Foreword by the Director-General
The Disability Discrimination Act 1992 makes discrimination in relation to a disability, unlawful. Legislation protects employees, prospective employees, volunteers, work experience students, contract workers and clients. It recognises that people with a disability have the same fundamental rights and should have the same opportunities as other people to participate in the workplace and in community life.
The Library is committed to ensuring that people with disabilities have the same access to information and opportunities to participate in and contribute to its programs as other people in the community. This is an integral part of ensuring that the whole community can access the Library – a significant national cultural institution - and that the Library is recognised as an employer of choice.
The Library’s Disability Framework has two key objectives:
- to ensure that all Australians have access to a national collection of library material to enhance learning, knowledge creation, enjoyment and understanding of Australian life and society; and
- to ensure that the Library is accessible as a workplace, affording equal opportunity for staff members (and prospective staff members) with disability. It seeks to have processes for recruitment and promotion, as well as workplace conditions that foster equal opportunity for people with disability.
I encourage all employees to identify the role they can play in realising the objectives of this Framework and to actively support and implement it.
The Australian Government, through the Disability Discrimination Act1992 and the National Disability Strategy 2010-2020 (NDS), is taking affirmative action to provide better access to facilities, information and services, and employment to members of the community, who may have one or more disabilities. Consequently, the Library will ensure the integration of disability access issues into strategic and business planning processes. The Library will also coordinate planning efforts to meet its responsibilities regarding equity, inclusion, participation, access and accountability.
The purpose of this document is to set out the Library’s commitment and approach to achieving the key elements of its Disability Framework. The key elements include:
- providing access to facilities, information and services;
- providing access to employment;
- purchasing services which are accessible;
- recognising people with disabilities as consumers of services; and
- consulting with people with disabilities to find out what they need.
These provide the platform for further planning and development across the Library, specifically across the operational areas of reader services, information technology, public programs, human resources and building and security services.
1.2 DISABILITY AND DISCRIMINATION DEFINITIONS
For the purposes of this Disability Framework, the Library acknowledges that there are two definitions of disability. The first definition is from section 4 of the Disability Discrimination Act 1992 which is deliberately broad and inclusive. The second definition is from the Australian Bureau of Statistics 2003 Disability, Ageing and Carers Survey and is to be used for the collection of data and statistics from APS employees. The definition of discrimination is taken from the Disability Discrimination Act 1992. Please refer to Appendix 1 for full details of these definitions.
- Creating and sustaining a culture that values diversity and actively promotes the employment of people with disability;
- Providing flexible recruitment strategies that are accessible to applicants with disability;
- Providing accessible training, cadetship and mentoring opportunities for people with disability;
- Developing special employment measures to improve the employment outcomes for people with disability (e.g. intellectual disability);
- Developing accessible premises, workplaces and supportive work environments for people with disability;
- Reducing complexity and cost for managers employing people with disability;
- Sustaining a consistent conceptual framework for defining disability; and
- Improving continuous recruitment and retention strategies for people with disability.
1.4 ROLES AND RESPONSIBILITIES
The Library Council has a general role to:
- oversee strategic initiatives within the Library, including development of the Disability Framework, consistent with the provisions of the National Library Act 1960, the Public Service Act 1999 and the Disability Discrimination Act 1992, and
- through the Director-General, oversee the performance of the Disability Framework.
The Director-General’s role is to:
- authorise the Disability Framework; and
- hold the CMG accountable for performance of outcomes against the key elements of the Disability Framework.
Corporate Management Group (CMG)
CMG’s role is to ensure that the Library develops three operational business sub-plans to implement the key elements outlined in this Framework in relation to equity of service delivery, purchasing and employment of persons with disability.
CMG member responsibilities include:
- collectively overseeing the development, resourcing, communication, implementation, and evaluation of the Library’s Disability Framework through individual and collaborative efforts;
- being held individually accountable for contribution to the development and implementation of the sub-plans against the key elements of the Library’s Disability Framework, as these relate to their own division; and
- actively encouraging workplace diversity, including modelling supportive behaviours in the Library for visitors and employees.
Specific Executive Sponsors
The Assistant Directors-General will sponsor action in the Library in relation to the key elements of the Library’s Disability Framework.
Specifically, the Assistant Director-General, Corporate Services will sponsor action in the Library in relation to the physical elements of building accessibility and the Library as an employer. All Directors-General will sponsor action in the Library in relation to the elements of purchaser and provider, as they apply to their respective Divisions’ responsibilities.
Each sponsor’s role is to:
- play a lead role in promoting an organisational culture in which the needs of people with disability are considered and acted upon; and
- provide business planning and guidance across the Library’s roles of accessible service provider, equitable employer and purchaser.
Responsibility for co-ordinating the Framework and monitoring its implementation across the Library rests with the Director, Human Resources and the Work, Health and Safety Officer, Human Resources. These responsibilities will include encouraging awareness, sourcing appropriate training and reporting to CMG on progress against the Framework whilst ensuring the Annual Report and the Australian Public Service Commission’s (APSC’s) State of the Service reporting is accurate and consistent.
Disability Sub-Plan Owners
The responsibility for the development, evaluation and revision of the three sub-plans rests with:
- the Director, Human Resources for the employer role;
- the Assistant Director, Legal and Contracts for the purchaser role; and
- the Director, Reader Services and the Director, Product Development (IT) share the provider role.
Such responsibilities will include collegiate liaison across divisions to develop, maintain, evaluate and review their respective sub-plans. Each sub-plan shall record the objective, strategies/performance measures, current level of performance, goals and actions for all areas to which the sub-plan relates, with progress against achievement of objectives reported at financial year end to the Disability Co-ordinators and subsequently CMG.
Disability Contact Officers
An employee, ideally one for each Division, will be selected for the role of Disability Contact Officer through a nomination process (with the provision for a Disability Contact Officer to represent more than one Division). Their role is to act as a point of referral within their constituency on disability issues for all staff and visitors and to advocate on disability issues in all appropriate forums, including at the Disability Stakeholder Committee and through divisional Consultative Committee representatives.
Managers and Supervisors
In accordance with the Australian Public Service (APS) Code of Conduct, Values and other legislation, all managers and supervisors shall:
- design and provide services in a manner that promotes dignified access for people with disabilities; and
- treat all employees and prospective employees fairly, from selecting employees on the basis of merit to providing training, career development and promotion on the basis of ability and reasonable workplace modifications.
All Library employees are required to:
- endeavour to provide library services in a manner that will enable people with disability to engage with the Library’s collections as fully and easily as possible;
- be accountable for treating everyone with respect and courtesy and without discrimination; and
- act in accordance with the APS Values and Code of Conduct.
1.5 Reporting Obligations
Under the central elements of the NDS, government agencies must specify and report against outcomes for the roles of policy adviser, regulator, provider, purchaser and employer. Consistent with the NDS, the Library’s Disability Framework is presented to permit ease of reporting on the three relevant roles that apply to the Library (i.e. provider, purchaser and employer).
It is acknowledged that achievements against the employer role are required to be reported in the APSC State of the Service Report, whereas the provider and purchaser roles are required to be reported in the Library’s Annual Report.
The Library does not consider it has any significant policy or regulatory role and therefore will not be routinely reporting against these roles unless otherwise requested.
The sub-plans should be developed, evaluated and revised by ‘the owners’ with progress against the achievement of objectives reported at financial year end to the Disability Co-ordinators and subsequently CMG.
The Assistant Director-General, Corporate Services will chair a meeting at least biannually with the Disability Contact Officers and the Disability Sub-plan Owners to discuss implementation of the Framework and associated sub-plans, known as a Disability Stakeholder Committee.
1.6. CONSULTATION WITH STAKEHOLDERS
The Library is committed to consulting with stakeholders in relation to matters about the application, implementation, evaluation and review of this Framework that affect them. These matters will be discussed in a spirit of cooperation, inclusion and trust to ensure that stakeholders have an opportunity to contribute their views on matters relating to disability and this Framework. A perpetual calendar of topics can be found at Appendix 2.
A Disability Stakeholder Committee will be established to seek input into this Framework and to facilitate communication and consultation with stakeholders. A Disability Action Plan will be established for the ensuing 3 year period, refer to Appendix 3 for full details. This group may consist of, but not be limited to CMG, executive sponsors, Disability Coordinators, Disability Sub-plan Owners, Disability Contact Officers, Human Resource staff, volunteers, interested visitors, employees in roles managing contracts and building services staff, as well as their contracted providers and representatives from disability groups.
The Disability Stakeholder Committee will also communicate and consult with the Consultative Committee on this Framework and disability related matters, as required.
The Framework will be evaluated and reviewed periodically by the Director-General who will incorporate advice from CMG, the Disability Co-ordinators and Disability Stakeholders.
1.8 FURTHER INFORMATION
National Library of Australia
PARKES ACT 2600
Telephone (02) 6262 1563
Facsimile (02) 6273 4980
Disability Discrimination Act 1992
Disability, in relation to a person, means:
- total or partial loss of the person’s bodily or mental functions; or
- total or partial loss of a part of the body; or
- the presence in the body of organisms causing disease or illness; or
- the presence in the body of organisms capable of causing disease or illness; or
- the malfunction, malformation or disfigurement of a part of the person’s body; or
- a disorder or malfunction that results in the person learning differently from a person without the disorder or malfunction; or
- a disorder, illness or disease that affects a person’s thought processes, perception of reality, emotions or judgment or that results in disturbed behaviour;
and includes a disability that:
- presently exists; or
- previously existed but no longer exists; or
- may exist in the future; or
- is imputed to a person.
To avoid doubt, a disability that is otherwise covered by this defnition includes behaviour that is a symptom or manifestation of the disability.
Australian Bureau of Statistics - 2003 Disability, Ageing and Carers Survey
A person has a disability if they report that they have a limitation, restriction or impairment, which has lasted or is likely to last, for at least six months and restricts everyday activities. This includes:
- Loss of sight (not corrected by glasses or contact lenses)
- Loss of hearing where communication is restricted, or an aid to assist with, or substitute for, hearing is used
- Speech difficulties
- Shortness of breath or breathing difficulties causing restriction
- Chronic or recurrent pain or discomfort causing restriction
- Blackouts, fits or loss of consciousness
- Difficulty learning or understanding
- Incomplete use of arms or fingers
- Difficulty gripping or holding things
- Incomplete use of feet or legs
- Nervous or emotional condition causing restriction
- Restriction in physical activities or in doing physical work
- Disfigurement or deformity
- Mental illness or condition requiring help or supervision
- Long-term effects of head injury, stroke or other brain damage causing restriction
- Receiving treatment or medication for any other long-term conditions or ailments and still restricted
- Any other long-term conditions resulting in a restriction.
Disability Discrimination Act 1992
5. Direct disability discrimination
(1) For the purposes of this Act, a person (the discriminator) discriminates against another person (the aggrieved person) on the ground of a disability of the aggrieved person if, because of the disability, the discriminator treats, or proposes to treat, the aggrieved person less favourably than the discriminator would treat a person without the disability in circumstances that are not materially different.
(2) For the purposes of this Act, a person (the discriminator) also discriminates against another person (the aggrieved person) on the ground of a disability of the aggrieved person if:
- the discriminator does not make, or proposes not to make, reasonable adjustments for the person; and
- the failure to make the reasonable adjustments has, or would have, the effect that the aggrieved person is, because of the disability, treated less favourably than a person without the disability would be treated in circumstances that are not materially different.
(3) For the purposes of this section, circumstances are not materially different because of the fact that, because of the disability, the aggrieved person requires adjustments.
Perpetual calendar: Disability Stakeholder Committee
Meeting schedule: April, August and November
|Agenda or Action Item
|Welcome & Apologies
|Acceptance of the previous minutes
|Review outstanding Action Items
|Review of Disability Framework
|Review of Action Plan: The Library as an Employer
|Review of Action Plan: The Library as a Service Provider
|Review of Action Plan: The Library as a Purchaser
|Discuss recent AND meeting
|Discuss recent Disability Activities and Attendance
Disability Action Plan 2016-19
NLA OPERATIONS AND WORKFORCE
The Library collects and provides access to a large national collection of Library material in both physical formats and online. It serves the Australian community through the provision of reader services, document delivery services, exhibitions and public programs. These nationally available services are accessible from the Library building in Canberra as well as online though Library websites. The National Library also provides the national infrastructure for the discovery of and access to resources held in libraries across the country, which Australians can obtain through their local libraries.
A large proportion of the Library’s positions are in traditional librarian fields such as collection acquisition, processing and preservation, and reader services. Other fields with a high representation are curatorial, public exhibition and publishing roles, and (as Library operations and services are increasingly computer-based and online) Information Technology (IT) roles. The Library’s workforce is largely female (70%) with a median age of 46 years. The median length of service is 9.3 years and the percentage of part time employees as at 30 June 2016 is 18%.
The Library manages workforce needs through a Strategic Workforce Plan. The Plan includes action items relating to reasonable diversity and working towards a workforce that is representative of the broader Australian community.
NLA DISABILITY FRAMEWORK – AN OVERVIEW
The Library‘s disability disclosure rate as at 30 June 2016 was 6.3% of the workforce. This is higher than the APS wide disclosure rate of 3.5%, however, the rates across the APS vary from 0% to 17%. Overall, the disclosure rates do not reflect the broader Australian community, with the Australian Bureau of Statistics reporting approximately 18% of the population reporting a disability and 14% of the working age population.
Of those who have disclosed a disability there is a proportionate even distribution between male and female, with a median age of 45 years. The median length of service is higher for those with a disability at 10.4 years, as is the percentage of part time employees (28%).
The Library engages with the community and the broader APS in disability matters through the Australian Network on Disability and APS specific disability forums. As an employer a range of support is provided through the existing policies and guidelines, staff training, reasonable adjustments and, as appropriate, individual case management.
Information gleaned from voluntary disclosures, concerns raised by managers and colleagues and support provided by the Library’s WH&S function indicates a significant under disclosure of disability in the Library’s workforce. Strategies to foster an environment in which staff are comfortable in disclosing a disability and raising awareness of disclosure will continue to be a key focus of the Disability Action Plan in 2016-19.
|THE LIBRARY AS AN EMPLOYER
|ACTIONS FOR 1 JULY 2016-30 JUNE 19
Review the As One: Making it Happen, APS Disability Employment Strategy 2016-19 and incorporate initiatives into the Disability Action Plan
Establish a checklist calendar(s) for the Disability Stakeholder Committee to assist in planning and completing initiatives and routine tasks
|1: A culture that values diversity and promotes the employment of people with disability
|a. An initiative specifically targeted at developing a culture that values diversity and actively supports the employment of people with disability
Ensure a Senior Executive Service ‘champion’
Update Internet and Intranet to promote the Library’s commitment to supporting the employment of people with disability
|b. Ensure recruitment and retention policies and procedures support those with a disability and do not contain unintentional barriers.
Review recruitment and retention policies and procedures to ensure the Library supports the recruitment and/or retention of people with disability and that no unintended barriers exist
Review Library recruitment web pages to eliminate any barriers to people with disability for example fonts and the ability to use audio conversion software
Ensure recruitment documents are available in a variety of accessible formats
Monitor candidates who have disclosed disability and ensure appropriate follow up and support is accessible
Implement workplace adjustment policies and procedures
Ensure applicants are aware of the mechanisms available to provide feedback on their recruitment experience
|c. Improved data capture and disclosure rates
Encourage existing staff to update their EEO details, including disability status, using the Library’s Human Resource Management System
Ensure information on intranet on disclosure of disability, procedure and information usage
Promote and encourage disclosure
|GOALS FOR 2016-19
|2: Flexible and responsive recruitment strategies that are accessible to applicants with disability
|d. Applications accepted in different formats and people with disability given reasonable time to lodge applications and/or make appropriate adjustments to any direct testing situation
|Continually review the Library’s recruitment webpage for accessibility
|e. Processes in place to ensure methods of selection do not indirectly discriminate against applicants with disability
Ensure disability awareness and related legal obligations in training module for Selection Panel members
Regularly review feedback from applicants with disability and, as appropriate, make modifications to the recruitment framework
Ensure information regarding EEO requirements included in recruitment guides
|f. Delegates and selection panels are cognisant of the diverse needs of applicants with disability
|Add workplace adjustment guidance to recruitment intranet content and to training module for Panel members
|3: Accessible premises, workplaces and supportive work environments for people with disability
|g. Workplace adjustments identified for new employees with disability, before they commence duty
Maintain a workplace adjustment policy and consult with key stakeholders
Ensure the workplace adjustment policy is available on the Intranet
Review of Workplace Inspection Checklist conducted bi-annually
|h. Access provided to adaptive technology, or other practical support, by employees with disability Mobility of adaptive technology considered
Options for adaptive technology included in workplace adjustment policy and procedures
Mobility provisions for adaptive technology included in workplace adjustment policy and procedures
(Product Development IT and HR)
|i. Library Disability Stakeholder Committee maintained
|Disability Contact Officers membership maintained along with the Committee’s Terms of Reference
|j. Flexible work arrangements considered to meet individual workplace adjustment needs of people with a disability
Ensure Library employees are familiar with existing workplace flexibility provisions
Ensure links to the guidelines on Disability Intranet page
|4: Reduced complexity, cost or barriers for managers employing people with disability
|k. Provision of centralised source of information and expertise to assist managers and employees with disability
Disability Intranet page with resources and key contacts maintained
Disability Stakeholder Committee
|l. Training and/or awareness programs provided for managers and/or employees on mental illness, depression or related disorders
Workshops on disability awareness and mental health included on the Corporate Training Calendar annually
Promote online Disability Awareness Training
|5: Consistent conceptual framework for defining disability
|m. The definition of ‘disability’ used by the ABS Disability, Ageing and Carers
Communicate and promoted to staff via the Disability Intranet page and the Disability Stakeholder Committee
Definition used to capture EEO information in the Library’s HRMIS
|n. Employees actively encouraged to update their disability status on HR systems
Conduct an annual all staff campaign to encourage disclosure of disability
Review current disclosure procedure to ensure disclosure is simple and quick to do via the Library’s Human Resource Management Information System
|THE LIBRARY AS A SERVICE PROVIDER
|GOALS FOR 2016-19
|1: Dignified and equitable access to the Library building and facilities by people with disabilities
|a. Building, facilities, commercial outlets, venues and reading rooms, and the signage and access routes to these, meet physical accessibility standards and can be easily found
Regularly review the extent to which the building, facilities, commercial outlets and reading rooms, and the signage and access routes to these, meet physical accessibility standards (Building and Security Services)
Develop plans for improvements where current standards are not met and identify such works in annual and longer term work programs (Building and Security Services)
Ensure that building standards are met for all future redevelopments (Building and Security Services)
|2: Library communication with the community considers the needs of people with disabilities
|b. The Library’s face to face, telephone and electronic services staff are capable of confidently communicating with and serving people with a range of disabilities in a mutually dignified manner
Staff, security guards and volunteers at all service points throughout the Library offered training in communicating with and providing services to people with disabilities; attendance by all staff, security guards and volunteers encouraged and included in performance communication (Human Resources, Public Programs and Building and Security Services)
Usage of National Relay Service and requests for Auslan interpreter reported in monthly statistics and annually (All)
User feedback acted on promptly and reported on quarterly (All & Executive Support)
|3: Dignified and equitable access to the Library’s onsite services and collections by people with disabilities
In addition to 2. above:
c. The furniture and equipment in reading rooms and venues can flexibly cater for a variety of physical requirements, including people in wheelchairs
d. Assistive technology available to assist print handicapped and other users with disabilities access collection material independently
Review reading room and learning program venue furniture to ensure readers with a range of physical seating requirements can access services and use collection material independently (Reader Services for all reading rooms; Public Programs and Building and Security Services for venues)
Review the assistive technologies available in the marketplace and assess whether reading rooms and learning program venues need to up-date existing assistive technologies (Reader Services and Product Development IT in collaboration with Public Programs)
Monitor and respond to demand from users with disabilities for service improvements (taking into consideration access requests not met and user complaints and other feedback) (Reader Services, Product Development IT & Executive Support)
Develop plans for improvements to address any shortcomings found and to meet reasonable user requests (Reader Services, Events. Product Development and Building and Security Services)
|4: Dignified and equitable access by people with disabilities to the Library’s websites
|e. Ensure the Library’s websites meet Web Content Accessibility Guidelines (WCAG) as set out by the Australian Government
Develop a plan of compliance reviews for NLA websites (Information Technology Division)
Replacement for the ILMS includes compliance as part of the criteria, to ensure any newly developed catalogue replacing http://catalogue.nla.gov.au/ is compliant (Collections Management and Information Technology Divisions)
Compliance becomes a mandatory requirement for any externally built websites hosted by the Library (Information Technology Division)
Report compliance annually to Government as required
|5: Dignified and equitable access by people with disabilities to the Library’s exhibitions
|f. Exhibitions on display in the Library’s galleries meet better practice for displays and signage for people with disabilities, including people in wheelchairs, taking into consideration the preservation needs of collection material
In Treasures Gallery, maintain appropriate standard of wheelchair accessible display cases, lighting and portable large print captions (Exhibitions)
In Exhibitions Gallery, maintain appropriate access for people in wheelchairs, provide portable large print captions for people who have difficulty with reading captions, and use lighting to enhance visibility taking into consideration the specific needs of collection material (Exhibitions)
|6: Service standards and grievance mechanisms are accessible to people with disabilities
|g. The Library’s Service standards and complaints mechanism readily accessible by people with disabilities in the Library building and on the website
Service standards and complaint mechanism readily identifiable on Library websites and at onsite service points (Executive Support & Web Publishing);
User feedback from people with disabilities is considered, acted on, responded to and reported on quarterly to CMG in accordance with the Library’s user feedback policy (Executive Support)
|THE LIBRARY AS A PURCHASER
|GOALS FOR 2016-19
|1. Processes for purchasing goods and services with direct impact on people with a disability are developed in consultation with people with a disability.
|a. The Library considers the concerns of stakeholders, including people with a disability, as an on-going responsibility when undertaking purchasing activities. As part of the planning for procurement, where goods and services have a direct impact on people with a disability, these requirements are specified following appropriate stakeholder feedback.
|Maintain levels of feedback and undertake further consultation and/or obtain expert advice as appropriate. Ensure Library procurement training courses address issues of ‘fit for purpose’, as outlined in the Contract and Procurement Guidelines, for consideration in procurement planning by the responsible branch/division.
|2. Purchasing specifications and contract requirements for the purchase of goods and services are undertaken such that the requirements of people with disabilities once identified are then addressed
|b. The Library’s Contract and Procurement Guidelines reminds purchasing officers to consider issues associated with disabilities and relevant disability procurement practices when compiling tender documentation.
|Maintain guidelines and appropriate contract clauses. Monitor tender specifications and review templates to ensure compliance.
|c. The Library’s standard contract for services contains provisions for the contractor to agree to comply with the Disability Discrimination Act 1992.
|d. The Library follows procurement related policies such as the proposed accessibility ICT Procurement Standard to be used when determining technical specifications for the procurement of accessible ICT products and services
|3. For particular purchases, consideration is given by the Library to using an Australian Disability Enterprise.
|e. The Library follows relevant Commonwealth Procurement Rules which encourage purchasing officers to consider using an Australian Disability Enterprise. Services to consider include: cleaning; landscaping; corporate products and gifts; trophies; printing and design services; packing; and mail/document management.
Ensure Library purchasing officers are familiar with the Australian Disability Enterprise arrangements.
Explore exemptions from complying with procurement dollar value thresholds in the Contract and Procurement Guidelines for procurement from business that employ people with disability.
The Library will report its progress on outcomes through:
- Annual progress reports to CMG,
- Annual report indicator to be prepared by the Library's Human Resources Branch and provided to CMG, and
- Responses to the State of Service Agency Survey relating to this indicator.