all Help Scheme public information is appropriate, sensitive,
and accessible for disabled people and people with learning disabilities.
3 To involve and consult with eligible people and their representative bodies
including older people, and those with disabilities and learning disabilities in
the delivery and development of the Help Scheme.
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4 To gather and use information effectively in order to monitor and assess the
impact of current and planned operational processes, policies, and practices
on older people, and those with disabilities and learning disabilities.
5 To ensure effective internal monitoring and evaluation of the Help Scheme
DES outcomes.
6 To ensure that DSHS providers are promoting disability equality , through their
responsibilities under contract.
7 To ensure that the Help Scheme is feeding into, and learning from best
practice.
Supporting each of these objectives is a list of specific actions. Examples of
some of these are:

Providing accessible information

Involving people using the Help Scheme to inform the development delivery
of the help Scheme

Monitoring the performance of contractors against their duties to promote
gender equality

Conducting Equality Impact Assessments to inform operational processes,
policies or practices
BBC objectives relating to Digital UK activity
1 To assist the “most vulnerable beneficiaries” (older and disabled people) to
make the switchover to digital TV.
2 To ensure that the transition to digital-only broadcasting is a fully inclusive
process.
3 To ensure that all digital switchover and help scheme related information and
modes of communication are appropriate for target audience and are fully
accessible.
4 To involve disabled people in the planning and rollout of digital switchover
and in the planning and rollout of the help scheme.
5 To gather and use information effectively in order to monitor and assess the
impact of current and planned digital switchover policies and practices with
regard to disability equality.
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6 To ensure effective internal monitoring and Disability Equality Scheme
outcomes evaluation.
Supporting each of these objectives is a list of specific actions. Examples of
some of these are:

Providing accessible information

Regularly tracking levels of awareness and understanding of the switch to
digital on the basis of disability and taking any action to address any
significant differentials between disabled people and non-disabled people

Undertaking research to further understand differentials in understanding
and behaviour between different groups, including disabled people

Working with voluntary and community sector organisations

Evaluating experience of the switch to digital region by region to inform
future communications
Overview of other BBC public functions (ii)
Under the terms of the Agreement, the BBC must meet a series of access
commitments relating to the provision of all UK public services and ensure that
important public, security and defence announcements, as well as public
documents such as the Annual Report, are accessible to all disabled people.
Various key departments across the BBC contribute to meeting these
commitments. As public functions of the BBC, these are now clearly documented
within this Scheme in respect of their relevance to the Disability Equality Duty.
Systematic processes for assessing and monitoring current or future access as
effective and appropriate for disabled people have been in place for the last
three years, and will continue during 2010-11.
Other BBC public functions (under the BBC Agreement) – objectives
1 To anticipate and wherever practicable meet the diverse needs of disabled
people who access or seek to access UK public services.
2 To anticipate and meet communication needs of those with sensory
impairments in order to ensure their access to UK services and to related
information and consultation activities (as required by Ofcom’s code).
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3 To ensure that specific financial information is fully accessible, through
meeting the various communication needs of all disabled people.
4 To ensure that all disabled people have equal access to specific public
information announcements.
Supporting each of these objectives is a list of specific actions. Examples of
some of these are:

Involving disabled people in monitoring the effectiveness of access services.

Ensuring that the Annual Report and Accounts are accessible to all disabled
people.
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1 Introduction
1.1 The BBC
The British Broadcasting Corporation (BBC) is established as a corporation by
Royal Charter. The first Royal Charter was granted on 20 December 1926 and
the BBC has subsequently been continued by further Royal Charters, the most
recent of which was granted on 19 September 2006. This continues the
Corporation for a period of 10 years from 1 January 2007.
The Royal Charter essentially defines the powers of the BBC and its
constitutional arrangements, and states that the BBC is to be independent in all
matters concerning the content of its output, the times and manner in which this
is supplied, and in the management of its affairs.
In addition to the Royal Charter, the BBC has entered into a Framework
Agreement with the Secretary of State for Culture, Media and Sport. This
Agreement deals with a number of important matters, including the following:

A statement of the services which the BBC is to provide at the
commencement date of the Charter

The process which is to be followed for subsequent additions or changes to
the BBC’s public services, including the use of the Public Value Test under
which the public value of the BBC’s services is to be compared with any
potential market impact which a new or varied service may have

The obligations on the BBC in relation to the achievement of digital
switchover, including managing delivery of the Digital Switchover Help
Scheme

The regulatory obligations which apply to the BBC UK public services

The arrangements relating to the provision of the World Service

Fair trading and competitive impact provisions

The BBC’s commercial services

Complaints

The BBC’s relationship with Ofcom

A number of other miscellaneous and general matters
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The BBC is mainly funded by the television licence fee, the collection of which by
the BBC is authorised by section 365 of the Communications Act 2003. After
collection the BBC is obliged to pay the sums received to the Government. Under
the terms of the BBC Agreement, sums equal to the amounts collected by the
BBC are paid to the BBC, after deduction of the Government’s administration
costs. The World Service is funded separately by the provision of grant-in-aid
from the Foreign & Commonwealth Office. There are also separate divisions and
companies which operate at arm’s length from the BBC. These carry out a
number of commercial activities (for example, the sale of magazines, books,
DVDs and CDs). The profits arising from these activities are returned to the BBC
and used in support of licence fee-funded services.
1.2 Review and Extension of the Disability Equality Scheme – 2010-11
The BBC first developed this Scheme in 2007 and was due to undertake a threeyear review of the Disability Equality Scheme during 2009-10. The BBC had
committed to develop a single plan which would replace its three equality
schemes (including the Disability Equality Scheme) and respond to any new
responsibilities under the new public sector equality duty set out in the Equality
Bill. However, the BBC decided to review its existing equality schemes (including
the Disability Equality Scheme) and extend each one for a period of 12 months –
the point at which it is expected that the new public sector equality duty will
come into force. The BBC is keen to understand in full its duties under the new
legislation, particularly as it understands its responsibilities will change and that
the new duty will apply to more of its activities. This document represents a
Disability Equality Scheme document which has been reviewed and extended for
12 months. This process has involved reviewing each of the objectives and
actions on the basis of progress, evidence gathered to date, involvement and
consultation. It also contains progress reporting for the third year of the DES and
an update of the substantive document.
The BBC will develop a single plan on the breadth of its equality and diversity
commitments and activity. This Corporate Equality and Diversity Plan will be
developed to respond to the new equality duty, to be published by 1 April 2011.
This plan will enable the organisation to communicate more effectively how it is:

Meeting new legal requirements in the shape of a new equality duty

Keeping diverse audiences, including disabled people, at the heart of
everything the BBC does

Presenting a positive and coherent picture of the complete range of the BBC’s
equality and diversity activity
17
The BBC has reported annually against this Scheme during the last three years.
Summaries of performance during years 1 and 2 of the equality schemes
including the Disability Equality Scheme can be found at
http://www.bbc.co.uk/aboutthebbc/policies/diversity.shtml A summary of
performance in year 3 is contained later in this document in section 6.
1.3 Application of the Disability Equality Scheme to Northern Ireland, the
Channel Islands and the Isle of Man
The equality duties do not legally apply where the BBC is exercising public
functions outside Great Britain. However, it has been determined that, so far as
is practicable, the BBC will apply standards which are substantially similar to the
equality duties when exercising its public functions across the United Kingdom,
in the Channel Islands and in the Isle of Man.
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2 The Disability Equality Duty
2.1 The Disability Discrimination Act 1995 (as amended) (DDA)
The DDA was amended in 2005 so as to require public authorities to fulfil a
Disability Equality Duty. This duty encompasses requirements:

To promote equality of opportunity between disabled persons and other
persons

To eliminate discrimination that is unlawful under the Act

To eliminate harassment of disabled persons that is related to their
disabilities

To promote positive attitudes towards disabled persons

To encourage participation by disabled persons in public life

To take steps to take account of disabled persons’ disabilities, even where
that involves treating disabled persons more favourably than other persons
The Disability Equality Duty applies to the BBC “in respect of its public
functions”. This means that not all functions of the BBC are subject to the
requirement to fulfil the Disability Equality Duty.
The BBC believes that the correct approach to defining its public functions is to
look at the nature of the function involved rather than the nature of the body
carrying out the function or the nature of its funding. For this reason, regulatory
functions are likely to be public functions, whereas the BBC’s output-related
activities (for example newsgathering and programme-making) are not.
The application of general principles of this type to specific situations involves
detailed analysis which it would not be appropriate to set out in this document.
However, the result of the analysis that has been carried out – that is, a
definition of those functions of the BBC which are considered to be public
functions – is set out in the Annex to this Scheme.
Section 3 of this Scheme sets out what the BBC intends to do in order to fulfil the
Disability Equality Duty in respect of each of these functions.
Section 8 sets out the BBC’s broader approach to promoting disability equality,
in the wider context of the BBC’s Diversity Strategy. Various specific actions and
targeted initiatives are detailed, as well as examples of more long-standing and
19
routine good practice across the BBC. Although these are not requirements
under the Disability Equality Duty, they demonstrate the BBC’s positive and
inclusive approach towards disabled people as employees, audiences and TV
licence fee payers, as well as its clear intention to fully meet additional specific
duties relating to equal opportunities which are placed on it by the BBC Charter
and Agreement (ref. Charter Article 44 (1) (a) and (b) and (2) (b), and Agreement
Clause 83).
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3 The BBC’s Disability Equality Scheme
The BBC’s Disability Equality Scheme forms a part of the BBC’s overall
commitment to equality and diversity. The Scheme outlines a framework for how
the BBC will develop, implement, monitor and review its work towards achieving
equality for disabled people (and their carers) in relation to its relevant public
functions. The Scheme is a tool to help promote disability equality at the centre
of the BBC’s work and specifically across relevant areas such as TV licensing,
digital switchover and the BBC Trust’s operations.
The Disability Equality Scheme aims to build on a strong foundation of existing
good practice and expertise. The BBC has always sought to address any
identified gaps and barriers to delivering fair, accessible and appropriate
services. It has also sought to protect the rights of disabled people both at work
and in the wider community and to engage with them in order to understand
their concerns and meet their needs wherever possible. This Scheme, therefore,
aims not only to ensure full compliance with the general duty (with regard to the
BBC’s public functions), but also to provide some information relating to the
BBC’s previous and current efforts to ensure equality of opportunity and access
for disabled people.
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4 Key elements of the BBC’s Disability Equality Scheme
The Equality and Human Rights Commission has set out five key elements or
principles on which the Disability Equality Scheme should be based. Under each
element there is a list of ways by which the BBC will work to deliver its
commitment to disability equality. The five key elements are:
4.1 Involvement
4.2 Action plan
4.3 Performance monitoring
4.4 Assessment
4.5 Review
4.1 Involvement – a statement of how disabled people have been involved in
developing the Scheme
All Disability Equality Schemes are required to be updated in the light of
experience and ongoing involvement with disabled stakeholders, and this has
been the case in relation to the BBC’s Scheme. The BBC committed to continually
reviewing and developing its Scheme so as to maximise its relevance to the
delivery of real benefits for disabled people in relation to the performance of the
BBC’s public functions.
The first draft of this Scheme was developed during the autumn of 2006, against
a constitutional background which was being clarified and finalised at the same
time. This Scheme was then reviewed in 2007 and again in full 2008 which led to
the Trust amending their objectives and associated actions. This process was
repeated during 2009-10 in order to extend this Scheme for one year. Both the
Trust and Digital Switchover Help Scheme have redesigned their objectives in
this Scheme based on involvement and consultation activity and other relevant
information.
4.1.1 Previous and recent involvement of disabled people
The BBC had previously involved and consulted disabled people in a number of
ways with regard to the performance of the public functions which are now
covered by the Scheme. These initiatives are listed below:

BBC Trust

Charter review consultation

TV Licensing
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
Digital switchover, Digital Switchover Help Scheme and Digital UK

Consulting disabled BBC staff
(See also section 4.3 for details of the BBC’s involvement and informationgathering activities.) The outcomes of this previous involvement and
consultation, and very recent involvement and consultation about the Help
Scheme, have informed the Scheme and in particular the Action Plan.
4.1.2 Disabled people’s involvement with the development of the Disability
Equality Scheme
When this Scheme was reviewed in February 2007, it was informed by the
outcomes of planned involvement activity, which the BBC undertook with
Churchill, Minty and Friend, with disabled people, carried out as part of the
Scheme’s initial development. The activity was conducted through
questionnaires and focus group meetings during the course of November 2006
and was launched following the final settlement of the BBC’s new constitutional
arrangements by means of the grant of the new BBC Charter. The outcomes of
this planned involvement activity were considered by relevant sections of the
BBC and informed the Action Plan developed as part of this Scheme. Details of
the involvement activity and the headline findings are reported in a previous
version of the Disability Equality Scheme (2008) and reflected within the Action
Plan as appropriate which you can find at:
http://www.bbc.co.uk/aboutthebbc/policies/diversity.shtml.
During the life of this Scheme, each of the areas within the BBC responsible for
its public functions has conducted involvement and consultation activity directly,
which has informed regular reviews of this Scheme, in particular the Action Plan.
Every year the Digital Switchover Help Scheme involves people who are eligible
to use the service, including older and disabled people, in order to ensure that
its users shape its development. The 2007 annual consultation informed the
review of this Scheme in 2008. That consultation process involved almost 150
disabled and older people and over 30 disability organisations. The aim of the
consultation was to obtain as much information as possible to ensure that the
Help Scheme was fully accessible to, and inclusive of, disabled people. Care was
taken to ensure that the organisations identified for interviews and the
participants in focus groups were a diverse group representing a range of lived
experience in terms of impairments, gender including trans people, ethnicity,
language, geographical location, and literacy skills. The findings from the
consultation led to a series of improvements to the Help Scheme, including:
23

Development of a Code of Service Standards, designing out potential
disability discrimination, and available to every service user informing them
of what they can expect through the service. That code now forms part of the
contract the service provider, eaga plc, and is a specific requirement of the
Help Scheme Agreement (the legal document outlining the BBC’s obligations
for delivering the scheme

Greater awareness of disability equality among staff developing the Help
Scheme

Greater awareness of disability equality among call centre staff and
equipment installers

Increased accessibility to the scheme though more accessible marketing
materials with additional features such as audio description, BSL
interpretation and subtitles, the need for ability to pay any charges in
instalments.
In 2009, the annual consultation centred on the extent to which people for
whom the scheme is designed, are using the service in order to increase their
understanding about users and potential users of the Help Scheme. The
consultation involved:

local community organisations in the geographical regions which had most
recently switched to digital

14 discussion groups and 38 in-depth interviews with people who were
eligible to use the Help Scheme

Observations of the delivery of the Help Scheme at the frontline both in callcentres and during installations of equipment in people’s homes
This consultation has assisted Digital Switchover Help Scheme to understand in
more detail the range of people’s experiences in making the switch to digital, in
particular, those people who found it difficult to make the switch and didn’t use
the Help Scheme. Further exploration of this particular group pointed to possible
explanatory factors including overly complex information about the Help Scheme
and a lack of awareness of the service among people who are most excluded.
However, it also pointed to barriers to using the Help Scheme highlighting
accessibility issues particularly for deaf, hearing impaired, blind and visually
impaired people. This consultation has informed the review of this Scheme for
24
2010-11 and the issues highlighted will be an area of focus for the next 12
months.
For further information on the Help Scheme, see section 4.3.3.
As part of this review of the Disability Equality Scheme (2010) the Trust
commissioned a research agency to carry out an involvement exercise with a
number of organisations representing disabled people and carers. The main
objectives of the research were to assess the current BBC Trust objectives and
actions within each of the three equality schemes and to identify any gaps in the
existing objectives. The research was originally designed to involve a series of
in-depth interviews and an ongoing online portal. However, in practice
participation in the online portal was, unfortunately, extremely low and as a
result more resources were spent on the in-depth interviews. Quotas were set to
ensure an appropriate spread of organisations were included in the total number
of in-depth interviews (this was primarily based on gaps in the BBC Trust’s
existing research amongst these three equality strands, including disability). To
ensure that every opportunity was given to the organisations they were offered a
choice of phone or face-to-face interview. 30 in-depth interviews with
stakeholder organisations, including disability related organisations were
conducted over a four week period with each interview lasting an average of 4560 minutes. The key findings from the research included:

There was low awareness of the BBC Trust and its activities, amongst all
organisations - not just those representing seldom heard audiences
making it hard for these groups to get involved in any decision making.

Currently engagement by the BBC Trust is seen to be a series of ad hoc
activities rather than based on a desire to foster ongoing relationships.
Therefore there was the recommendation that with the help of third
parties the Trust should build long term, ongoing relationships with
seldom heard groups using specific, tailored communications channels.

The BBC Trust was perceived to rely too much on the internet and there
was a call for it to engage less online and more face-to-face, especially
with regard to consultations and the complaints procedure.
25

Again with the help of third parties engage with the smaller minorities
(those that aren't already well catered for in the schemes) and build a long
term involvement strategy with them.

The BBC Trust needs to demonstrate that the involvement of harder to
reach or seldom heard groups has an impact on how the Trust operates.
For example having targets and benchmarks set and for the performance
to be monitored, published and publicised.
For further information on the Trust, see section 4.3.2.
4.2 Action plan
The BBC Action Plan in respect of its public functions consists of three main
sections. These are television licensing functions, certain functions of the BBC
Trust and certain functions of the BBC under the BBC Agreement, including
digital switchover and the Help Scheme.
4.2.1 Action planning and review
The Action Plan has been reviewed and updated in 2009-10 by each of the
management teams responsible for each set of public functions, based on the
outcomes of involvement and consultation with disabled people and staff, on the
outcomes of disability equality impact assessments and other relevant
information. The key areas that emerged, which were found to be of most
importance or concern to disabled people, varied depending on the public
function under discussion (see 4.1 above for more detail). The Action Plan sets
out the steps which the BBC intends to take during this extended year for this
Scheme (2010-11) to address these key areas and work towards ensuring
disability equality in relation to its public functions (see section 9, Action Plan).
The BBC will continue to consult with and involve disabled people in order to
monitor its operation and assess the impact of actions implemented. Feedback
will inform the annual review process and help the BBC to update or set new
actions to meet its disability equality objectives over the Scheme’s three-year
period. (Details of the way in which disabled people will be involved are set out
in section 4.4.) The BBC will review and, if necessary, update and amend the
manner of involvement based on an evaluation of how successful these
processes have been.
The Disability Equality Scheme has run for three years and is now extended for
12 months up to 31 April 2011 when the new public sector equality duty is
26
expected to come into force. Performance has been reported annually against
this Scheme and the Action Plan in particular has been regularly updated and
undergone two formal reviews in that time. During 2010-11, the BBC will
prepare a Corporate Equality and Diversity Plan to respond to its new duties
currently set out in the Equality Bill. An extensive involvement and consultation
process will be developed over the next 12 months to inform the BBC’s
Corporate Equality and Diversity Plan which will replace the equality schemes,
including the Disability Equality Scheme and form the BBC’s response to the new
single public sector equality duty, expected in the new Equality Bill once
enacted.
4.2.2 Ownership and implementation
The BBC Trust is responsible for overview and scrutiny of the Disability Equality
Scheme (DES). The three-part Action Plan embedded within the Scheme is the
responsibility of the Director-General and other members of the BBC Executive
Board within the BBC divisions, and of the BBC Trust Unit. The pan-BBC Diversity
Centre is responsible for liaising with relevant divisions, disseminating best
practice and providing guidance, and monitoring progress of the Disability
Equality Scheme Action Plan at a corporate level.
Each relevant divisional director is responsible for implementing the DES and the
specific local actions which have been identified as a result of consultation and
equality impact assessments at divisional level. These will be monitored within
each division and progress will be reported at the Diversity Board and Executive
Board. Implementation of the DES is scrutinised by the BBC Trust.
4.2.3 Structure and content
The Action Plan is divided into the three public function areas of the BBC’s
activity:

Television licensing functions

Certain functions of the BBC Trust

Certain functions of the BBC under the BBC Agreement, for example digital
switchover including the BBC’s responsibility for delivery of the Digital
Switchover Help Scheme
Within each section, key objectives have been set which aim to achieve the
positive outcomes that disabled people and their carers have identified as most
important to achieving disability equality. Specific actions support one or more
of the Scheme’s key objectives, which are all underpinned by core BBC values
27
relating to diversity. Actions have been informed directly by disabled people or
arise out of recommendations made following a range of engagement and
consultation initiatives plus various initial reviews of current activities.
Background information on each of the relevant function areas and examples of
how the BBC carries out, or intends to carry out, each of the public functions
covered by the Scheme has been provided as part of the introduction to each
section of the Action Plan.
4.3 Performance monitoring – arrangements for gathering information about
the performance of the BBC on disability equality
This section provides examples of how the BBC gathers information on its own
performance through examining its current activities and processes and by
investigating the specific needs and barriers to access which may be identified
through the outcomes of involvement with disabled people and other relevant
research.
Information and evidence gathered is used to:

Inform Disability Equality Scheme review processes and any additional work
areas which fall outside its scope.

Benchmark against other broadcast industry providers and allow for broad
comparison against a range of other public bodies where appropriate.

Systematically identify barriers and gaps which may impact negatively on
disabled people.

Understand and wherever possible respond appropriately to diverse and
constantly changing needs.

Examine and assess outcomes.

Inform future planning processes target setting, where appropriate. (The
majority of the administration of TV Licensing is contracted to Capita
Business Services Ltd (which undertakes the majority of the TV licensing
system), with the administration of cash-related payment schemes
contracted to Revenue Management Services Ltd (RMS). PayPoint Collections
Limited is contracted to provide over-the-counter services. Marketing and
printing services are contracted to Proximity London Ltd as are public
relations and advertising services. The latter are subcontracted by Proximity
to Fishburn Hedges Boys Williams Ltd, Abbott Mead Vickers BBDO Ltd and
PHD Media Ltd.)
28
Previous and current information gathering
4.3.1 TV Licensing
‘TV Licensing’ is a trade mark of the BBC and is used under licence by companies
contracted by the BBC to administer the collection of television licence fees and
enforcement of the television licensing system. (The BBC is a public authority in
respect of its television licensing functions and retains overall responsibility. 21)
Regular and targeted involvement
The BBC and TV Licensing (TVL) have been working with a number of key
stakeholders to both gather and share information. In particular there is a
regular dialogue with the Royal National Institute for the Blind (RNIB), Royal
National Institute for Deaf People (RNID), Mencap, Age Concern, Help the Aged
and Citizens Advice. (All liaise with organisations which represent disabled
people.)
Information is gathered and planned changes in TVL processes are discussed so
that the views and needs of disabled people help to shape developments. These
processes have led to the following initiatives, for example:
Actions

A revised, improved TV Licensing website went live in October 2009. The
new website included an upgrade to the online purchase facility whereby
customers could view all of their licence details online.

Following October 2009 the TVL website was subjected to a further usability
assessment in which disabled people took part. This looked at whether
disabled people found the website satisfactorily accessible and found no
issues.

TVL continued to develop stakeholder relationships with key disability
advocacy organisations including the RNIB and Mencap.
4.3.2 The BBC Trust
The BBC Trust is committed to monitoring the diversity of the participants, which
includes disabled people and carers, of its public meetings, its audience
research and online consultations. It is an action set by the Trust within this
Disability Equality Scheme and assists the Trust to meet the objectives:
29
1. We will operate in a way that means that anyone can have their say and
contribute to our work. Our processes will be accessible and we will
tackle/minimise the barriers for audiences wanting to engage with us
2. We will be proactive in reaching minority and seldom heard audiences
This monitoring information is held and regularly reviewed by the Trust’s
Diversity Advisor and the department’s Equalities Working Group. It is used to
inform the Trust where efforts need to be made to achieve a more representative
participation of licence fee payers, including disabled people.
When arranging any public meeting/event the Trust ensures that the venue and
location are accessible and that if required sign language interpreters and any
other dedicated service are provided. Unfortunately only a third of the people at
these events complete the Trust’s diversity monitoring form, so the data we have
is not a true reflection of the people who take part. This is also true of the
monitoring data we receive from our online consultations. Out of the responses
we do get between 4-9% declare they have a disability. The Trust is very mindful
that some engagement tools might not be appropriate or easily accessible to
some groups, therefore it has worked hard to use alternative methods such as
leaflets, on-air trails or discussions, targeted correspondence, stakeholder
events and visiting shopping centres to try and ensure that it reaches as wide a
range of people as possible.
In addition the Trust carries out Equality Impact Assessments on all
projects/policies of a public nature. The requirement to conduct an Equality
Impact Assessment is now embedded in a number of key Trust documents so as
to ensure that they are started at the very outset of a project.
As part of the review of the Disability Equality Scheme the Trust commissioned a
research agency to carry out an involvement exercise with a number of
organisations representing disabled people and carers. The main objectives of
the research were to assess the current BBC Trust objectives and actions within
each of the three equality schemes and to identify any gaps in the existing
objectives. The research was originally designed to involve a series of in-depth
interviews and an ongoing online portal. However, in practice participation in the
online portal was, unfortunately, extremely low and as a result more resources
were spent on the in-depth interviews.
30
In the initial engagement stage, a total of 169 organisations across all three
equality strands were contacted by both phone and email to brief them on the
project and ascertain their willingness to participate. Of those who responded,
some refused to participate, citing time and work pressures or a feeling they did
not know enough about the subject matter to comment meaningfully. Quotas
were set to ensure an appropriate spread of organisations were included in the
total number of in-depth interviews (this was primarily based on gaps in the BBC
Trust’s existing research relating to disability, race and gender).
To ensure that every opportunity was given to the organisations they were
offered a choice of phone or face-to-face interview. 30 depth interviews with
disability, gender and race related organisations were conducted over a four
week period with each interview lasting an average of 45-60 minutes. The key
findings from the research are summarised as follows:

There was low awareness of the BBC Trust and its activities, amongst all
organisations - not just those representing seldom heard audiences making
it hard for these groups to get involved in any decision making.

Currently engagement by the BBC Trust is seen to be a series of ad hoc
activities rather than based on a desire to foster ongoing relationships.
Therefore there was the recommendation that with the help of third parties
the Trust should build long term, ongoing relationships with seldom heard
groups using specific, tailored communications channels.

The BBC Trust was perceived to rely too much on the internet and there was a
call for it to engage less online and more face-to-face, especially with regard
to consultations and the complaints procedure.

Again with the help of third parties engage with other more seldom heard
groups (including those that aren't already well catered for in the schemes)
and build a long term involvement strategy with them.

The BBC Trust needs to demonstrate that the involvement of seldom heard
groups has an impact on how the Trust operates. For example having targets
and benchmarks set and for the performance to be monitored, published and
publicised.
As well as the Trust monitoring its own performance, it is also responsible for
assessing the performance of the Executive Board in delivering the BBC’s
31
services and activities and holding the Executive Board to account for its
performance. The Trust does this using its regulatory tools, which include
service licence reviews and public value tests. Both of these tools have enabled
the Trust to assess the impact the existing or new service has on disabled
people, for example:
Licence Fee Collection review
In 2008 the Trust ran a wholesale review of the BBC Executive’s arrangements to
collect the licence fee. The research which informed the review incorporated
qualitative research with disabled people (which included visually impaired
people, deaf/hard of hearing people, those with mobility problems, people with
learning difficulties, those with mental health issues and those associated with
care homes for older people). The results of the research indicated that TV
Licensing may need to address a better consideration of the needs of some
including disabled people and this could be done by:

providing information in a very simple format for those who have poor
literacy skills or understanding of English

doing more to publicise services for disabled people, including the Minicom
service for deaf people and the availability of correspondence in Braille for
blind people

ensuring that enforcement visits are not aggressive in the first instance and
that people who need help in understanding their situation (e.g. those with
learning difficulties or rudimentary English) are assisted in getting this
support before the enforcement process progresses too far.
As a result of these recommendations the BBC Executive have began work on
addressing the issues the report raised with a set of timetabled actions in place.
BBC’s Complaints Framework
As a result of the Trust’s Complaints Framework Consultation which took place
between October 2007 and January 2008, there have been changes to the BBC’s
complaints framework. For example, the language has been amended in the
procedures document so that it is clear and consistent (for instance, using the
same wording throughout the document and ensuring that timelines are referred
to in a consistent manner). The changes also aim to ensure that the complaints
process is accessible by offering alternative methods for contacting the BBC
instead of only by written correspondence at appeal stage. The document itself
32
has been made more accessible by removing footnotes and inserting them into
the body of the text where appropriate.
The Trust is currently running a project over the next year to test the
effectiveness of the BBC Executive’s complaints processes, following these
changes. Equality and diversity have been key to the Trust’s thinking and we are
finding ways to investigate whether who you are or what you complain about
affects what happens in any way.
In addition we will be working with the BBC Executive to try and develop the way
the BBC collects diversity information from those people who contact the BBC,
including complainants.
Editorial Guidelines review
As part of the comprehensive research for the Trust’s editorial guidelines review
it commissioned eight ad-hoc ethnographic sessions. (These are informal
sessions with friends, which take place in environments such as someone’s
home, a community centre, a church meeting room etc). The purpose of these
sessions were to allow the Trust to capture the perspective of people whose
views might not otherwise be heard and whose views might differ from those of
the rest of the sample. Included in the eight sessions were two which involved
disabled people – one with deaf/hard of hearing people and the second with
people who are registered as blind. Both of these groups were facilitated to
ensure that all attendees could participate fully and equally.
Audience Councils
The Audience Councils exist to bring the diverse perspective of licence fee
payers to bear on the work of the Trust. Audience Councils’ links with diverse
communities and their programme of outreach and other activities allows them
to provide a broadly based assessment of audience needs, interests and
concerns, thereby bringing audience voices to the heart of the Trust’s work. The
format of these events varies across and within each nation and region, with
some specifically targeting audience groups and some focusing on key
discussion topics. Any potential barriers to participation are considered when
developing an event so that where possible, accessibility or other additional
needs can be addressed.
Some examples of specific activity with disabled people and carers during 2009,
included:
33

Audience Council Wales held a meeting with members of the Alzheimer’s
Society in July where they covered topics such as representation and
portrayal, technology and the internet.

As part of the scoping exercise for the Trust’s portrayal project, Audience
Council Northern Ireland had a discussion with representatives of
organisations and groups working with disabled people. 19 people attended
representing 16 organisations covering physical disability, learning
difficulties and mental health issues.
4.3.3 Digital switchover and Digital UK
Digital UK
In September 2005, the Government announced that digital switchover would
take place between 2008 and 2012. Digital switchover is the process of
changing the television broadcasting network to digital. It involves converting
the current analogue television network, as well as encouraging the public to
convert or upgrade their TV and recording equipment so that they can receive
digital television.
A Ministerial Group on Digital Switchover manages digital switchover. The
Ministerial Group meets quarterly and is co-chaired by the Department for
Business Innovation and Skills (BIS) and the Department for Culture, Media and
Sport (DCMS). The Ministerial Group also includes representatives from Digital
UK, Ofcom, BIS, DCMS, public service broadcasters (BBC, ITV, Channel 4, Five,
S4C and Teletext), non-terrestrial platform operators, consumer bodies, retailers
and manufacturers.
Digital UK is the independent, non-profit organisation set up to manage all
communications with the public regarding digital switchover and the Digital
Switchover Help Scheme (although the BBC subsidiary DSHS Ltd also has some
responsibility in this area). Digital UK provides impartial information on what
people need to do to prepare for the move to digital television. Digital UK is
owned by the UK’s public service broadcasters and the transmission companies
SDN and National Grid Wireless.
Digital switchover is a public function for the BBC and the BBC is a key
stakeholder in many elements of the digital switchover programme being
managed by the Ministerial Group. Digital switchover communications are part
of the public function of the BBC and, as mentioned above, this work is being
managed and implemented by Digital UK.
34
As well as managing the communications for digital switchover, Digital UK is
also working with digital TV platform operators, equipment manufacturers,
installers, retailers, rental companies and consumer groups to coordinate the
technical rollout of digital television across the UK.
Digital UK is consulting with a number of groups of disabled consumers and
audiences in different areas of the UK as part of its communication planning for
the regional rollout of digital switchover. It is gathering regional information
from consumers and audiences through its Regional Managers, its Community
Outreach Programme delivered on its behalf by Digital Outreach Ltd. (DOL) and
via its Consumer Experts Group (CEG), which includes representation from the
RNIB, Help the Aged, Age Concern, RNID, VLV, CAB, SENSE, NCC, OCP, ACRE,
TAG, Wireless for the Bedridden, and the Ofcom Advisory Committee on Older
and Disabled People. The CEG meets regularly to discuss the planning,
implementation and management of digital switchover.
Digital Switchover Help Scheme
To help ensure that everyone can switch more easily to digital TV, the BBC
manages a Help Scheme for people who need it most and is delivered on its
behalf by eaga plc. The Help Scheme is focused on providing practical assistance
and support for people who:

are 75 and over

receive Disability Living Allowance, Attendance Allowance, Constant
Attendance Allowance or Mobility Supplement

are registered as blind or partially sighted
The scheme helps people to select, install and use digital television equipment
and ncludes:

assistance with choosing the service

equipment designed for ease of use

providing equipment to convert one TV set

help with installation

follow-up support
The scheme costs £40 to take part, but is free for those receiving Income
Support, Job Seeker’s Allowance or Pension Credit.
35
The BBC’s subsidiary DSHS Ltd estimates 7 million households are eligible for
the Help Scheme in the UK. These households are able to opt in region by region
between 2008 and 2012.
For more information on the Help Scheme please visit:
http://www.helpscheme.co.uk/
How disabled people have been involved
Through its subsidiary DSHS Ltd, the BBC has consulted with disabled people
and disability organisations every year to inform the development of the Help
Scheme. During the summer of 2007 the BBC led a consultation and involvement
process to shape the development of the Help Scheme. The BBC involved
disabled and older people and voluntary sector organisations specifically in the
development of this service. Interviews with over 30 organisations informed a
series of focus groups with nearly 150 people who have positively informed the
service itself, the development of a Code of Service Standards used to monitor
service quality, delivering a high quality service to service users with a range of
impairments and requirements and accessible communications.
While previous consultations have focused on what people want from the Help
Scheme and its complexity, during 2009-10, the consultation centred on the
extent to which people for whom the Help Scheme is designed, are using the
service in order to increase understanding about the service users and potential
service users of the Help Scheme. The consultation involved:

local community organisations in the geographical regions which had most
recently switched to digital

14 discussion groups and 38 in-depth interviews with people who were
eligible to use the Help Scheme

observations of the delivery of the Help Scheme at the frontline both in callcentres and during installations of equipment in people’s homes
This consultation has assisted Digital Switchover Help Scheme to understand in
more detail the range of people’s experiences in making the switch to digital, in
particular people who found it difficult to make the switch and didn’t use the
Help Scheme. Further exploration of this particular group has pointed to
possible explanatory factors including overly complex information about the
Help Scheme, the impact of social isolation on awareness of the Help Scheme
and barriers to the Help Scheme highlighting accessibility issues, particularly for
36
deaf, hearing impaired and blind and visually impaired people. These issues will
be an area of focus for the next 12 months.
Raising awareness and understanding of digital switchover
Digital UK delivers a community outreach programme through its contract with
Digital Outreach Ltd. which is a partnership between Age Concern, Help the
Aged, Community Service Volunteers and Collective Enterprises Ltd., designed to
provide advice and guidance to people who would not have access to the Help
Scheme but who would like some assistance or advice in making the switch to
digital television. The community outreach programme works with voluntary and
community sector organisations switchover region by switchover region enabling
local organisations to support people, including disabled people, by providing
information and speakers for events or drop-ins, training volunteers and
developing a network of help and advice. Digital Outreach Ltd. is currently
working in the ITV regions covering The Borders, West Country, Granada and
Wales.
Digital UK regularly tracks levels of awareness and understanding of digital
switchover among the public. Digital UK monitors this information according to
a range of demographic breakdowns including disability. There are no
statistically significant differentials in the levels of awareness and understanding
between disabled people and the overall population. The most recent data found
a slightly higher rate of awareness of digital switchover among disabled people
compared to the overall population. This data enables Digital UK to identify any
differentials in awareness and understanding between demographic groups
about switchover which can inform communications strategies and activities.
(see also section 3.3).
The DCMS and BIS have consulted with a number of groups of disabled
consumers and audiences on digital switchover and the Digital Switchover Help
Scheme including the Consumer Expert Group and Ofcom’s Advisory Committee
on Older and Disabled People
(http://www.digitaluk.co.uk/about_digital_uk/partners)
Information on needs and barriers is also collected via a Usability Action Plan
which has been established by BIS. Manufacturers and consumers meet regularly
to discuss digital switchover and specifically digital TV receiver equipment. In
addition, ‘mystery shopping’ surveys at commercial outlets include a quota of
37
older and disabled store assessors who gauge the accessibility and
appropriateness of service and advice given.
4.3.4 Consulting disabled BBC staff
The BBC convened a group of disabled staff during 2006 to discuss the
feasibility of launching a Disability Forum and to consult them about what the
organisation needs to do now to become more disability aware and inclusive.
Prior to this there has been a small internal mailing list for BBC disabled staff,
but no formal representative mechanism to consult them about BBC plans which
affect them. The Disabled Staff Forum, advising the organisation on promoting
disability equality as a broadcaster and an employer, is now one of three staff
networks within the BBC. The Forum’s remit goes beyond that of this Scheme
but its work is important here and in the context of the BBC’s Diversity Strategy.
4.4 Assessment – arrangements for assessing the impact of the activities of
the BBC on disability equality and improving these when necessary
The BBC has developed a corporate Equality Impact Assessment (EIAs) toolkit for
each of the areas in the organisation which have public functions to ensure a
systematic and consistent approach to assessing existing or potential
differential impact or specific requirements. This was developed in line with
good practice and has been revised during the last three years. Each of the
action plans in section 9 contains actions relating to how those areas of the BBC
will undertake EIAs.
4.4.1 Equality impact assessments
During the last three years, each of the areas of the BBC with responsibility for
public functions has conducted EIAs. In year 1 of the Scheme, a programme of
retrospective EIAs was developed which informed each of the Action Plans for
that first year. In subsequent years, EIAs have informed new policies, new
services, public consultations and projects across each of the public function
areas within the BBC.
Any new policy or practice relating to a BBC public function (or any new function
which is identified as public by the BBC) is considered for an impact assessment
as a matter of course and the outcomes of those assessments conducted are
used to, and have been used to, inform future review of the Scheme.
EIAs help the BBC to:

Identify any adverse impacts in carrying out the relevant public functions (or
implementing policies and practices related to those functions).
38

Identify unmet needs which may become apparent when carrying out the
relevant public functions (or implementing policies and practices related to
those functions).

Ensure that action is taken to address identified areas above.

Inform future (disability) equality action planning and review of the Disability
Equality Scheme.
EIAs conducted by the BBC in relation to TV Licensing and the Digital Switchover
Help Scheme can be found at:
http://www.bbc.co.uk/aboutthebbc/policies/diversity.shtml
EIAs conducted by the BBC Trust are available at:
http://www.bbc.co.uk/bbctrust/about/how_we_govern/diversity_equality/equali
ty_impact_assessments.shtml
4.4.2 Consultation and involvement
Where a full equality impact assessment is identified as relevant and
proportionate to the duty to promote disability equality, the following
consultation mechanisms will be considered:

Consultation with and involvement of disabled colleagues from within the
BBC and other broadcasting industry groups.

Consultation and involvement with a range of organisations of and for
disabled people in different locations across the UK.

Questionnaires, surveys and other forms of information-gathering published
in appropriate media including print, broadcast and online, particularly those
which are addressed to disabled stakeholder group audiences.

Focus groups held in suitably diverse locations which meet appropriate
accessibility requirements.
The above activities may also be carried out at appropriate intervals as part of
other wider consultation activities, and relevant information or evidence will be
used to assess impact, inform action and influence the three-yearly review of
this Scheme. For example, regular annual consultation by the Digital Switchover
Help Scheme has informed the equality objectives for that set of public functions
for 2010-11. Equally, a consultation commissioned by the BBC Trust with a wide
range of stakeholder organisations informed the Trust in reforming their
equality objectives set out in this reviewed Scheme (see 4.1.2 for further
information).
39
4.5 Formal review for 2010-11
During the third year of operation of the Scheme, the BBC conducted a more
detailed review of the Scheme to identify relevant objectives and actions for
2010-11. The Disability Equality Scheme was due for a full three-year review.
However, with new legislation due but not yet complete and that legislation
expected to apply to more of the BBC’s activities, the organisation decided to
review and extend the existing equality schemes, including the Disability
Equality Scheme for 12 months until 30 April 2011. The BBC will prepare a
Corporate Equality and Diversity Plan.
40
5 Implementing the Disability Equality Scheme
The implementation of the Disability Equality Scheme will be driven by the BBC
Trust Unit insofar as it relates to the Trust, and otherwise by the BBC Executive
Board and carried out at relevant divisional level.
The Disability Equality Scheme has run for three years and is now extended for
12 months up to 31 March 2011 when the new public sector equality duty is
expected to come into force. Performance has been reported annually against
this Scheme and the Action Plan in particular has been regularly updated and
undergone two formal reviews in that time. During 2010-11, the BBC will
prepare a Corporate Equality and Diversity Plan to respond to its new duties
currently set out in the Equality Bill. An extensive involvement and consultation
process will be developed over the next 12 months to inform the BBC’s
Corporate Equality and Diversity Plan which will replace the equality schemes,
including the Disability Equality Scheme and form the BBC’s response to the new
single public sector equality duty, expected in the new Equality Bill once
enacted.
41
6 Monitoring and evaluation
Progress on the Disability Equality Scheme Action Plan will be monitored and
evaluated by the Trust Unit and management teams responsible for each
relevant public function. Each management team reports to the Diversity Board
(led by the Director General and agrees and drives forward the BBC’s Diversity
Strategy) and the Executive Board, which is accountable to the BBC Trust.
The structure chart below shows formal reporting lines (arrow lines also indicate
advice and information flow).
Each Disability Equality Scheme Action Plan section has an in-built monitoring
system (see section 9) which will be used to measure progress and its
effectiveness in achieving intended outcomes.
Throughout the three-year period, the BBC has continued to consult with and
involve disabled people to monitor implementation and assess the impact of
actions, in order to maintain a continual cycle of improvement.
An extensive consultation and involvement process will be developed over the
next 12 months to prepare the BBC’s Corporate Equality and Diversity Plan which
will replace the equality schemes, including this Scheme and form the BBC’s
response to the new single public sector equality duty, expected in the new
Equality Bill once enacted.
42
The
Trust
Unit
The
BBC
Trust
BBC
Executive
Board
TV
Licensin
g
BBC
Diversity
Board
Any other
relevant
public
function
areas
BBC
Diversity
Centre
Digital
Switchover
including
Digital
Switchover
Help Scheme
Digital
UK
(external)
6.1 Disability Equality Scheme Performance Summary 2009/2010
Introduction
Section 4 of the Disability Equality Scheme (DES) sets out in detail the steps the
BBC has taken to meet the Disability Equality Duty, including:

A statement of how disabled people have been involved in developing the
Scheme

An Action Plan
43

Arrangements for gathering information about the performance of the
BBC on disability equality

Arrangements for assessing the impact of the activities of the BBC on
disability equality and improving these when necessary

Details of how the BBC uses information gathered on the effect of BBC
policies and practices on disabled people, in particular in reviewing the
effectiveness of its Action Plans and preparing subsequent Schemes
This Performance Summary reflects an annual review of the DES and highlights
both the BBC’s performance across its public functions during year 3 and key
activities identified for the next 12 months (2010-11). All of the objectives for
each of the public function areas are outlined below together with corresponding
progress and priorities for next year.
Public function: TV Licensing
(For further detail on the range of public functions which relate to TV Licensing,
see Annex.)
Objective 1: To communicate with disabled people, wherever practicable, in a
way that is accessible and appropriate to facilitate a clear understanding of
television licensing obligations
Key achievements during 2009/2010

TV Licensing (TVL) reviewed its equality impact assessment (EIA) on a
representative sample of TVL communications in advance of the three-year
deadline set during the previous EIA process. The review found that further
improvements in communications material had been initiated since the
previous EIA (for example by commissioning a leading linguistic expert with
substantial experience in the needs of people with low literacy levels to
analyse a selection of TVL letters and recommend ways in which they could
be made more accessible).

TVL began a review (in liaison with the RNIB) of the internal processes by
which communications in Braille, large print, audio and electronic formats are
sourced and provided in order to increase efficiency and customer service.
The actions resulting from this review will be incorporated into the 2010/11
action plan.
Area for improvement
44

TVL will continue to liaise with key stakeholders to help us monitor how
effectively we are communicating with disabled people.
Objective 2: To ensure that all BBC TVL staff and contractors fully understand
their duty to promote disability equality and are active in implementing actions
identified
Key achievements during 2009/2010

TVL completed the roll-out of its equality training to existing staff who deal
with customers’ queries and complaints and to TV Licensing visiting officers.
Equality training is now built into the induction process for new staff.

The TV Licensing complaints database was amended in order to be able to
record and analyse information on complaints and comments which are
related to disability needs and issues and to put systems into place to
formally record requests from disabled people.

A procedure was established for analysing information from TVL’s customer
satisfaction survey to determine whether disabled people’s perception of TV
Licensing’s service is lower than that of non-disabled people. Results so far
indicate there is no perceived difference in levels of service.
Area for improvement

TVL will review the methodology of the customer satisfaction survey.
Objective 3: To continually review and, wherever possible, improve or develop
service supports (including technology) to provide maximum access to
support and advice services for all disabled people
Key achievement during 2009/2010

TVL continued to work on implementing the recommendations which came
from the audit of website usability. TVL launched a revised version of its
45
website in October 2009 and further usability testing was conducted in
advance of this release.
Objective 4: To develop and maintain a strategic and systematic approach to
integrating disability equality into all TVL activities
Key achievements during 2009/2010

An initial EIA was conducted on the Voice User Interface (VUI) system to
assess how well it meets diverse needs. An EIA was also undertaken on TVL’s
Refunds Policy. EIAs were also completed on the website refresh project and
a new service that increased contact with TVL’s customers by text message.

The BBC TVL Equality Working Group discussed progress against each of the
actions within the Scheme and received regular updates on equality
legislation.

The TVL Senior Policy Advisor gave presentations on the Equality Working
Group’s (EWG) progress to the senior management to assist them in
reviewing the work of the EWG.
Area for improvement

TVL will continue conducting EIAs on relevant policies and projects and will
continue reviewing the three-year EIA programme relating to existing BBC
(and contractors’) policies and functions which are relevant to the duty.
Objective 5: To maximise the potential for data and information management
systems to enhance and promote disability equality
Key achievement during 2009/2010

TVL used data gathered during Years 1 - 3 to inform the ongoing review of
its action plan.
46
Objective 6: To develop and maintain strategic leadership and commitment to
the broad implementation of the DES and the TVL Action Plan
Key achievements during 2009/2010

The TVL Management Team Policy Adviser has given presentations on the
Equality Working Group’s progress to a number of senior management
meetings to assist this team to review the work of the Group. This will
continue into 2010/2011.
Objective 7: To ensure that all payment methods/processes are accessible and
appropriate for a range of needs and lifestyles
Key achievement during 2009/2010

TVL utilised ‘mystery shopper’ calls to check that call centre agents were
following the correct procedures on calls regarding Paypoint accessibility.

As detailed in the overview, great efforts are made to ensure that information
is made available to diverse audiences. No complaints or issues on equality
of payment method were identified during the BBC Trust’s review of TV
Licence fee collection.
Objective 8: To ensure a strategic approach to integrating disability equality
into all TVL procurement activities
Key achievement during 2009/2010

The re-procurement of the contract to supply TVL’s over-the-counter
services on Jersey reflected the Disability Equality Duty throughout the
process.
For more detail on progress against each of the objectives relating to TVL and
the corresponding actions, see section 9, Action Plan Part 1.
47
Public function: the BBC Trust in relation to certain functions under the BBC
Charter and Agreement
(For further detail on the range of public functions which relate to the BBC
Trust, see the Annex to the Disability Equality Scheme.)
Objective 1: To ensure that the Trust actively engages with and seeks the
views of disabled people, and that engagement activities encourage
participation and are accessible
Key achievements during 2009/10

Both the Trust Unit and the Audience Councils held a number of meetings
across the year with disabled people and people from organisations
representing disabled people. The information and learning shared at these
meetings fed into projects such as the Television Service Licence Review and
the BBC Trust’s Portrayal project.

As part of the Trust’s Television and Radio 2 and 6 Music Service Licence
reviews, to try and reach those audiences who do not use the Trust website
and therefore participate in its online consultations, we used a number of
alternative engagement tools. These included: television trails across BBC
One, BBC Two, BBC Three, and BBC Four (ensuring a good mix of both
daytime and evening slots); network radio phone-ins with trustees;
distribution of leaflets to UK public libraries and visiting shopping centres
across England.

The Trust’s new website conformed to the BBC’s website accessibility
guidelines in full. In addition to the BBC’s statutory requirements, we also
sought the advice of the website design agency to ensure that steps were
taken to make the refreshed website accessible to disabled users. For
example, the refreshed site was user-tested with screen readers prior to
launch.

As part of the comprehensive research for the Trust’s editorial guidelines
review it commissioned eight ad-hoc ethnographic sessions. (These are
informal sessions with friends, taking place in their own environment e.g.
someone’s home, a community centre, a church meeting room etc) The
purpose of these sessions was to allow the Trust to capture the perspective
of people whose views might not otherwise be heard and whose views might
differ from those of the rest of the sample. Two of these sessions were held
with disabled people – one Deaf and hard of hearing people and the second
with people who are registered as blind. Both groups were facilitated ensure
that all attendees could participate fully and equally.
48
Areas for improvement

We have been trying to employ a variety of engagement tools to ensure we
communicate with a range of people, but we know there is far more to do
here. One area which we feel could be explored further is the connections
and relationships Audience Councils have with those interest groups
representing disabled people, especially as there seems to be an appetite
from the organisations themselves to understand and know more about the
work the Councils do.

Greater effort needs to be made to ensure that the Trust has a regular and
consistent approach to monitoring the diversity of licence fee payers
attending its public meetings

Feedback from our recent review of the BBC’s three Equality Schemes,
highlighted the low awareness levels of the Trust and its activities. There was
a call to improve outreach with different groups by building ongoing,
relationships with them over a long period of time.
Objective 2: To monitor and assess the BBC’s strategic approach to disability
equality in order to review and continually improve outcomes for disabled
people
Key achievements during 2009/10

We held an event with Trustees and invited senior external figures to discuss
with them the importance of equality and diversity in their oversight role.

For the first time we asked the BBC Executive to report to the Trust on the
progress it is making with its Diversity Strategy. This will be an annual
reporting requirement in the future.
Areas for improvement

We are conscious that the current Public Value Test (PVT) guidelines do not
include information about how the BBC Executive will ensure, to a reasonable
and appropriate extent, equality of access and service of BBC activities to
different groups in its PVT proposals. Therefore the Trust is to begin
discussions with the Executive to try and codify what is expected of them,
with regards to equality considerations, when preparing a proposal for
new/changes to/closure of a BBC service.
49

Feedback from our recent review of the BBC’s three Equality Schemes,
included the observation that there was a lack of evidence of how the BBC
Trust performs against its objectives. Demonstrating the efficacy of the
Trust’s operations and the impact different groups’ involvement have, could
better show the Trust’s value to licence fee payers.
Objective 3: To ensure that all disabled people have equal and fair access to
the Trust’s complaints processes
Key achievements during 2009/10

We are currently running a project to test the effectiveness of the BBC
Executive’s complaints processes. Equality and diversity have been key to our
thinking and we are finding ways to investigate whether who you are or what
you complain about affects what happens in any way.

We have influenced the BBC Executive’s procurement process for audience
services, including the complaints process. In addition we will be working
with the BBC Executive to try and develop the way the BBC collects diversity
information from those people who contact the BBC (including complainants).
Objective 4: To ensure that disabled people have equality of access to
consultations and are involved in Trust decision-making in relation to its public
functions
Key achievement during 2009/10

Both the Trust Unit and the Audience Councils held a number of meetings
across the year with people from organisations representing disabled people.
The information and learning shared at these meetings fed into projects such
as the BBC One, BBC Two and BBC Four service licence review and the Radio 2
and 6 Music service licence review.

In addition to the above mentioned stakeholder meetings, as part of these
two reviews As part of the Trust’s Television and Radio 2 and 6 Music Service
Licence reviews we used a number of alternative engagement tools to try and
reach those audiences who do not use the Trust website and therefore
participate in its online consultations, These included: television trails across
BBC One, Two, Three and Four (ensuring a good mix of both daytime and
evening slots); network radio phone-ins with trustees; distribution of leaflets
to UK public libraries and visiting shopping centres across England.
50

The Trust’s new website conformed to the BBC’s website accessibility
guidelines in full. In addition to the BBC’s statutory requirements, we also
sought the advice of the website design agency to ensure that steps were
taken to make the refreshed website and its online consultations accessible
to disabled users. For example, the refreshed site was user-tested with
screen readers prior to launch.
Areas for improvement

As highlighted in the 2008/09 performance summary, we still need to work
harder at disabled people given we know that they are less likely to respond
to our public consultations. Continual work and effort on our EIA practice and
further exploring the connections and relationship Audience Councils have
with these groups will go towards improving this situation

Feedback from our recent review of the BBC’s three Equality Schemes,
included the perception that the Trust relies too heavily on the internet when
consulting. Face to face communication was highlighted as being a preferred
method of reaching disabled people.
Objective 5: To ensure that, where appropriate and reasonable, the Trust’s
public reports and communications (including online) are accessible (in
language, format and content) for disabled people
Key achievement during 2009/10

One of the aims of the BBC Trust’s new website was that it would be more
‘audience friendly’ and in line with the recommendations of the Trust’s
strategic marketing work. In addition to ensuring that the website complied
with all the BBC’s accessibility guidelines and that user testing was conducted
with screen readers, much effort was given to building a website which would
have a clearer structure, navigation and labelling of documents.
Areas for improvement

Feedback from our recent review of the BBC’s three Equality Schemes,
indicated that documents (especially ones accessed online) might not be the
best way to publish information. Many felt face to face communication would
51
work better.
Objective 6: To ensure that diversity and equality matters are integrated into
the Trust’s governance tools
Key achievements during 2009/10

Finding ways to integrate diversity within our governance tools was the main
objective of the equality and diversity review (carried out in 2008). It
highlighted a range of challenges which we are working to address. Some
examples of progress made over this past year include:

The Director of the Trust, team leaders and project managers have all
been set individual objectives relating to equality and diversity.

The Trust Unit are in the process of meeting all research agencies on the
qualitative and quantitative research rosters to take them through the
Trust’s internal research guidelines, using the meeting to probe them on
their experiences in researching more seldom heard audiences.
Areas for improvement

We are conscious that the current Public Value Test (PVT) guidelines do not
include information about how the BBC Executive will ensure, to a reasonable
and appropriate extent, equality of access and service of BBC activities to
different groups in its PVT proposals. Therefore the Trust is to begin
discussions with the Executive to try and codify what is expected of them,
with regards to equality considerations, when preparing a proposal for
new/changes to/closure of a BBC service.
Objective 7: To ensure that Audience Councils are fully inclusive and should as
far as possible reflect the diversity of society they represent. The Trust will
actively encourage membership from disabled people, people from diverse
ethnic and cultural backgrounds and a gender-balanced membership wherever
practicable and possible. The Trust will also work with Audience Councils to
ensure that they engage effectively with diverse communities to enhance
members’ understanding of audience concerns.
Key achievement during 2009/10

We are currently working with Audience Councils to explore audience views
on portrayal of all audiences including disabled people.
52

Employing a variety of methods, including television and radio trails, online
promotions, e-zines, press advertisements and direct contact with
organisations representing diverse groups, to raise the awareness of
vacancies within the Audience Councils so as to reach and encourage as
diverse a number of applicants as possible
Areas for improvement

Improving the awareness of Audience Councils.

Broadening our engagement with seldom heard groups and communities
through our Audience Councils.
For further detail on each of the objectives relating to the Trust and the
corresponding actions, see Section 8, Action Plan Part 2, of the Disability
Equality Scheme.
Public function: the BBC’s obligations in relation to digital switchover
(For further detail on the range of public functions which relate to digital
switchover, see the DES: Annex.)
Objective 1: To assist the “most vulnerable beneficiaries” (older and disabled
people) to make the switchover to digital TV
Key achievements during 2009/2010

We invest heavily in ‘outreach’ activity to better engage people who are
eligible for the Help Scheme. Outreach activity takes the form of:


Statutory sector activity

Third sector activity

Communities programme
Statutory sector activity is delivered in each region by eaga network
managers. Examples of activity this year have included:

Building strong relationships with large local authorities has produced
opportunities for shared events, coverage in local newsletters, and
information points at major city libraries, Town Halls, Council offices and
Day Centres.

Developing campaigns with Neighbourhood watch, the police and fire
services. These organisations have considerable interface with the public,
53
and have disseminated Help Scheme information in the form of face to
face, one to one discussions, and within wider community programmes.

In the Granada region, linking the Help Scheme with Flu Clinics was
incredibly successful – delivering over 7,000 face-to-face conversations
with potential customers.

In Wales we have gained commitment from the majority of NHS Trusts to
distribute Help Scheme materials in local hospitals, brief medical staff and
host Open Days.

In the West region, ‘Help Scheme Champions’ have been enlisted within all
local authorities. Help Scheme information has been posted on all local
authority websites, and information made available in all public libraries.

Third sector activity is crucial in engaging local community and voluntary
sector organisations to support the Help Scheme. The majority of third sector
activity is delivered by eaga through Digital Outreach Limited (DOL),
contracted by Digital UK to communicate with people who aren’t eligible for
the Help Scheme but are at risk of being left behind. Examples of activity this
year includes:

DOL training for the Voluntary and Community Sector (VCS) has become
widespread throughout all regions, with additional training for black and
minority ethnic groups, and disability groups as appropriate.

The Help Scheme community radio publicising the Scheme throughout
local communities - particularly among those at-risk of being left behind.
The community radio initiative involves producing and broadcasting
customised Community Service Announcements (CSAs), interviews with
Help Scheme related personnel, and packaged reports showcasing Help
Scheme success stories.

An updated outreach pack was created to raise the profile of outreach to
disabled people. We introduced 3 photos on the back cover, including an
image of a disabled person and a carer.

The BBC bus was mobilised in Granada to target areas of low response.
The bus has been a high profile venue, offering face to face advice to
customers and their representatives, and also acting as a broadcast
platform. A Help Scheme bus will enable the Help Scheme to gain profile
in specific neighbourhoods (particularly remote communities) in the
future.
54

The communities programme is managed by DOL, and aims to reach the 5%15% of people who are most at risk of being left behind. Examples of activity
this year have included:

Identifying and engaging key community figures (such as community
counsellors, GPs, carers, community, psychiatric nurses, shopkeepers,
community police officers, café owners), to find community supporters
who then identify those who are most isolated

Continuing to deliver Deaf Roadshows at deaf clubs - often the most
trusted source of information for members.

We are working with the Department for Work and Pensions (DWP) to
develop a ‘scoring model’ to help identify people most socially isolated, in
order that we can develop strategies to better engage them.

Every year the Help Scheme conducts consultation with people eligible
to use the Help Scheme, in order to continuously improve the service.
This year the consultation provided new insights into the behaviour of
people eligible for the Help , particularly those who found switchover
difficult, were eligible for the Help Scheme but who opted out because
of a lack of awareness of the Help Scheme and what it offers –
including people who have already made the switch to digital. The
consultation raised a number of issues this year including barriers to
the Help Scheme highlighting accessibility issues particularly for deaf
and hearing impaired and blind and visually impaired people which will
be an area of focus over the next 12 months.

The Code of Service Standards outlines the level and standard of service that
people using the Help Scheme can expect. The Code of Service Standards is
currently undergoing an audit to ensure the Help Scheme is delivering
against these standards.

Digital UK created a Help Scheme TV advert aimed at raising awareness of the
Help Scheme amongst disabled audiences. It features double gold medallist
at the 2008 Paralympic Games, Eleanor Simmonds. We have produced
additional versions of our posters and bus headliners to carry the image of
Eleanor Simmonds the Paralympics swimming champion.

Following research to identify key groups of people who interact with the
most seldom heard and who could help them to make an informed decision,
the Help Scheme developed a series of A5 leaflets aimed at in home carers,
55
threshold service workers and peers to be distributed by on-the-ground
teams.
Objective 2: To ensure that the transition to digital-only broadcasting is a fully
inclusive process
Key achievements during 2009/2010

The customer satisfaction survey is completed by 200-300 Help Scheme
customers every month. Since the survey began, (Jan 09) 92.5% of
respondents have rated their willingness to recommend the Scheme at 8 or
above, out of 10. The satisfaction survey will be improved across the coming
year to ensure that feedback is gained from disabled people with a broad
range of impairments.

DSHS Ltd. are in the process of commissioning an independent organisation
to conduct an ‘audit’ of a person’s journey using the Help Scheme in order to
review the accessibility of the Scheme for disabled people. Results are
expected by mid 2010.

Evidence from Digital UK’s Switchover tracker, which measures awareness
and understanding by different groups, suggests a positive picture among
disabled people. Quarter 4 2009 results indicate that across eight key
switchover awareness and understanding measures responses from disabled
people were either in line with or above the average response for seven of the
measures.
Areas for improvement

We want to focus on improving the Help Scheme experience for eligible
people from the following access groups (where there are known access
issues): mental health, learning disabilities, blind and partially sighted, deaf
and hard of hearing.
Objective 3: To ensure that all digital switchover (DSO) and Help Scheme
related information and modes of communication are appropriate for target
audience and are fully accessible
Key achievements during 2009/2010
56

The Help Scheme branding has undergone significant user testing in order to
identify and mitigate potential barriers for people within the target group
audiences, including disabled people.

The Help Scheme has developed a storybook version of the Help Scheme
leaflet designed for people with learning difficulties, BSL users, some mental
health conditions, people for whom English is not a first language, and child
carers. This has been circulated through voluntary and community sector
organisations as well as being available to order directly along with all other
alternative formats from the call centre including audio, BSL and Braille. The
storybook has received positive feedback, and we are currently developing
the next version.

The Help Scheme’s website meets the Web Accessibility Initiative AA standard
and enables users to access the site using large text, British Sign Language
(BSL), Easy Read and Browse Aloud. All information is available, either off the
shelf or upon request, in large print, Braille, Easy Read and audio.

Blind and partially sighted people, eligible for the Help Scheme, receive their
direct mail as an audio CD (including letter) once their status has been
confirmed via information from the relevant Local Authority. We have also
developed a story book to be used by the carers of people with learning
difficulties to explain the help with switchover which the scheme provides.

We ensured the BBC TV 30 Sept National Retune event trails included
subtitles, for the benefit of a deaf audience. This was vital, as sets with
subtitles permanently switched on were not able to receive the MHEG text
pop-ups flagging the retune.

The eaga contact centre has introduced a simpler process for eligible people
to nominate another person to handle their application to the scheme. This
will increase access to the scheme for a number of people who find it difficult
to engage with the contact centre directly themselves.

Eaga contact centre offers Text phone for deaf people. In response to
feedback, eaga have also installed a quiet area where agents are able to
communicate better with hard of hearing callers.
57

Community radio stations were used extensively in Granada in order to raise
awareness and understanding of the Help Scheme. These stations have
strong listenership amongst disabled audiences. The community radio
initiative involves producing and broadcasting customised Community
Service Announcements (CSAs), interviews with Help Scheme related
personnel, and packaged reports showcasing the Help Scheme success
stories.
Objective 4: To involve disabled people in the planning and rollout of DSO and in the planning and roll-out of the Help Scheme
Key achievements during 2009/2010

We consult annually with people eligible for the Help Scheme specifically to
ensure that the scheme is shaped by its users. We continued relationships
with a wide range of community and voluntary sector organisations to ensure
that the BBC continues to involve disabled people in the Help Scheme.

Help Scheme outreach teams interact regularly with community organisations
including eligible people and their representative bodies, charities, volunteer
groups.

We worked with Mencap to develop the easy read version of the Help Scheme
leaflet.
Area for improvement

We are investigating how to increase the involvement of more eligible people
in delivering the Help Scheme.
Objective 5: To gather and use information effectively in order to
monitor and assess the impact of current and planned DSO
policies and practices with regard to disability equality.
58
Key achievements during 2009/2010

The Help Scheme Equalities Working Group meets quarterly, and is attended
by all member of the senior team. The group monitors and reports on
progress related to commitments in each of the BBC equality schemes,
including the Disability Equality Scheme.

All major decision making forums e.g. Design Authority, Markets Direction
Group are charged with undertaking Equality Impact Assessments (EIAs) on
all major decisions.

The existing customer satisfaction survey, customer complaints procedure,
installation inspections have all being designed to surface disability equality
issues. They are reviewed systematically and issues are logged and progress
monitored in the equalities action plan. We have completed the first round of
mystery shopping which demonstrated a strong call centre performance in
dealing with the needs of eligible people. A second mystery shopping
exercise will take place in Feb / March 2010 in which customers will have the
opportunity to give feedback on their full customer journey.

The Digital UK tracker continues to inform us of awareness, understanding
and attitudes towards the Help Scheme among disabled audiences. This is
used in evaluating the current contact strategy.
Area for improvement

To ensure that EIAs are used more systemically to evaluate all major
decisions.
Objective 6: To ensure effective internal monitoring and DES outcomes
evaluation
Key achievements during 2009/2010

The Help Scheme Equalities Working Group meets quarterly, and is attended
by all member of the senior team. The group monitors and reports on
progress related to commitments in each of the BBC equality schemes,
including the Disability Equality Scheme.
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
Help Scheme is represented on the BBC Finance Division’s Equality and
Diversity Action Group.

Quarterly research accompanied our annual consultation to assist us to
review our progress against our commitments in the BBC equality schemes,
including the Disability Equality Scheme to identify lessons and any remedial
action.
Other BBC public functions (under the BBC Agreement)
Public function: Making the UK public services widely available
Key achievements during 2009/2010

In May 2008 the BBC reached its target of 100% of programmes subtitled
on BBC One, BBC Two, BBC Three, BBC Four, CBeebies, CBBC and BBC
News. This amounts to more than 50,000 hours of subtitled content each
year.

During 2009/2010, the BBC achieved the following audio-described
content (against a target of 10%%):
BBC One: 15.5%
BBC Two: 13.3%
BBC Three: 24.1%
BBC Four: 22.9%
CBBC: 18.7%
CBeebies: 15.4%

During 2009/2010, the BBC achieved the following signed content
(against a target of 5%):
BBC One: 5.2%
BBC Two: 5.8%
BBC Three: 5.7%
BBC Four: 6.5%
CBBC: 6.5%
CBeebies: 5.2%

This year iPlayer launched the availability of audio described programmes,
making it possible for visually impaired people to experience BBC TV
programmes more fully. This makes the BBC the first broadcaster in the
world in include audio described TV programmes in its video-on-demand
service. Audio described shows include Dr Who and EastEnders.
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Areas for improvement

The BBC will put in place an improved assurance process to ensure that
each new website or service is as accessible as possible.

The BBC will explore facilitating the provision of transcripts of radio
content via an automated mechanism. Currently, any available transcripts
or information about a programme will be on the relevant website.
Public function: Code relating to provision for the deaf and visually impaired
and power to modify targets
For more detail on this public function and the related actions, see section 9,
Action Plan, Part 3 (ii).
Public function: Reports and accounts about the commercial services
Key achievements during 2007/2008

English, audio and Braille versions of the Annual Report and Accounts
2006/2007 were produced. For the first time the Annual Report
2007/2008 will have its own dedicated website, designed together with
access specialists.
Public function: The BBC may be requested to broadcast or distribute
announcements in relation to defence and emergency arrangements
For more detail on this public function and the related actions see section 9,
Action Plan, Part 3 (ii).
For more detail on progress against each of these public functions and the
related actions see section 9, Action Plan Part 3 (ii).
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7 Feedback and update
The BBC promotes its broad commitment to respecting, valuing and celebrating
diversity via the BBC Diversity website,
http://www.bbc.co.uk/info/policies/diversity.shtml , where the Disability
Equality Scheme is published. It is also published on the BBC Trust website,
http://www.bbc.co.uk/bbctrust/framework/diversity/index.html
Updates will be added at regular intervals.
In addition the Trust will report annually on the performance of the BBC
Executive Board with regard to disability equality – see also Action Plan 2
(objective 2, action 2).
Alternative formats will be available on request from the Diversity Centre and
will be provided within a set maximum time limit.
For a copy of the Disability Equality Scheme in another format, or for further
information, contact:
BBC Diversity Centre
Room 2568,
White City
201 Wood Lane
London
W12 7TS
Email: mailto:diversity.centre@bbc.co.uk
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8 The BBC’s broader approach to promoting disability equality
The Disability Equality Scheme is limited to how the BBC applies the Disability
Equality Duty to its public functions. However, while not within its legal
obligations, the BBC’s Diversity Strategy aims to embed consideration of equality
and diversity, including disability equality within everything it does.
The BBC aims to promote disability equality generally through seeking to
understand and meet the specific and diverse requirements of disabled people
and by ensuring that they are fully involved in working together towards
achieving fair and equal outcomes for themselves and their carers. This
approach is based on the BBC’s Diversity Strategy and is underpinned by its core
values: Audiences, Respect and Working Together. It is also driven, in part, by
the specific duties relating to equal opportunities which are placed on the BBC
by the BBC Charter and Agreement (ref. Charter Article 44 (1) (a) and (b) and (2)
(b), and Agreement Clause 83).
8.1 BBC Diversity Strategy
The BBC’s diversity strategy outlines the Corporation’s overall approach and
priorities for action in terms of equality and diversity, including disability
equality.
The strategy defines diversity as a creative opportunity for the BBC to connect
with all UK audiences in all their diversity.
The strategy has four main areas of activity, aimed at integrating diversity into:

Corporate strategy – how the BBC meets its six public purposes and plans for
the future

Audiences – how the BBC engages with all audiences in all their diversity

Output and content – how the BBC authentically reflects the diversity of the
nation

Workforce – how the BBC promotes a diverse workforce across the
organisation and at all levels
Set out below are examples of activity, against the key areas of the Diversity
Strategy which aim to promote and enhance disability.
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8.1.1 Diversity Strategy – Corporate Strategy
Disability equality sits firmly within the BBC’s Diversity Strategy. This key
area of the strategy is concerned with embedding diversity within how the
BBC plans for the future and priortises:

Mainstreaming diversity into how the BBC operates by for example,
building in routine consideration of diversity into strategic and business
planning, major projects and policy development (eg BBC North, Digital
Switchover and key partnerships).

Ensuring that the BBC remains compliant with current equality
legislation, eg having up to date Equality Schemes in place, and
providing reasonable adjustments for disabled staff.

Communicating and sharing examples of good practice on diversity
across the organisation and beyond via partnership and collaborative
working.
All BBC divisions are required to develop a Diversity Action Plan which sets out
the practical steps they are taking to implement the Diversity Strategy. The
action plans address each of the four headline areas: corporate strategy,
audiences, output and content, and workforce planning. Diversity Champions
across the organisation drive this process within their divisions, supported by
Diversity Action Groups. The Diversity Centre monitors progress against the
Diversity Strategy across the organisation and reports to Diversity Board, chaired
by Mark Thompson, the Director-General.
Over the last 12 months BBC Workplace has made further progress on a number
of fronts to introduce several access related improvements for both our disabled
staff and visitors. Key highlights are:

A full review and subsequent re-launch of improved disability related
evacuation procedures, introducing new and improved evacuation equipment
at a number of sites. Furthermore, a number of our older and in access terms
more challenging regional sites have been targeted for refurbishment.

The BBC Workplace Disability Risk and Compliance Manager is now part of
the design team for all projects involving site re-furbishment be they large or
small. This ensures that best practice is adopted whenever possible. This also
applies to our major new developments at the Media City in Salford and
London Broadcasting House.
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
An on-going programme of building access inspections is also carried out by
the designated risk and compliance manager and this also leads to minor
improvement works

BBC Workplace continues to work closely with the BBC Disabled Staff Forum
to identify and deal with any problems, issues or suggestions that may arise.
8.1.2 – Diversity Strategy - Audiences
The following examples of specific projects help to demonstrate some of the
BBC’s commitment to continue to make programmes that reflect the reality of
diverse audiences, including currently underserved audiences and which deliver
on the BBC’s responsibility to inform, educate and entertain:
Us5 - Building on the BBC’s research into our audience with learning difficulties,
BBC Ouch presented Us5, an accessible interactive video commissioned by BBC
Future Media & Technology, written by Sangeeta Patel and created by Gamelab
London. Us5 shows people with learning disabilities/difficulties faced with reallife dilemmas in five video stories. Decision making tools support users in
making big choices for the characters and supports them in thinking through
what they might do in the same circumstances, and what the consequences
might possibly be. Find out more at:
http://www.bbc.co.uk/blogs/bbcinternet/2009/12/us5_bbc_online_videos_help
_peo.html
Talking Disability - A joint research project, between the BBC and Channel Four
which looked at the portrayal of disabled people and accessibility to content,
from the perspective of disabled people. Key challenges as a result of the
research were:

Disabled actors should play disabled roles

More disabled people in shows not about disability

More 'everyday' portrayal of disabled people

Access is good - but there are high expectations for BBC Online
Following the research, creative workshops were delivered to help programme
makers digest and practically apply the findings from this research to their
content. The BBC launched its Disabled Actors Directory and Performers
Directory, both valuable internal resources for programme makers, promoting
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UK disabled talent. In tandem, the BBC launched Talent Alert a nationwide search
to find new disabled actors and performers. The BBC and Channel Five also
hosted the Broadcast & Creative Industries Disability Network Spark Event which
focused on disability portrayal in entertainment.
8.1.3 – Diversity Strategy - Output and content
The BBC aims to make programmes that reflect the reality of our diverse
audiences , including currently undeserved audiences and which deliver on the
BBC’s responsibility to ‘inform, educate and entertain’. Below are examples
of the BBC increasing its commitment to the inclusion and portrayal of
disabled people in on screen and on air:
Radio
BBC Radio 4 series No Triumph, No Tragedy featured Betty Jackson, the fashion
designer and Tammy Duckworth a US helicopter pilot, who lost her legs in the
Iraq War.
Mind Your Own Business? BBC Radio 4’s You and Yours explored the dilemma
for job applicants, on whether to reveal a history of mental health issues, in a
phone in.
Dos and Don’ts for the Mentally Interesting, a BBC Radio 4 drama based on a
blog by Seaneen Molloy, dealt with the day to day experiences of a young
woman with bi-polar disorder.
In The Choice, on BBC Radio 4, Michael Buerk talked to Alex Bell about her
choice to adopt children with Down’s syndrome.
Television
The Silence, a drama about a deaf girl who witnesses a murder in this new fourpart drama on BBC One. Amelia Edwards played by Genevieve Barr has recently
been fitted with a cochlear implant, enabling her to hear, but she struggles to
accept that she has a place in the hearing world. She witnesses the audacious
murder of a policewoman, and is reluctantly propelled into a loud and
frightening world.
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BBC Three’s Dancing on Wheels, featured six wheelchair users, paired with
celebrities, competing to represent the UK in the Wheelchair Dance Sport
European Championship.
Egghead featured an all deaf quiz team called One Sense Less who beat the
BBC’s Eggheads. The production included two British Sign Language interpreters,
including one on screen.
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BBC Two’s Wonderland – featured two documentaries which dealt with the issue
of disability. Can we Get Married? A documentary about Emma and Ben, a young
couple with Down's syndrome, who hoped to marry and The Alzheimer's Choir:
told the story of Ted and wife Hilda who belong to a choir made up of
Alzheimer's sufferers with their spouses.
EastEnders has had numerous storylines around disability and guest characters
with disability some of them children including Janet Mitchell, and more recently
Syd’s son Noah. In addition, EastEnders has told the stories of Jean Slater and
Stacey Branning’s bi-polar disorder, Jim Branning played by John Bardon whose
real life stroke was incorporated into the drama. Also in 2009 EastEnders’ first
regular adult character with a visible disability played by a disabled actor, David
Proud.
BBC One is developing a comedy drama about two people with Down’s syndrome
who run away to get married at Gretna Green. The 60-minute Honky Tonk is
being developed in-house and the cast is yet to be confirmed.
BBC Three have commissioned a ground-breaking season of documentaries
about young people with autism – The Autistic Me, Autism School, The Autistic
Driving School and Disco Kid. The season aims to shed new light on what it is
like to grow up living with autism. The films are warm and insightful and
explore people’s abilities and strengths as well as the challenges they face.
Hannah: The Girl Who Said No to a New Heart, a documentary on BBC One
following 13 year old Hannah Jones, who made national headlines when she took
the controversial step of turning down a heart transplant, knowing that she
could die at any time.
Why Do You Hate Me? Exposed hidden hate crimes against disabled people in
Wales.
This year the BBC introduced Cerrie Burnell as a new CBeebies presenter, the BBC
channel for pre-school children. Cerrie is the first visibly disabled children’s
presenter.
This year, the BBC won a number of awards for its portrayal and reflection of
disabled people’s lives. On air, BBC Radio 4’s Mind Your Own Business (You and
Yours) and the Do’s and Don’ts For The Mentally Interesting, Newsnight, Alister
Campbell’s documentary Cracking Up, Welsh Soap Pobol Y Cwm were all
recognised. EastEnders, won a Mind Mental Health Media Award under the
category Making a Difference for their portrayal and reporting of mental health
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issues. The Storyville documentary - Heavy Loaded, won The Cultural Diversity
Network award for Excellence in Creative Output for its programme on a
learning disabilities/difficulties punk band. The BBC won the Doing Media
Differently Award in both the factual and fictional categores at the Radar
Awards. Otto: Love, Lust and Las Vegas won the factual award while the fictional
award went to EastEnders. Radio 4’s The Pursuits of Darleen Fyles (a journey
through the unique life of a young woman with learning disabilities) was also
highly commended. BBC Programming and talent won four awards at The Ability
Media International Awards 2009. Northern drama The Street won the TV
category while the Hunchback of Notre Dame won the radio category. Cbeebies
presenter Cerrie Burnell won a Champion Award and the Fellowship Award went
to Frank Gardner. The children’s drama Dustin Baby won the Children & Young
People category at the International Emmy Awards. The programme is based on
Jaqueline Wilson’s novel and focuses on a 14 year old girl’s journey through the
foster care system. Its cast includes Lizzy Clarke, a young actress with Aspergers
Syndrome who plays Poppy, a character who also has Aspergers.
Last year the BBC exceeded its targets for providing access to its services
through subtitling, audio description and BSL interpretation. Since 2008 the BBC
has subtitled 100% of its services across its television network. The BBC
exceeded its target across its networks of 5% BSL interpretation and its 10%
target for audio description – in some cases exceeding 20% of its content
including BBC Three and BBC Four.
January 2010 saw the launch of our technology strategy paper for the whole
BBC. It is based on a set of principles which will guide technology decisions in
the BBC. This represents an important step in the way we are approaching
technology, and the widespread support for this move across the organisation,
demonstrates the importance of technology in everything the BBC does.
Online
The BBC, in partnership with ITV, Five, BT, Channel 4 and Talk Talk, received
provisional approval for Project Canvas– designed to establish standards for
bringing broadband and broadcast content together direct to TV and increasing
access to on demand content. The Trust’s provisional approval is subject to a
number of conditions, including delivering accessibility and usability from the
outset.
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This year audio description became available on the iPlayer for the first time
making it possible for visually impaired people to experience BBC TV
programmes more fully. The BBC is the first broadcaster in the world to include
audio described TV programmes in its video-on-demand service. Audio
described shows include Dr Who and EastEnders. The iPlayer was recognised by
the Access IT @ Home Award for the best ICT service in Europe that advances
independent living for disabled and older people.
Digital accessibility is a fundamental objective of the BBC’s digital service
strategy. Over the coming year, the BBC will continue to provide and monitor the
provision of access services (subtitling, audio description and signing
reversioned from its Broadcast Television access services) for its Video-onDemand service BBC iPlayer, and will seek to offer access services wherever
programmes have carried those services when first broadcast. The BBC will
continue to consult groups which are representative of those with sensory
impairments, regarding the most appropriate range of access services across
BBC Broadcast Television and Video-On-Demand services and in evaluating their
effectiveness. The BBC will also consult groups which are representative of those
with people with a broad range of impairments, regarding their accessibility
requirements, and evaluating the effectiveness of BBC sites and service in
meeting these needs.
The BBC will also continue to develop and publish Online and Mobile sites and
services that meet the accessibility requirements of disabled people, where these
are technically feasible and costs are reasonable. All new Online & Mobile sites &
services will meet the accessibility requirements of its users through compliance
with the BBC’s Future Media Accessibility Guidelines and involvement of users
with disabilities when developing and testing its sites & services. The BBC will
develop and publish online DTV/IPTV apps and services that meet the
accessibility requirements of disabled people, where these are technically
feasible and costs are reasonable. While DTV platforms have not, in the past,
provided facilities to enable the creation of accessible apps and services, where
new platforms include these facilities the BBC will endeavour to create apps and
services which use them to provide accessible apps and services. Equally, where
the BBC is involved in creating new technology platforms on which our
audience-facing new technological products are built (for example, Project
Canvas) we will work with the platform creators, where possible, to encourage
them to include the accessibility frameworks needed to allow us to create
accessible products on them.
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8.1.4 – Diversity Strategy - Workforce
Key priorities for the Diversity Strategy in relation to employment are:

Developing a pipeline of diverse senior talent for decision-making roles.

Meeting the BBC’s workforce diversity targets by 2012 designed to
ensure that diversity is reflected on and off air. The current disability
workforce targets to be met by December 2012 are:

5.5% for disabled staff overall (4.3% as at 28 February 2010)

4.5% for disabled staff at senior management grades (3.4% as at 28
February 2010)
Examples of initiatives to support meeting these objectives over the last year
are:
Extend: The BBC Academy’s work placement scheme for disabled people
introduced a pilot management strand in March 2010 which will run along side
the standard scheme, making placements available at management level. Extend
won the Personnel Today Award for diversity in the workplace where two-thirds
of participants go on to get jobs within the BBC.
Inspired Ability Event: This event took place last year and was aimed at anyone
with a disability and a proven interest in a media career. Participants had an
opportunity to hear motivational speakers, develop media and transferable skills
in workshops, work on career development plans and meet leaders of industry
work schemes. As well as apply to have an industry mentor for three months.
Jobsite accessibility: The BBC has been working with disabled people to make the
BBC Jobsite more accessible. Accessibility and usability testing has been
undertaken to identify necessary improvements.
Journalism Trainee Scheme and Journalism Talent Pool: Both the Journalism
Trainee Scheme (JTS) and Journalism Talent Pool (JTP) have been set up with the
intention of increasing diversity within BBC Journalism. Whilst both did well in
recruiting from Black and Minority Ethnic backgrounds it is disappointing that
more disabled candidates were not recruited to take part in either programme.
Consequently the BBC is developing strategies to increase the proportion of
disabled people recruited to both schemes and in particular, onto the JTS.
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The Mentoring and Development Programme, designed to diversify the pool of
people competing for roles at senior management level, ring fences 20% of its
places for disabled people and is entering its third year.
Disability Confidence Training for News – this year, successful training for
journalists on disability equality focusing on working with disabled people as
both colleagues and contributors, and portrayal of disabled people through BBC
content was made available online
BBC Academy, rolled out a series of 1 day courses specifically designed to assist
line managers and HR Managers in how to recognise early warning signs of
mental health conditions, how to mange staff with mental health issues, where,
when and how they can seek further advice and help.
The BBC received Silver status (rising 21 spots to 40th place) in the Employer’s
Forum on Disability’s (EFD) Disability Standard.
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9 Action Plan
Action Plan 1: TV licensing function
What is TV Licensing?
‘TV Licensing’ is a trade mark of the BBC and is used under licence by companies
contracted by the BBC to administer the collection of television licence fees and
enforcement of the television licensing system. The majority of administration is
contracted to Capita Business Services Ltd., with cash related payment schemes
contracted to Revenues Management Services Ltd. Over-the-counter services
are provided by PayPoint plc. Marketing and printing services are contracted to
Proximity London Ltd as are public relations and advertising services. The latter
are subcontracted by Proximity to Fishburn Hedges Boys Williams Ltd, Abbott
Mead Vickers BBDO Ltd and PHD Media Ltd. The BBC is a public authority in
respect of its television licensing functions and retains overall responsibility.
What help is already available to consumers who need it?
TVL currently offers a number of ways to enable people with disabilities to
access its services and information. These include the following:

Textphone service

Braille letters and publications

Large print letters and publications

Audio tapes of TVL information

Special email forms (some forms can be sent in electronic format enabling
manipulation to make them accessible)

Typetalk for deaf or speech-impaired people

Account security numbers to enable carers and support workers to
discuss customers’ accounts on cash payment schemes

Liaising with housebound customers to find an appropriate way for them
to make payments, even if Direct Debit or other payment methods are not
available to them
TVL also has a small number of customers with specific requirements which are
taken into account when conducting transactions or communicating with them.
Concessionary TV licences are available for people who are registered as blind
(who receive a 50% discount). For those who live in applicable accommodation
73
such as residential care, where one qualifying factor is that the individual is
disabled, a £7.50 licence has been available from 1 April 2007.
To offer peace of mind to all customers, but particularly those who are or may
feel vulnerable, a password system is available to enable people to confirm the
authenticity of TVL visiting officers.
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The BBC has ensured that there are provisions in the BBC’s contracts with
suppliers to ensure that they must comply with legal requirements and related
policies, including the Disability Discrimination Act and this Disability Equality
Scheme. This is monitored by the BBC TV Licensing Management Team (TVLMT).
How are the public consulted and informed about TVL?
The BBC and TVL engage in regular consultation with a number of key
stakeholders to both gather and share information in relation to meeting the
needs of disabled people. There is regular dialogue with the Royal National
Institute for the Blind (RNIB), Royal National Institute for Deaf People (RNID),
Mencap, Age Concern, Help the Aged and Citizens Advice.
These relationships also relate to consulting on and seeking input on proposed
changes in TVL processes (see section s4.3.1 and for information on
involvement and the mechanisms used to gather information related to disability
and TVL).
TVL’s community relations campaign is designed to target more seldom heard
community groups including people on low incomes and who may be more
vulnerable. By working with national and local stakeholders, the campaign
targets groups and organisations including disabled people and their carers,
who may struggle to pay for their TV licence for financial reasons or who are
unaware of the legal requirement to buy a TV licence. The objective of the
campaign is to raise awareness of the need to have a TV licence and the many
easy ways to pay.
Action Plan aims
That disabled people and their carers experience and receive appropriate and
accessible TVL information, advice and targeted support services
This Action Plan section shows how current TVL activities which are relevant to
the Disability Equality Duty will be maintained and progress monitored. It also
details a series of planned actions which have been identified as necessary
following an audit of current activity and through consultation and involvement
with disabled people. A formal programme of equality impact assessments and
continual involvement with disabled people will inform ongoing review (see
above and also sections 4.3 and 4.4).
NB: Objectives are not in priority order.
Objective 1
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To communicate with disabled people, wherever practicable, in a way that is
accessible and appropriate to facilitate a clear understanding of television
licensing obligations
1 An equality impact assessment (EIA) will be conducted on a representative
sample of TVL communications (mailings, information leaflets and
publications), to examine how accessible and appropriate they are in style,
content, format and dissemination, and the EIA outcome will inform any
further action necessary.
Due date: By end 2007
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Progress: Completed
Lead: Marketing
Evidence/outcomes: TVL communications assessed. Mitigating actions found
to be in place where required.
2 TVL will continue to make our communications available in Braille, large print,
audio and electronic formats.
Due date: Ongoing
Progress: Braille, large print and audio tapes available. TVL are currently
looking at streamlining how they process alternative formats and will
investigate provision of audio CDs.
Lead: Marketing, Customer Relations
Evidence/outcomes: Standard communications will be accessible to a range of
disabled people.
3 TVL will explore options for use of SMS or videophone in addition to existing
textphone service.
Due date: By end 2007
Progress: Completed. Videofone option investigated and found to be costprohibitive. Information from the Digital Switchover Help Scheme suggests
that some deaf people find text messaging more helpful than letters. TV
Licensing will be using SMS services more widely across the business and it
may be that this group finds this service of particular help to them.
Lead: Operations
Evidence/outcomes: Options for introducing additional alternative modes of
communications assessed.
4 TVL will explore further use of SMS as a means of facilitating communication
with all members of the public which may help people with disabilities as
outlined above.
Due date: By end 2010
Progress: Investigations will commence following prerequisite July 2010
upgrades to the TVL database.
Lead: Operations
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Evidence/outcomes: Wider use of SMS messaging throughout the TV Licensing
operation.
5 TVL will review all television trails and publications to examine how best to
represent disabled people.
Due date: By end 2007
Progress: Completed. This is monitored on an ongoing basis
Lead: Marketing
Evidence/outcomes: A systematic review conducted and appropriate
recommendations made.
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6 TVL will explore options for introducing use of subtitling, BSL translation and
audio description as appropriate in television trails.
Due date: By end 2007
Progress: Completed. All options are now in use save for audio description
which was found to be technically unfeasible.
Lead: Marketing
Evidence/outcomes: See above
7 TVL will involve disabled people in an audit of website usability to assess
accessibility (including usability of online purchase facility) and provide a
positive customer experience for all. The use of pictures and Easy Read will be
explored.
Due date: By end 2007
Progress: Two audits of usability have been completed, one in 2008 and one
in 2009. Easy Read pages were reinstated in March 2010.
Lead: Web Programme Manager
Evidence/outcomes: Recommendations coming out of the audit
8 TVLwill work with organisations such as Mencap so that information can be
cascaded to members on TVL.
Due date: Ongoing
Progress: Completed. TVL has regular discussions with key stakeholders
including Mencap
Lead: Communications
Evidence/outcomes: Disabled people within the wider community will have
access to information via representative groups.
9 Relationships will be continued and developed with a range of bodies which
represent or consist of disabled people such as RADAR, the RNIB, the RNID
and Mencap to develop a dialogue on licensing requirements.
Due date: Ongoing
Progress: Actioned. TVL has regular discussions with key stakeholders.
Lead: Communications
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Evidence/outcomes: Partnership working and involvement with disabled
people enhanced and new mutually beneficial relationships will be developed
where possible.
10 TVL will investigate the introduction of a more effective customer satisfaction
review system involving an automated Interactive voice response (“IVR”) and
online customer satisfaction survey on a monthly basis and a quarterly
telephone survey taking place via IVR.
Due date: End 2010
Progress: Investigations to begin in Q4 2009/10.
Lead: Communications
Evidence/outcomes: More effective customer satisfaction survey which
confirms that levels of customer service do not vary by ethnic group.
Drivers/informed by:

DDA 2005

BBC Values: Audiences; Respect

BBC public functions:
Promotion of licensing requirements to the general public
Promotion of licensing requirements to stakeholders
Objective 2
To ensure that all BBC TVL staff and contractors fully understand their duty to
promote disability equality and are active in implementing actions identified
1 Existing and new staff who deal with customers’ queries and complaints will
receive disability equality training and will be expected to put learning into
practice when dealing with customers.
Due date: By end 2008
Progress: Completed for contractors (and built into their induction processes
for new staff) and most BBC TVL staff. TVL Senior Policy Advisor ro laisise with
Diversity group to arrange training for remaining BBC TVL staff..
Lead: Policy, Customer Relations
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Evidence/outcomes: Those staff who have direct contact with disabled people
are better equipped to understand additional needs and relevant staff will
understand the use of specialist equipment.
2 Enquiry officers will receive disability equality training and their code of
conduct will cover the BBC’s expectations of their treatment of disabled
people.
Due date: By end 2008
Progress: Completed. New Enquiry Officers are trained as they join TVL.
Lead: Field Operations
Evidence/outcomes: Visiting officers are aware of the duty and will be better
able to support and understand the diverse and complex needs of disabled
people and carers.
3 Systems will be put into place to record and analyse information on complaints
and comments which are related to disability needs and issues and ensure
that all complaint monitoring is monitored for diversity (including disability).
Due date: By end 2008
Progress: Completed
Lead: Customer Relations
Evidence/outcomes: Information and data collection relating to disability
issues and needs are used by staff to improve services and better understand
needs.
4 Systems will be put into place to formally record requests from disabled
people and their carers.
Due date: By end 2009
Progress: Investigations completed. RMS maintains this system but such a
system would be practically difficult for Capita. This is because customers
contact Capita far less frequently than RMS meaning those who did contact
the BBC would be required to remember passwords for long periods which is
impractical
Lead: Operations
Evidence/outcomes: Formal systems in place where practical
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5 Information from TVL’s customer satisfaction survey will be analysed to
determine whether disabled people’s perception of TV Licensing’s service is
lower than that of non-disabled people.
Due date: By mid 2008
Progress: Completed. No different perception found.
Lead: Customer Relations
Evidence: Information analysed and used where possible to improve services.
Drivers/informed by:

DDA 2005

BBC Values: Audiences; Respect; Working Together

BBC public functions:
Customer relations
Objective 3
To continually review and wherever possible improve or develop service
supports (including technology) to provide maximum access to support and
advice services for all disabled people
1 This Action Plan will be reviewed as necessary in the light of outcomes from
the analysis in action above.
Due date: By end 2007
Progress: Completed
Lead: Policy
Evidence/outcomes: Regular reviews of Action Plan carried out.
2 An equality impact assessment (EIA) will be conducted on the automated
voice-recognition system to assess how well it meets the diverse needs of
disabled people.
Due date: By end 2007
Progress: Completed
Lead: Operations
Evidence/outcomes: Assessment made and outcomes considered.
3 TVL will examine possible options for disabled people to be able to speak to a
customer services officer during non-business hours.
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Due date: By end 2007
Progress: Completed. All practical options were investigated but none were
found to be feasible.
Lead: Operations
Evidence/outcomes: Options noted and assessed.
4 TVL will explore options for introducing a dedicated telephone payment line
for disabled people.
Due date: By mid 2008
Progress: Completed. All practical options were investigated but none were
found to be feasible.
Lead: Operations
Evidence/outcomes: TVL automated voice-recognition systems will meet the
differing needs of disabled people wherever practicable.
Drivers/informed by:

DDA 2005

BBC Values: Audiences; Respect; Working Together

BBC public function: Operations
Objective 4
To develop and maintain a strategic and systematic approach to integrating
disability equality into all TVL activities
1 All policies which are being developed or reviewed (BBC policies and the
relevant contractors’ policies) will be assessed for relevance to the Disability
Equality Duty. EIAs will be carried out where it is considered relevant and
proportionate to meeting the duty.
Due date: Ongoing
Progress: Actioned. Members of the BBC TVL senior management team are
regularly reminded in BBC TVL Equalities Working Group meetings of the need
for EIAs to be conducted on new policies and projects.
Lead: Policy
Evidence/outcomes: See above.
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2 All senior managers will be briefed on the Disability Equality Duty to ensure
that they pay due regard to the needs of disabled people when developing
policy and practice and reviewing TVL’s overall performance.
Due date: By end 2007
Progress: Completed. All senior managers now briefed.
Lead: Policy
Evidence/outcomes: A consistent level of knowledge and awareness among
senior managers who are responsible for policy decisions which may impact
on disabled people.
3 A BBC TVL Equalities Working Group will be set up to monitor compliance and
review future Schemes and Action Plans.
Due date: By end 2007
Progress: Completed. The Group was established in May 2007 and continues
to meet regularly.
Lead: Policy
Evidence/outcomes: Greater clarity around who is responsible for implementing
actions and a mechanism aimed at ensuring consistent monitoring and
systematic reviews
4 Existing BBC (and contractors’) policies and functions which are relevant to the
duty will be prioritised for a programme of equality impact assessments over
three years.
Due date: By end 2009
Progress: Work begins in January 2009.
Lead: Policy
Evidence/outcomes: A systematic process will be in place for ensuring that
existing policies and related practices are screened to determine whether they
impact negatively (or positively) on disabled people.
Drivers/informed by:

DDA 2005

BBC Values: Audiences; Respect; Working Together

BBC public functions: Operations; Policy Development
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Objective 5
To maximise the potential for data and information management systems to
enhance and promote disability equality
1 Any review and subsequent changes to information management (database)
systems will be compliant with the Disability Equality Duty (as well as the Data
Protection Act).
Due date: Ongoing
Progress: Progressed and monitored on a regular basis.
Lead: Data Management
Evidence/outcomes: Data and systems will not impact adversely on disabled
people and opportunities to use information to deliver improvements will be
maximised.
2 TVL will seek to use relevant information sources to inform further reviews of
this action plan (subject to necessary compliance with the Data Protection
Act).
Due date: Ongoing
Progress: Actioned. The updating of this Action Plan has incorporated
information gathered throughout years 1-3 in connection with all of TVL’s
actions.
Lead: Policy
Evidence/outcomes: Updates to the Action Plan are informed by relevant
information and data sets.
Drivers/informed by:

DDA 2005

BBC Values: Audiences; Respect; Working Together

BBC public functions: Operations; Policy Development
Objective 6
To develop and maintain strategic leadership and commitment to the broad
implementation of the Disability Equality Scheme and the TVL Action Plan
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1 A three-year timetable of EIAs will be developed to assess the impact of
current payment methods and processes on disabled people.
Due date: By end 2009
Progress: Progressed and monitored.
Lead: Policy
Evidence/outcomes: Potential adverse impacts will be identified at an early
stage and actions taken where practicable to mitigate.
2 An EIA will be conducted on new (or reviewed) payment policies as part of the
development process and EIA outcomes will inform further action.
Due date: As necessary
Progress: There are currently no new payment methods.
Lead: Policy
Evidence/outcomes: A systematic process will be in place to ensure that
future policies and related practices will be screened at development stage to
determine potential negative (or positive) impacts on disabled people.
Drivers/informed by:

DDA 2005

BBC Values: Audiences; Respect

BBC public function: Operations – Database management
Objective 7
To ensure that all payment methods and processes are accessible and
appropriate for a range of needs
1 TVL will evaluate the usability of the online purchase facility on TVL website
Due date: Performed as required when website is redesigned or significantly
amended.
Progress: Completed in 2008 and repeated following the October 2009
redesign of the TVL website.
Lead: Web Programme Manager
Evidence/outcomes: Access to a wide range of payments options is available.
2 The Cash Easy Entry payment will be extended to all.
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Due date: From 1 April 2007
Progress: Completed
Lead: Operations
Evidence/outcomes: Those who experience more barriers in receiving or
accessing information, such as those with visual impairments and those using
British Sign Language (BSL), are likely to benefit.
3 TVL will liaise with representative groups and organisations to examine how to
provide more information on PayPoint accessibility.
Due date: By end 2007
Progress: Completed. nearest PayPoint with disabled access. The BBC is due to
inform representative groups of this solution.
Lead: Operations
Evidence/outcomes: Phone number available for customers to check disabled
access to PayPoint.
4 TVL will work with disabled people to explore possible alternative ways of
contacting customer services (see objective 1 action 1).
Due date: By end 2007
Progress: Completed.
Lead: Operations
Evidence/outcomes: TVL has worked with representative organisations and is
aware of no current issues.
Drivers/informed by:

DDA 2005

BBC Values: Audiences; Respect

BBC public function: Operations – Payment Processing

Feedback following involvement with disabled stakeholders (ref. CM&F
report)
Objective 8
To ensure a strategic approach to integrating disability equality into all TVL
procurement activities
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1 TVL will continue to impose a contractual obligation on contractors to comply
with legal obligations including the Disability Equality Duty and this Disability
Equality Scheme.
Due date: Ongoing
Progress: Actioned. Ongoing compliance is monitored.
Lead: Operations
Evidence/outcomes: Clear and explicit specifications (and contracts) regarding
the duty to promote disability equality, which will allow for consistent, robust
monitoring of contractors by the BBC.
2 TVL will aim to ensure that clear and explicit reference to disability equality
issues and implications is contained within specifications (where permitted
under the Public Contracts Regulations 2006).
Due date: Ongoing
Progress: Actioned. Disability equality issues and implications have been
included in recent procurement processes.
Lead: Operations
Evidence/outcomes: Potential contractors will be clear about the BBC’s duties
and general approach to disability and will be expected to take these into
account when delivering services.
3 At Invitation to Tender (ITT) stage and preferred bidder stages, all bidders will
be briefed on the Disability Equality Duty and the BBC’s expectations related
to the Disability Equality Duty.
Due date: Ongoing
Progress: Actioned. Disability equality issues and implications have been
included in recent procurement processes.
Lead: Operations
Evidence/outcomes: The BBC will be able to screen bidders at an early stage
to ensure a positive approach to disability in planned service delivery.
4 TVL will clarify to bidders what impact the duty is likely to have on how they
intend to deliver their services if their bid is successful.
Due date: As necessary
Progress: Actioned. Disability equality issues and implications have been
included in recent procurement processes.
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Lead: Operations
Evidence/outcomes: Raised level of awareness among potential bidders.
5 TVL will continue to require all bidders to complete a corporate social
responsibility questionnaire which includes matters relevant to the Disability
Equality Duty.
Due date: Ongoing
Progress: Actioned. Bidders have been required to complete a corporate social
responsibility questionnaire as part of recent procurement processes.
Lead: Operations
Evidence/outcomes: Increased understanding of how to mitigate potential
adverse impacts for disabled people.
6 TVL will monitor contractors’ compliance with the BBC’s imposed contractual
obligation in relation to the disability (and other) equality duties and this
scheme as part of TVL’s standard business practice.
Due date: From now on
Progress: Actioned. Monitoring is active and ongoing.
Lead: Policy
Evidence/outcomes: The BBC will be able to identify where a contractor may
not be complying with duties or expected standards and take action to
address.
Drivers/informed by:

DDA 2005

BBC Values: Audiences; Respect
Action Plan 2: The BBC Trust in relation to certain functions under the BBC
Charter and Agreement (relating to involvement)
What is the BBC Trust?
The BBC Trust is the governing body of the BBC. It is responsible for getting
the best out of the BBC for all licence fee payers. The Trust does this by
assessing the performance of the BBC Executive Board in delivering the BBC’s
services and activities and holding the BBC Executive Board to account for its
performance. In doing so the Trust must ensure that licence fee payers are
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at the heart of its decision-making and that their diverse views and needs are
listened to and heard.
How are the public consulted and informed about the Trust’s activities and
role?
The Trust is required to consult publicly when carrying out a number of its key
regulatory functions, for example when conducting Public Value Tests or Service
Reviews. As it is the Trust’s role to represent all audiences, it is important that
the methods it uses reach the full diversity of licence fee payers.
The Trust is always seeking to develop its understanding and awareness of the
different needs and expectations that disabled people may have. The Trust
regularly draws upon the support and advice of the BBC’s Diversity Centre. . It
also, where relevant, invites organisations who represent disabled people to
stakeholder meetings.
In reviewing the Trust’s objectives and actions within each of the BBC’s three
Equality Schemes, which includes the Disability Equality Scheme, the Trust
commissioned a research agency to carry out an involvement exercise with a
number of organisations representing disabled people. 30 in-depth
interviews amongst disability, gender and race related organisations were
conducted over a four week period with each interview lasting an average of
45-60 minutes. The results of this exercise informed the following action
plan.
Action Plan aims
That disabled people are afforded fair and equal access and maximum
opportunity to participate in all relevant BBC public functions and related
activities, through their increased involvement and representation in the new
BBC Trust
This Action Plan details a series of planned actions which have been identified as
necessary following an audit of current activity in relevant areas and through
consultation and involvement with disabled people. Equality impact
assessments, where appropriate, and the continual involvement with disabled
people and carers will inform ongoing review (see above and also sections 4.3
and 4.4). Each action is cross-referenced with the relevant BBC Charter Article or
Agreement Clause, where relevant to the Disability Equality Duty
Objective 1
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We will operate in a way that means that anyone can have their
say and contribute to our work. Our processes will be accessible
and we will tackle the barriers for audiences wanting to engage
with us.
Action 1- We will ascertain specific needs in advance of all public meetings and
appropriate adjustments will be made to facilitate the involvement of disabled
people and carers.
Due date: Ongoing
Lead: Audiences and Marketing team
Evidence/outcomes: The Trust’s public meetings will be held in venues which
are accessible to all. If requested, they will be supported by a sign language
interpreter, a palantypist or any other dedicated service identified prior to the
date.
Action 2- When handling appeals we will identify and provide the necessary
advice and support required for those people who are unable to submit their
appeal in writing and/or may lack literacy skills or the confidence to submit their
appeal through the usual channels.
Due date: 2010-11
Lead: Editorial Standards team
Evidence/outcomes: Disabled people and carers are not deterred or prevented
from submitting an appeal to the Trust.
Action 3- In relation to BBC Trust Appeal hearings, information on specific needs
will be sought in advance and the appropriate adjustments will be made to
facilitate the full participation of disabled people and carers.
Due date: 2010-11
Lead: Editorial Standards team
Evidence/outcomes: Disabled people and carers are not deterred or prevented
from participating in a BBC Trust hearing.
Action 4- In making arrangements to support the work of the Audience Councils
the Trust will seek to tackle any barriers for disabled people in becoming
members of the Audience Councils.
Due date: 2010-11
Lead: Audiences and Marketing team
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Evidence/outcomes: Over time, the Audience Councils to have a balanced and
representative membership.
Action 5- Audience Councils will ensure that they engage with and positively
encourage the involvement of disabled people and carers.
Due date: 2010-11
Lead: Audiences and Marketing team
Evidence/outcomes: The work of the Audience Councils is informed by their
diverse communities.
Action 6- Ensure our website meets the statutory and BBC’s accessibility
requirements and that all published public documents are screen reader
accessible.
Due date: 2010-11
Lead: Communications team
Evidence/outcomes: An accessible website which disabled people can access
and use easily.
Objective 2
We will be proactive in reaching audiences, including minorities
and seldom heard audiences.
Action 1- For greater success in involving seldom heard groups in the Trust's
work, develop a long term relationship with those groups and organisations who
represent disabled people and carers. For example through the programme of
Trustee interest group lunches.
Due date: 2010-11
Lead: Audiences and Marketing team
Evidence/outcomes: Less ad hoc and more strategic relationship building with
interest groups.
Action 2- Where possible use alternative and more tailored methods for
reaching those disabled people and carers who do not routinely participate, or
are unable to participate in our online consultations.
Due date: 2010-11
Lead: Audiences and Marketing team
Evidence/outcomes: An increase in the participation of Trust Unit activities by
disabled people and carers
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Action 3- Improve the implementation of diversity monitoring of our
consultations, meetings and research to enable us to measure and report on
performance and to inform action planning /review where necessary.
Due date: 2010-11
Lead: Audiences and Marketing team
Evidence/outcomes: Evidence of more consistent diversity information collected
by the Trust.
Action 4- Find ways of ensuring that the Trust’s engagement with opinion
formers and interest groups includes those who can speak for and may influence
disabled people.
Due date: 2010-11
Lead: Communications team
Evidence/outcomes: A broader range of voices the Trust hears from.
Objective 3
In our work we will carefully consider the full range of
contributions and evidence so that our decisions are fair,
independent and impartial and do not discriminate against any
audience groups. To further this we will take action to address
key issues that have emerged, so that, where appropriate and
necessary, we and the BBC Executive deliver change in the
interests of all audiences.
Action 1- When reviewing and then publishing a framework for dealing with BBC
Complaints we will ensure that this is open and accessible to all and there are no
barriers to participation.
Due date: 2010-11
Lead: Editorial Standards team
Evidence/outcomes: Through audience research and customer surveys the BBC
can demonstrate to the Trust that the complaints framework is accessible to
disabled people and carers.
Action 2- We will explore the opportunities for improving the BBC’s Complaints
recording.
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Due date: 2010-11
Lead: Editorial Standards team
Evidence/outcomes: Effective monitoring data that informs the Trust whether
there is a fair representation of disabled groups using the complaints system.
Action 3- During part 2 of the Mystery Shopping project we will investigate
amongst users of the BBC’s complaints system whether there is any aspect in the
way disabled people and carers are treated which is unfavourable and/or unfair.
Due date: 2010-11
Lead: Editorial Standards team
Evidence/outcomes: A complaints system which when used is not unfavourable
or unfair for disabled groups or carers.
Action 4- We will review the BBC’s commitments for access services in relation
to party political broadcasts and referendum campaigns.
Due date: 2010-11
Lead: Editorial Standards team
Evidence/outcomes: The Trust will approve a policy by the Executive Board on
party political broadcasts and referendum campaigns, making sure that the
needs of disabled people have been taken into account.
Action 5- An Equality Impact Assessment will be conducted prior to us
commencing any new policy/project/review which is carried out as part of a
public function.
Due date: 2010-11
Lead: Audiences and Marketing team
Evidence/outcomes: New Trust policies/reviews/projects which result in better
outcomes for disabled people.
Action 6- We will monitor and then report to the Secretary of State in an Annual
Report and Accounts the performance and steps we and the BBC Executive have
taken to fulfil our public sector equalities duties.
Due date: 2010-11
Lead: Trust Unit
Evidence/outcomes: The Trust to receive regular compliance reports from the
BBC Executive. The publication of an Annual Report and Accounts which reports
on the performance of the Trust and BBC Executive in fulfilling its public sector
equalities duties.
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Action 7- We will plan Board and departmental activities that will continue to
facilitate open discussion on diversity and equality issues, for example
awareness training and working lunches with key external and internal guests.
Due date: 2010-11
Lead: Audiences and Marketing team
Evidence/outcomes: Improving and raising the awareness of diversity and
equality issues within the Trust.
Objective 4
We will share our findings and conclusions in a way which is
accessible, open and transparent.
Action 1- We will provide audio and Braille versions of all publicly available
documents on request (within a maximum time limit) and will explore what other
formats might be necessary to meet other specific needs, for example easy read
or pictorial
Due date: 2010-11
Lead: Audiences and Marketing team
Evidence/outcomes: The prompt provision of audio and Braille documents so
that information about Trust activities are accessible to disabled people.
Action 2- When appropriate and where possible we will use alternative methods
for feeding back our findings and decisions to disabled people who routinely do
not or are unable to access our website and its online documents.
Due date: 2010-11
Lead: Trust unit
Evidence/outcomes: Where appropriate, the prompt provision of audio and
Braille documents so that disabled people are not prevented from accessing
and/or participating in the Trust’s activities. In addition evidence of alternative
methods being used.
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Action Plan 3: The BBC in relation to certain functions under the BBC
Agreement
Section (i): The BBC’s obligations in relation to digital switchover (Agreement
Clauses 34–41)
What is digital switchover?
TV services in the UK will go completely digital by 2012. This switchover process
is taking place region by region. The UK’s analogue television broadcast signal
will be switched off and digital terrestrial TV coverage will increase to 98.5%
across the UK.
Digital switchover involves major technological changes across the UK television
broadcast infrastructure which need to be carried out not only by the BBC but
also by all other terrestrial broadcasters including ITV, Channel 4, Five and S4C,
and the transmission companies SDN and National Grid Wireless. Digital
switchover is also about ensuring that people have adapted or upgraded their
televisions and recording equipment to receive digital TV.
What help will be available to consumers who need it?
On confirming the timetable for digital switchover in the UK, the Secretary of
State for Culture, Media and Sport made it clear that the transition to digitalonly broadcasting needed to be an inclusive process and gave a commitment
that people who would find the change to digital TV most challenging would be
supported through a comprehensive help scheme. Under the Charter and
Agreement, the BBC is responsible for delivering the Digital Switchover Help
Scheme. The BBC, through its subsidiary DSHS Ltd, is responsible for managing
the Digital Switchover help Scheme. Eaga plc delivers the service on behalf of the
BBC. For more information on the Help Scheme please visit
http://www.helpscheme.co.uk/
Digital Switchover Help Scheme
To help ensure that everyone can switch more easily to digital TV, the BBC
manages a Digital Switchover Help Scheme for those who need it most.
The Digital Switchover Help Scheme provides practical assistance and support to
people who need it most, specifically people:

75 and over

receiving Disability Living Allowance, Attendance Allowance, Constant
Attendance Allowance or Mobility Supplement
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
registered as blind or partially sighted
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The scheme helps people to select, install and use digital television equipment
and includes:

providing equipment to convert one TV set

help with installation

follow-up support
The scheme costs £40 to take part. However, it is free to those receiving Income
Support, Job Seeker’s Allowance or Pension Credit.
The BBC’s subsidiary DSHS Ltd estimated that across the switchover timeline
between 2008 and 2012, the Help Scheme could be available to 7 million
households.
How are the public being consulted about the Help Scheme?
Each year, DSHS conducts a consultation to develop its understanding of the
people using the Help Scheme to inform its development and delivery. Previous
consultations have focused on what people want from the Help Scheme and its
complexity leading to significant changes in policy development and
communications materials.
During 2009-10, the consultation centred on the extent to which people for
whom the scheme is designed, are using the service to increase their
understanding about users and potential users of the Help Scheme. The
consultation involved:

local community organisations in the geographical regions which had most
recently switched to digital

14 discussion groups and 38 in-depth interviews with people who were
eligible to use the Help Scheme

Observations of the delivery of the Help Scheme at the frontline both in callcentres and during installations of equipment in people’s homes
This consultation has assisted Digital Switchover Help Scheme to understand in
more detail the range of people’s experiences in making the switch to digital, in
particular those people who found it difficult to make the switch and did not use
the Help Scheme. Further exploration of this particular group has pointed to
possible explanatory factors including overly complex information about the
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Help Scheme, the impact of social isolation on awareness of the Help Scheme
and barriers to the Help Scheme highlighting accessibility issues, particularly for
deaf, hearing impaired and blind and visually impaired people. These issues will
be an area of focus for the next 12 months.
How are the public being informed about digital switchover?
Digital UK is the independent, not-for-profit organisation leading the process of
digital switchover in the UK. Digital UK provides impartial information on what
people need to do to prepare for the move to digital, and when they need to do
it.
Digital UK was set up at the request of the Government to manage all
communications with the public regarding digital switchover. Digital UK works
closely with the Department for Culture, Media and Sport (DCMS) and the
Department for Business Innovation and Skills (BIS), as well as the regulator
Ofcom, to prepare the UK for the changes.
Digital UK is owned by the UK’s public service broadcasters (BBC, ITV, Channel 4,
Five, S4C and Teletext) and the transmission companies SDN and National Grid
Wireless. Digital UK works with digital TV platform operators, equipment
manufacturers, installers, retailers, rental companies and consumer groups to
coordinate the technical rollout of digital television across the UK.
Digital UK is responsible for informing the public in general about the digital
switchover process, and the service the Help Scheme offers.
Digital UK delivers a community outreach programme through its contract
with Digital Outreach Ltd. which is a partnership between Age Concern, Help
the Aged, Community Service Volunteers and Collective Enterprises Ltd., to
deliver designed to provide advice and guidance to people who would not
have access to the Help Scheme but who would like some assistance or
advice in making the switch to digital television. The community outreach
programme works with voluntary and community sector organisations
switchover region by switchover region enabling local organisations to
support older and disabled people by providing information and speakers for
events or drop-ins, training volunteers and developing a network of help and
advice. Digital Outreach Ltd. is currently working in the ITV regions covering
The Borders, West Country, Granada and Wales.
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(See also section 4.3.3 for information on involvement and a range of
mechanisms already in place which aim to gather information related to
disability and digital switchover.)
NB: Because of the collaborative nature of the digital switchover project,
involving Digital UK, the DCMS, BERR and Ofcom, the BBC does not have control
over all of the actions in its Action Plan. Where this is the case, the BBC will meet
its commitment by working closely with the relevant organisation and will use its
best endeavours to ensure that the actions are achieved.
Action Plan aims
That disabled (and older) people experience or receive appropriate and
accessible digital switchover and Digital Switchover Help Scheme information,
advice and targeted support throughout the entire transition period
This Action Plan, section I, (parts A and B), shows in detail how current digital
switchover activities which are relevant to the Disability Equality Duty will be
maintained and progress monitored. It also details a series of planned actions
which have been identified, including those in relation to the Help Scheme,
through consultation and involvement with disabled people. Equality impact
assessments, where appropriate, and continual involvement with disabled
people have informed and will continue to inform ongoing review (see also
above and sections 4.3 and 4.4). It also details a series of planned actions which
have been identified in relation to:

Managing and delivering the Help Scheme – set out in Part A,

Informing the public about digital switchover and the Help Scheme – set out
in Part B.
This Action Plan is split into two parts. The first (Part A) sets out the objectives
and associated actions which the BBC, (through its subsidiary DSHS Ltd.) has
identified in managing the Help Scheme. The second half (Part B) focuses on BBC
and Digital UK activity highlighting their objectives and associated actions as
they relate to the Disability Equality Duty.
In particular, the Action Plan (parts A and B) sets out how the BBC, and its
subsidiary DSHS Ltd, and Digital UK will work together (see also section 4.3.3)
and specifies:

The ways in which disabled people have been involved in development of the
digital switchover (DSO) communications and activities.
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
Methods for assessing the impact of DSO and Help Scheme policies and
practices or proposed policies and practices on disabled people.

The steps which Digital UK is taking towards the fulfilment of the Disability
Equality Duty in respect of equal access to information and support through
the DSO programme.

Arrangements for gathering information on the effect of DSO policies and
practices on disabled people and the arrangements for information usage to
assist the BBC in complying with the Disability Equality Duty.

How Digital UK and the BBC will work together to ensure that the BBC has
sufficient information to comply with the Disability Equality Duty.

How policies which aim to ensure that disabled organisations and individuals
are actively engaged with DSO have been shared with the BBC and will be
forwarded and shared as they are developed.
Note: this Action Plan reflects future activity only and does not reference where
activities are well established and ongoing.
Part A: BBC Actions relating to the Digital Switchover Help Scheme
Objective 1
To ensure that the Help Scheme engages all eligible people in need of
assistance, and supports them through their customer journey.
1 DSHS to initiate a 'Transformation Plan' in identified areas for improvement to
the customer journey.
Due date: 2010-11
Lead: Operations Director
Evidence/outcomes: Whole service reviewed from the customer’s perspective
and any barriers to using the service identified and addressed.
2 DSHS to deliver a Scheme in line with the current Code of Service Standards
and to continually develop the Code of Service Standards.
Due date: 2010-11
Lead: Operations Director / Head of Customer Strategies
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Evidence/outcomes: Fully accessible and high quality service, informed by
service users and measured for quality and for access to the service itself.
3 DSHS to deliver outreach activity to identify and engage the 'hard to reach' with
specific strategies to reach diverse populations including older people, and
those with disabilities and learning disabilities.
Due date: 2010-11
Lead: Head of Customer Strategies
Evidence/outcomes: Greater awareness of the Help Scheme particularly among
those it is designed to assist and who may be in greater need of help
4 DSHS to focus on improving the Help Scheme experience for eligible people
from the following access groups (where there are known access issues):
people with mental health issues, people with learning difficulties, blind and
visually impaired people and, deaf and hearing impaired people.
Due date: 2010-11
Progress: Ongoing
Lead: Operations Director
Evidence/outcomes: Fully accessible service available to anyone who uses the
Help Scheme
5 DSHS to collaborate with switchover programme partners to produce
marketing and publicity that engages people in need of assistance.
Due date: 2010-11
Lead: Head of Marketing
Evidence/outcomes: Fully accessible publicity material which informs more
people about the service the Help Scheme offers
6 DSHS to develop regional plans which enrol the support of local delivery
partners in delivering the Help Scheme. DSHS to develop action plans in
response to 'non-responder' analysis.
Due date: 2010-11
Lead: Head of Customer Strategies
Evidence/outcomes: Working in partnership with local communities to help
engage potential users of the Help Scheme
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7 DSHS to work with Department for Work and Pensions to develop an approach
to better identify and prioritise those in need of assistance.
Due date: 2010-11
Lead: Finance Director
Evidence/outcomes Ensures the Help Scheme reaches everyone who might need
the service
Drivers/informed by:

DDA 2005

Government White Paper

BBC Values: Audiences; Respect
Objective 2
To ensure that all public Help Scheme information is appropriate,
sensitive, and accessible for disabled people and people with
learning disabilities.
1 DSHS and DUK to ensure that all information and forms of communication are
available in an appropriate range of accessibility formats and language options.
To provide a personalised response where appropriate.
Due date: 2010-11
Lead: Head of Marketing
Evidence/outcomes: Fully accessible Help Scheme which people are able to
engage with in a way that meets their requirements
2 DSHS to work with DUK to ensure a basic minimum standard of accessible
communications is in place across all media platforms.
Due date: 2010-11
Lead: Head of Marketing
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Evidence/outcomes: Communications targeted to potential and / or users of the
Help Scheme are fully accessible
3 DSHS to ensure that methods of communicating and transacting with the
Scheme are available in a range of format and language options.
Due date: 2010-11
Lead: Operations Director / Head of Marketing
Evidence/outcomes: Fully accessible Help Scheme which people are able to
engage with in a way that meets their requirements
4 DSHS to deliver outreach activity for communities that may need additional
support in engaging with the Scheme e.g. deaf club roadshows.
Due date: 2010-11
Lead: Head of Customer Strategies
Evidence/outcomes: Information about the Help Scheme reaches everyone who
might need it
Drivers/informed by:

DDA 2005

Government White Paper

BBC Values: Audiences; Respect
Objective 3
To involve and consult with eligible people and their
representative bodies including older people, and those with
disabilities and learning disabilities in the delivery and
development of the Help Scheme.
1 DSHS to understand the needs of people eligible for the Help Scheme
through regular research and annual consultations which feeds insights into
the continual improvement of Help Scheme and removes barriers that
prevent eligible people receiving assistance.
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Due date: 2010-11
Lead: Head of Customer Strategies
Evidence/outcomes: Ofcom/Digital UK Tracker results, consultation reports.
People who use the service are able to influence its further development and
improvement
2 DSHS to promote the involvement of eligible people in delivering the Help
Scheme.
Due date: 2010-11
Lead: Operations Director
Evidence/outcomes: People who use the service are able to influence its further
development and improvement
3 To ensure that learning from customer satisfaction, complaints and other
feedback is fed into the continual improvement of the Help Scheme.
Due date: 2010-11
Lead: Complaints and Appeals Manager
Evidence/outcomes: People who use the service are able to influence its further
development and improvement
4 DSHS to deliver outreach activity for communities that may need additional
support in engaging with the Scheme e.g. deaf club roadshows.
Due date: 2010-11
Lead: Head of Customer Strategies
Evidence/outcomes: People who use the service are able to influence its further
development and improvement
Objective 4
To gather and use information effectively in order to monitor and
assess the impact of current and planned operational processes,
policies, and practices on older people, and those with disabilities
and learning disabilities.
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1 DSHS to ensure that Equality Impact Assessments (EIAs) are used to assess any
planned operational processes, policies, and practices.
Due date: 2010-11
Lead: Business Manager
Evidence/outcomes: DSHS develops operational processes, policies and practices
which result in better outcomes for disabled people.
2 DSHS to conduct regular audits / reviews of the customer journey to ensure
that all activities are accessible to older people, and disabled people.
Due date: 2010-11
Lead: Operations Director / Head of Customer Strategies
Evidence/outcomes: Any barriers to disabled people accessing the services
identified and addressed
3 DSHS to conduct evaluations for each region as it closes to ensure that all
activities have successfully engaged older people, and those with disabilities.
Due Date: 2010-11
Progress: Complete
Lead: Business Manager
Evidence/outcomes: Evaluations of delivery of the Help Scheme in each region
include consideration of successful engagement of disabled people
4 DSHS and DUK to track and respond to Awareness and Understanding data by
disabled people.
Due Date: 2010-11
Progress:
Lead: Head of Marketing
Evidence/outcomes: Any differentials between in levels of awareness and
understanding of switchover on the basis of disability are identified and
addressed
Drivers/informed by:

DDA 2005
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
Government White Paper

BBC Values: Audiences; Respect
Objective 5
To ensure effective internal monitoring and evaluation of the
Help Scheme single equality DES outcomes.
1 Quarterly DSHS Equality Working Group meetings to track performance and
develop strategies to achieve the Help Scheme DES outcomes.
Due date: 2010-11
Progress:
Lead: Business Manager
Evidence/outcomes: Regular forum to discuss equality issues including
performance against the Disability Equality Scheme
2 DSHS represented on the BBC Finance Division Equality and Diversity Group.
Due date: 2010-11
Progress:
Lead: Complaints and Appeals Manager
Evidence/outcomes: DSHS’s commitments under the disability equality duty
form an integral part of the BBC’s wider Diversity Strategy
3 The BBC and Digital UK DSO team to conduct Action Plan annual reviews. A
formal scheme review will go to the BBC Executive Board and the BBC Trust for
approval.
Due date:
Lead: Business Manager
Evidence/outcomes: Compliance with the Disability Equality Duty maintained
Drivers/informed by:

DDA 2005

Government White Paper

BBC Values: Audiences; Respect
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Objective 6
To ensure that DSHS providers are promoting disability equality,
through their responsibilities under contract.
1 DSHS exercises due diligence to ensure that Equality duties and considerations
are fully integrated into any future procurement decisions (including eaga subcontracts).
Due date: 2010-11
Lead: Contracts Manager
Evidence/outcomes: Contractors delivering services on behalf of DSHS promote
disability equality
2 To ensure that all contracted staff fully understand their duty to promote
equality legislation and are active in implementing actions identified. DSHS to
focus on improving installer understanding of how to best serve customers with
disabilities.
Due date: 2010-11
Lead: Contracts Manager
Evidence/outcomes: Contractors delivering services on behalf of DSHS promote
disability equality
3 To ensure that DSHS providers have in place mechanism that allow them to
demonstrate their performance with regard to Equalities.
Due date: 2010-11
Lead: Contracts Manager
Evidence/outcomes: Contractors delivering services on behalf of DSHS promote
disability equality
4 DSHS to ensure that Equality Impact Assessments (EIAs) are used to assess any
planned operational processes, policies, and practices delivered by DSHS
providers.
Due date: 2010-11
Lead: Business Manager
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Evidence/outcomes: DSHS develops operational processes, policies and practices
which result in better outcomes for disabled people.
Drivers/informed by:

DDA 2005

Government White Paper

BBC Values: Audiences; Respect
Objective 7
To ensure that the Help Scheme is feeding into, and learning from best practice.
1 DSHS to encourage the digital television supply chain to develop technology to
support older people, and disabled people.
Due date: 2010-11
Lead: Operations Director / Lead Technologist
Evidence/outcomes: Development of the Help Scheme is informed by best
practice on equality and diversity, including disability equality
2 DSHS to seek external opportunities for knowledge and inspiration around
equality best practice and to share its own success within the BBC and externally
where appropriate.
Due date: 2010-11
Lead: All
Evidence/outcomes: Development of the Help Scheme is informed by best
practice on equality and diversity, including disability equality
3 DSHS to work with BBC Diversity Centre to gain advice and input into the creation
and monitoring of the DES.
Due date: 2010-11
Lead: Business Manager
Evidence/outcomes:
4 DSHS to participate in Finance Division Equality & Diversity action group activities.
Due date: 2010-11
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Lead: Complaints and Appeals Manager
Evidence/outcomes: Development of the Help Scheme is informed by best
practice on equality and diversity, including disability equality
NB: Agreement Clauses 40 and 41: These provisions have been assessed by the
BBC and have been found to be public functions not relevant to the general duty.
Part B: BBC Actions relating to Digital UK
Objective 1
To assist the “most vulnerable beneficiaries” (older and disabled people) to make
the switchover to digital TV
1 The BBC to continue to work with DCMS, BIS and Digital UK on the Digital
Switchover Help Scheme.
Due date: 2010-2011
Progress: Ongoing
Lead: BBC Chief Operating Officer and BBC Director of Marketing,
Communications & Audiences, working alongside Digital UK and other
industry partners
Evidence/outcomes: Older and disabled people entitled to assistance to
benefit from the Help Scheme. Measured by the BBC’s subsidiary DSHS Ltd
through contractual service level agreements.
2 BBC Digital UK board members monitor and influence Digital UK activities and
ensure that the needs of disabled people and carers (and older people) are
being addressed.
Due date: 2010-2011
Progress: Ongoing. BBC representatives meet quarterly with Digital UK to
monitor progress on equality and diversity, including disability equality.
Lead: BBC Finance Director
Evidence/outcomes: Digital UK information is accessible and includes options
for receiving digital TV.
3 BBC representatives will attend Digital UK’s quarterly Finance & Marketing
Committee (F&MC) meetings to drive forward a strategy aimed at ensuring a
consistent and systematic approach to assisting disabled people.
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Due date: 2010-2011
Progress: Ongoing
Lead: BBC Finance Director
Evidence/outcomes: F&MC operates as a formal arena to ensure a consistent
approach to assisting disabled people.
4 The BBC to advise on minimum standards for ensuring accessibility and
inclusiveness for the most vulnerable groups.
Due date: 2010-2011
Progress: BBC representatives meet quarterly with Digital UK to monitor
progress specifically on equality and diversity, including disability equality.
Lead: BBC Finance Director
Evidence/outcomes: Policy on agreed minimum standards in place. The BBC to
forward accessibility communications policy.
5 The BBC will attend BIS Usability Group meetings and use these to encourage
the digital television supply chain to give full technological consideration to
providing a solution for those dependent on environmental controls and to
ensure that relevant information is promoted appropriately to disabled
audiences.
Due date: 2010-2011
Lead: BBC Finance Director
Evidence/outcomes: The BBC regularly attending Usability Group meetings
and contributing advice regarding needs of disabled users.
6 Ongoing engagement of Digital UK Regional Managers with disability relevant
organisations including consumer groups, charities (including disabled
groups), volunteer groups and social services departments within local
authorities.
Due date: Region-specific start dates according to regional rollout of DSO:
2010-2011
Progress: Digital UK has contracted Digital Outreach Limited (a consortium
made up of Help the Aged, Age Concern, Community Service Volunteers and
Collective Enterprises Ltd) to work in regions undergoing digital switchover
until the end of the switchover programme. Digital Outreach Limited will map
the demographics and community infrastructure of each region in order to
111
develop a strategy for meeting people’s needs in partnership with local
community organisations and volunteers.
Lead: BBC Finance Director
Evidence/outcomes: Outcomes included in Digital UK’s current reporting
procedures.
Drivers/informed by:

DDA 2005

Government White Paper

BBC Values: Audiences; Respect
Objective 2
To ensure that the transition to digital-only broadcasting is a fully inclusive
process
1 Through attending its quarterly F&MC meetings, the BBC will monitor Digital
UK’s general and specific marketing for inclusiveness and accessibility and
request improvements as and when necessary, for example following
evaluation of Granada communications.
Due date: 2010-2011
Progress: Ongoing. BBC representatives meet quarterly with Digital UK to
monitor progress on equality and diversity, including disability equality.
Lead: BBC Finance Director
Evidence/outcomes: Digital UK consistently produces inclusive and accessible
communications on digital switchover (copies supplied to the BBC).
Ofcom/Digital UK Tracker results. Lessons learned from Granada switchover.
Drivers/informed by:

DDA 2005

Government White Paper

BBC Values: Audiences; Respect
Objective 3
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To ensure that all digital switchover and Help Scheme related information and
modes of communication are appropriate for the target audience and are fully
accessible
1 Digital UK actively engages with relevant disabled organisations and disabled
people through its ongoing work with a number of groups such as Consumer
Expert Group, RNIB, RNID, TAG, Wireless for the Bedridden, SENSE, Age
Concern, Help the Aged, Ofcom Consumer Panel, and Ofcom Advisory
Committee on Older and Disabled People.
This work may involve research from time to time and any findings will be
used to inform further review of this Action Plan.
Due date: 2010-2011
Progress: Ongoing. BBC representatives meet quarterly with Digital UK to
monitor progress on equality and diversity, including disability equality.
Lead: BBC Finance Director
Evidence/outcomes: Ofcom/Digital UK Tracker results and Churchill Minty &
Friend report feedback.
2 At F&MC quarterly meetings, the BBC and Digital UK will monitor the spectrum
of digital switchover and Help Scheme communications to check for
appropriate style and format plus relevant content.
Due date: 2010-2011
Progress: Ongoing. BBC representatives meet quarterly with Digital UK to
monitor progress on equality and diversity, including disability equality.
Lead: BBC Finance Director
Evidence/outcomes: People can contact Digital UK in various ways, for
example by telephone, textphone, mail, email, through local roadshows and
Digital Outreach advice points.
Information on specialist resources for disabled people is provided.
3 The BBC will work with Digital UK to ensure basic minimum standards of
accessible communications which are appropriate to different media platforms
as some standard routes may present barriers to some groups, for example
subtitling and audio description.
Due date: 2010-2011
Progress: Ongoing
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Lead: BBC Finance Director
Evidence/outcomes: Policy on standards in place. Code of Service Standards.
4 The BBC will work with Digital UK to provide, wherever practicable, specific
forms of communication which are relevant and appropriate for relevant
audiences, for example those with sensory impairments or learning
difficulties.
Due date: 2010-2011
Progress: Ongoing.
Lead: BBC Finance Director
Evidence/outcomes: Identified target groups receiving information in specific
formats, where practicable.
5 The BBC will attend BIS Usability Group and encourage the development of a
platform-neutral information resource which signposts people to specialist
equipment and functions, such as compatibility with audio description or
subtitling.
Due date: 2010-2011
Progress: Ongoing. Lead: BBC Finance Director
Evidence/outcomes: Specialist information is available in Digital UK
communications to advise on access functions and services, for example
audio description.
Digital UK provides signposts to relevant information on its website such as
Ricability consumer reports.
Objective 4
To involve disabled people in the planning and rollout of digital switchover and
in the planning and rollout of the Help Scheme
1 Regular meetings of the Usability Action Plan group will take place led by BIS.
Due date: 2010-2011
Lead: BBC Finance Director
Evidence/outcomes: BIS Usability Action Plan Group Meetings.
2 The BBC will ensure that the findings of the Churchill, Minty & Friend
consultation report are shared with Digital UK.
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Progress: Complete
Lead: BBC Finance Director
Evidence/outcomes: Digital UK has the Churchill Minty & Friend consultation
report.
3 Outcomes of the consultation and involvement with disabled people
conducted in order to shape the Help Scheme, also to inform Digital UK’s
communications strategy.
Due date: 2010-2011
Progress: Completed annually
Lead: Digital Switchover Help Scheme
Evidence/outcomes: Digital UK communications strategy reflects the
outcomes of the consultation and involvement with disabled people.
Communications by Digital UK and potential Help Scheme users are fully
accessible.
4 Digital UK and Ofcom monthly research into disabled people’s attitudes,
awareness and understanding of digital switchover and the Help Scheme will
be used to assess the impact of the Digital UK communications strategy.
Due date: 2010-2011
Progress: Ongoing. BBC representatives meet quarterly with Digital UK to
monitor progress on equality and diversity, including disability equality.
Lead: Digital UK
Evidence/outcomes: Ofcom/Digital UK Tracker results. Digital UK
communications evolve during the digital switchover programme.
5 Digital UK regional managers to meet with local charity and volunteer
organisations and local authorities.
Due date: 2010-2011
Progress: Digital UK Regional Managers are in post 18 months prior to DSO1
in a region. Digital UK has contracted Digital Outreach Limited (a consortium
made up of Help the Aged, Age Concern, Community Service Volunteers and
Collective Enterprises Ltd) until the end of the switchover programme. Digital
Outreach Limited will map the demographics and community infrastructure of
each region in order to develop a strategy for meeting people’s needs in
partnership with local community organisations and volunteers.
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Lead: Digital UK
Evidence/outcomes: Digital UK regional manager meetings with local charity
and volunteer organisations and local authorities taking place.
Drivers/informed by:

DDA 2005

Government White Paper

BBC Values: Audiences; Respect
Objective 5
To gather and use information effectively in order to monitor and assess the
impact of current and planned DSO policies and practices with regard to
disability equality
1 Digital UK will use this research to review which groups may need more
targeted digital switchover and Help Scheme communications.
Due date: 2010-2011
Progress: Ongoing. BBC representatives meet quarterly with Digital UK to
monitor progress on equality and diversity, including disability equality.
Lead: Digital UK
Evidence/outcomes: Ofcom and Digital UK publish consultation reports on
their websites.
2 Digital UK and Ofcom Advisory Committee on Older and Disabled People
(ACOD) will carry out digital switchover and the Help Scheme qualitative
research and focus groups with disabled people.
Due date: 2010-2011
Progress: Ongoing. BBC representatives meet quarterly with Digital UK to
monitor progress on equality and diversity, including disability equality.
Lead: Digital UK
Evidence/outcomes: Ofcom/Digital UK Tracker reports are published quarterly
and available on both organisations’ websites.
3 Analyse and evaluate findings from Granada switchover to capture learning
and report back to the Diversity Board, BBC Executive Board and BBC Trust.
Due date: Analysis of Granada findings by end Quarter 3 2010
116
Lead: Digital UK
Evidence/outcomes: Recommendations from Granada demonstrably
incorporated into future digital switchover communications.
Objective 6
To ensure effective internal monitoring and Disability Equality Scheme outcomes
evaluation
1 The BBC will monitor and update this Action Plan and review as necessary, for
example following the Granada evaluation.
Due date: 2010-2011
Lead: Digital UK
Evidence/outcomes: Action Plan is regularly reviewed and updated.
2 The BBC and Digital UK DSO team will conduct Action Plan annual reviews, and
the three-yearly formal scheme review will go to the BBC Executive Board and
the BBC Trust for approval.
Due date: 2010-2011
Progress: Ongoing
Lead: Digital UK
Evidence/outcomes: Formal reviews approved by responsible team and
reports available to the BBC and Digital UK.
3 The BBC will set up internal mechanisms for progress monitoring and
reporting to the Diversity Board, BBC Executive Board and BBC Trust.
Due date: 2010-2011
Progress: Ongoing
Lead: Digital UK
Evidence/outcomes: Clear roles and responsibilities are documented for the
internal team.
Drivers/informed by:

DDA 2005

Government White Paper

BBC Values: Audiences; Respect

Recommendations following involvement with disabled stakeholders (ref.
CM&F report)
117
Action Plan 3: The BBC in relation to certain functions under the BBC
Agreement
Section (ii): Other functions of the BBC in relation to certain functions under
the BBC Agreement (Agreement Clauses 12, 59–60, 74, 81)
What is the BBC Agreement?
In addition to the Royal Charter, the BBC has entered into a Framework
Agreement with the Secretary of State for Culture, Media and Sport. This
Agreement deals with a number of important matters (see page 10 and Annex
for more detail).
How are the public consulted and informed about the BBC Agreement?
During previous public consultation connected with the transition from the BBC
Governors to the BBC Trust arrangements, disabled licence fee payers were given
the opportunity to meet with Governors and tell them at first hand what they
thought about the proposed Charter and Agreement.
Action plan aims
That disabled people and audiences are afforded fair and equal access and
maximum opportunity to participate in all relevant BBC public functions and
related activities, through ensuring full access to all public information and
involvement activities
This Action Plan (section ii) details a series of planned actions which have been
identified as necessary following an audit of current activity in relevant areas and
through consultation and involvement with disabled people. Equality impact
assessments, where appropriate, and continual involvement with disabled
people will inform ongoing review (see above and also section 4.3). Each action
is cross-referenced with the relevant Agreement Clause, where relevant to the
Disability Equality Duty.
Objective 1
To anticipate and wherever practicable meet the diverse needs of disabled
people who access or seek to access UK public services
1 The BBC will continue to meet its targets for delivering access services on
qualifying broadcast television programmes, which are as follows:
• 100% subtitling of all programmes on our main channels
118
• 10% audio-description on qualifying services rising to 20% by 2016
• 5% signing
Due date: Ongoing
Lead: Wilf White
Evidence/outcomes: BBC Access Services target met (TV).
Objective 2
To anticipate and meet communication needs of those with sensory impairments
in order to ensure their access to UK services and to related information and
consultation activities (as required by Ofcom’s code)
1 The BBC will ensure compliance with the Ofcom code (relating to provision for
the deaf and visually impaired) as it is set out in the BBC Charter (ref.
Agreement Clauses 59–60).
Due date: Ongoing
Progress: Ongoing
Lead: Wilf White
Evidence/outcomes: Compliance monitoring report available.
2 The BBC will ensure that any public documents relating to the Ofcom code and
the BBC’s implementation of that code will be made available in accessible
Braille and audio tape on request (within a maximum time limit) (ref.
Agreement Clauses 59–60).
Due date: Ongoing
Progress: Ongoing
Lead: Wilf White
Evidence/outcomes: Mechanisms in place for those with sensory impairments
to request relevant accessible documents.
3 The BBC will seek to identify in advance of meetings or consultations related to
the BBC’s implementation of the Ofcom code any specific requirements or
support needs and will make appropriate adjustments in order to facilitate full
participation by disabled people – whether members of BBC staff, members of
Ofcom’s staff or representative persons (ref. Agreement Clauses 59–60).
119
Due date: Ongoing
Progress: Ongoing
Lead: Wilf White
Evidence/outcomes: Relevant meetings are held in fully accessible venues,
meetings are supported by a sign language interpreter and, if requested, a
palantypist or any other specialist services identified prior to the date.
Drivers/informed by:

DDA 2005

BBC Values: Audiences; Respect; Working Together

Ofcom code
Objective 3
To ensure that specific financial information is fully accessible, through meeting
the various communication needs of all disabled people
1 The BBC will ensure that copies of the Annual Report and Accounts will be
provided on request to disabled persons in Braille or audio versions (within a
maximum time limit) (ref. Agreement Clause 74).
Due date: Ongoing
Progress: Ongoing
Lead: BBC Communications, Diversity Centre
Evidence/outcomes: Evidence of prompt provision of audio and Braille
versions of the Annual Report and Accounts (when requested) and additional
alternative formats (as applicable), to facilitate full and equal access to such
public documents for disabled persons and carers.
Drivers/informed by:

DDA 2005

BBC Values: Audiences; Respect
Objective 4
To ensure that all disabled people have equal access to specific public
information announcements
120
1 The BBC will seek to ensure that all access service commitments are fully met
when broadcasting or otherwise distributing announcements concerning
defence and emergency arrangements (ref. Agreement Clause 81).
Due date: Ongoing
Progress: Ongoing
Lead: Wilf White (Television) and Seetha Kumar (Online)
Evidence/outcomes: Broadcast distribution announcements concerning
defence and emergency arrangements are fully accessible and clearly
understood by all groups.
Drivers/informed by:

DDA 2005

BBC Values: Audiences; Respect; Working Together
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Annex
The BBC’s public functions
A TV Licensing
1 Promotion of licensing requirements: Communication with general public
2 Promotion of licensing requirements: External stakeholder management
3 Customer relations
4 Operations: General
5 Operations: Policy development (which covers new and existing policies)
6 Operations: Database management
7 Operations: Payment processing
8 Operations: Issuing licences
9 Enforcement: Visiting and prosecution
10 Procurement
B The BBC Trust in relation to certain functions under the BBC Charter and
Agreement
The following functions of the BBC Trust are public functions for the purpose of
this Scheme.
Charter

Article 22: The Trust has responsibility for:
• BBC stewardship of the licence fee revenue and its other resources.
• Upholding the public interest within the BBC, particularly the interest of
licence fee payers.

Article 23: General duties of the Trust in exercising its public functions.
Article 23 does not create self-standing public functions but will be
relevant to the BBC’s exercise of its functions so far as these are public
functions for the purposes of the Scheme.

Article 24
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• Assessing the performance of the Executive Board and holding it to
account.
• The process of issuing service licences for BBC services and monitoring
compliance with them.
• Holding the Executive Board to account for the BBC’s compliance with
programme standards, quotas and the law.
• Setting the framework within which the BBC should handle complaints.
• Conducting investigations into any activity of the BBC which it suspects does
not comply with the requirements supervised by the Trust.
• Commissioning value-for-money investigations into specific areas of BBC
activity.
• Setting the BBC’s fair trading policy and holding the Executive Board to
account for compliance with it.
• Setting an approvals framework within which the Trust will assess proposals
from the Executive Board for new services, significant changes to existing
services, commercial services and other activities.
• Ensuring that arrangements for collection of the licence fee are efficient,
appropriate and proportionate.

Article 25: The Trust must adopt and publish Protocols setting out a
detailed framework within which the Trust will discharge its functions.

Article 26: Protocols must require the Trust to seek the views of, and
engage with, licence fee payers and set out how it will do so. The Trust
must consult publicly before adopting any protocol under Article 27.

Article 27: Protocols on openness and transparency.

Article 39 (7) and (8): The Trust shall set out in a Protocol details of how
Audience Councils are to be set up, run and recruited. The Trust may
make whatever arrangements it considers appropriate for supporting the
work of the Audience Councils.

Article 45
• The Trust must consider the annual report and statement of accounts
prepared by the Executive Board and prepare a commentary.
• The Trust must transmit the report and accounts and its commentary to the
Secretary of State.
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Agreement

Clause 5: The Trust shall prepare purpose remits for each of the six public
purposes. The Trust shall consult publicly about these. The Trust must
keep these under review and may amend them.

Clause 11 (6) : The Trust may approve the launch of new UK public
services, or the termination of or material change to the nature of existing
services.

Clause 15: In performing its functions in relation to the UK public
television services, the Trust shall have regard to the purposes of public
service television broadcasting set out in section 264(4) of the
Communications Act 2003.

Clause 18: The process of determining which activities of the BBC should
be covered by a service licence and how they should be covered.

Clause 19: Before issuing a service licence, the Trust must have consulted
publicly.
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
Clause 20: The Trust must review service licences periodically and at least
once every five years. The Trust must publish information on its intended
programme of reviews. In reviewing a service licence, the Trust must
consult publicly. The Trust should undertake a review whenever the public
interest demands it. The public function does not extent to the content of
the service licences.

Clause 21 (5) (in relation to the BBC’s Statements of Programme Policy):
The Trust must monitor the BBC’s performance in carrying out the
proposals. Each annual report presented by the BBC shall contain a report
on the performance of the BBC in this area.

Clause 22 (3): It is the Trust’s responsibility to ensure that the principles
which underlie the treatment of services are, where relevant, applied to
non-service activities in a way which the Trust considers appropriate to
the circumstances.

Clause 25 (2): The Trust must judge when the Public Value Test must be
applied before a decision is taken to make any significant changes to the
UK public services.

Clause 26 (4), (5) and (6): The Trust must consider the outcome of the
public value assessment and the market impact assessment and reach
provisional conclusions regarding the proposed change. The assessments
must be published. The Trust must consult about its provisional
conclusions.

Clause 41: The Trust must provide the Secretary of State with an annual
report.

Clause 42: The Trust shall secure the efficient use of the radio spectrum
available for use by the BBC or its contractors.

Clauses 43–46: The Trust must approve guidelines to secure the
appropriate standards, specifically in relation to accuracy and impartiality;
fairness; programme standards; and news and current affairs.

Clause 48: The BBC must include party political broadcasts and
referendum campaign broadcasts. The Trust must determine which of the
UK public broadcasting services are to include these and the basis on
which and the terms and conditions subject to which such broadcasts are
to be included.
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
Clause 50: The Trust must impose on the Executive Board the
requirements it considers appropriate in relation to programming for the
nations and regions. The Trust must consult Ofcom on these proposals
and must not make certain changes without the agreement of Ofcom.

Clause 58: The Trust must impose requirements on the Executive Board in
relation to the production of radio programmes and material for online
services.

Clause 61: The Trust shall require the Executive Board to draw up and
from time to time revise a code of practice in relation to the
commissioning of independent productions.

Clause 65: The Trust must after a public consultation adopt and publish a
statement of policy on fair trading. The Trust must keep the policy under
review and conduct a comprehensive review at least every three years.
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
Clause 66: The Trust must publish a statement of its duty to have regard
to the competitive impact of the BBC’s activities on the wider market. The
Trust must adopt and publish codes dealing with those aspects of the
operation of the UK public services that in its view could raise significant
issues regarding the competitive impact to the BBC’s activities.

Clause 85 (2) (in relation to the Executive Board’s report on equal
opportunities and training arrangements): The Trust must publish its
observations on the report.

Clauses 89 and 90 (complaints): The Trust must set and publish one or
more frameworks for dealing with complaints. This must include the
handling and resolution of complaints about the observation of the
relevant programme standards.
C The BBC in relation to certain functions under the BBC Agreement
The following functions of the BBC are public functions for the purpose of this
Scheme.
Agreement

Clause 12: Making the UK public services widely available. This function is
a public function when it is performed in conjunction with other public
function activity such as Digital Switchover, the Trust’s public functions
and the BBC’s arrangements with Ofcom in relation to Ofcom’s
accessibility codes.

Clauses 34–41: The BBC’s obligations in relation to Digital Switchover.

Clauses 59–60: Code relating to provision for deaf and visually impaired
people and power to modify targets.

Clause 74: Reports and accounts about the commercial services.

Clause 81: The BBC may be requested to broadcast or distribute
announcements in relation to defence and emergency arrangements.

Clause 88: The BBC may be directed to monitor and record specified
media output. In complying with such direction the BBC is to be regarded
as an agent of the Crown and to be acting in the public interest.
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