British Broadcasting Corporation

Disability Equality Scheme

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Foreword by the Chairman of the BBC.........................................................3Foreword by the Director-General of the BBC..............................................5Summary of the Disability Equality Scheme................................................61 Introduction.............................................................................................12

1.1 The BBC............................................................................................121.2 Review and Extension of the Disability Equality Scheme – 2010-11.131.3 Application of the Disability Equality Scheme to Northern Ireland, the Channel Islands and the Isle of Man.......................................................13

2 The Disability Equality Duty....................................................................142.1 The Disability Discrimination Act 1995 (as amended) (DDA)............14

3 The BBC’s Disability Equality Scheme.....................................................154 Key elements of the BBC’s Disability Equality Scheme...........................16

4.1 Involvement – a statement of how disabled people have been involved in developing the Scheme........................................................164.2 Action plan........................................................................................194.3 Performance monitoring – arrangements for gathering information about the performance of the BBC on disability equality.......................204.4 Assessment – arrangements for assessing the impact of the activities of the BBC on disability equality and improving these when necessary.274.5 Formal review for 2010-11................................................................29

5 Implementing the Disability Equality Scheme........................................306 Monitoring and evaluation......................................................................31

6.1 Disability Equality Scheme Performance Summary 2009/2010........327 Feedback and update.............................................................................478 The BBC’s broader approach to promoting disability equality................48

8.1 BBC Diversity Strategy.....................................................................489 Action Plan..............................................................................................55

Action Plan 1: TV licensing function........................................................55Action Plan 2: The BBC Trust in relation to certain functions under the BBC Charter and Agreement (relating to involvement)..........................66Action Plan 3: The BBC in relation to certain functions under the BBC Agreement..............................................................................................70Section (i): The BBC’s obligations in relation to digital switchover (Agreement Clauses 34–41)....................................................................70Action Plan 3: The BBC in relation to certain functions under the BBC Agreement..............................................................................................87Section (ii): Other functions of the BBC in relation to certain functions under the BBC Agreement (Agreement Clauses 12, 59–60, 74, 81).......87

Annex.........................................................................................................91The BBC’s public functions.....................................................................91

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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 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

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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

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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.

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.

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Mark Thompson

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Summary of the Disability Equality Scheme

Review and Extension for 2010-11The 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.

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.

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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.

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

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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 1We 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 2We will be proactive in reaching audiences, including minorities and the seldom heard..

Objective 3In 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.

Objective 4We 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

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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 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.

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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.

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.

6 To ensure effective internal monitoring and Disability Equality Scheme outcomes evaluation.

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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).

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.

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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

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

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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 – 2010-11The BBC first developed this Scheme in 2007 and was due to undertake a three-year 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

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 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 SchemeThe 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 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 information-gathering 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.

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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:

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.

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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 call-centres 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 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 45-60 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.

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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 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.

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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 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 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

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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.)

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

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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:

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.

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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.

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.

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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 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 reviewIn 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 FrameworkAs 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 has been made more accessible by

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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 reviewAs 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 CouncilsThe 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: 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.

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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.

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

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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.

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

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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 call-centres 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 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

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include a quota of 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 assessmentsDuring 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).

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.

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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.shtmlEIAs conducted by the BBC Trust are available at: http://www.bbc.co.uk/bbctrust/about/how_we_govern/diversity_equality/equality_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).

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.

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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.

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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.

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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 Arrangements for gathering information about the performance of the

BBC on disability equality

The BBCTrust

BBC Diversity

Board

The Trust Unit

BBCDiversity Centre

TV Licensing

Any other relevantpublic

function areas

Digital Switchoverincluding

Digital Switchover

Help Scheme

Digital UK

(external)

BBC Executive

Board

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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

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

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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 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.

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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.

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.

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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.

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

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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.

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.

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.

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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.

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

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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 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

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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. 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

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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, 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.

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,

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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, 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.

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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

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.

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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.

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 roll-out 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.

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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.

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.

Help Scheme is represented on the BBC Finance Division’s Equality and Diversity Action Group.

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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 availableKey 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.

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.

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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.

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

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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.

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

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and created by Gamelab London. Us5 shows people with learning disabilities/difficulties faced with real-life 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 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.

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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 four-part 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.

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 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

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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.

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-on-Demand 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.

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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.

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.

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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.

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 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 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,

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content, format and dissemination, and the EIA outcome will inform any further action necessary. Due date: By end 2007

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Progress: CompletedLead: 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 cost-prohibitive. 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 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 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.

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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 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

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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 impracticalLead: Operations Evidence/outcomes: Formal systems in place where practical

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

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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. 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.

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.

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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

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

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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

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

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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. Due date: From 1 April 2007 Progress: CompletedLead: 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

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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

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: OngoingProgress: 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 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.

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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 1We 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: OngoingLead: Audiences and Marketing teamEvidence/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

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Lead: Editorial Standards teamEvidence/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: 2010-11Lead: Editorial Standards teamEvidence/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: 2010-11Lead: Audiences and Marketing teamEvidence/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: 2010-11Lead: Audiences and Marketing teamEvidence/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: 2010-11Lead: Communications teamEvidence/outcomes: An accessible website which disabled people can access and use easily.

Objective 2We 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: 2010-11Lead: Audiences and Marketing teamEvidence/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.

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Due date: 2010-11Lead: Audiences and Marketing teamEvidence/outcomes: An increase in the participation of Trust Unit activities by disabled people and carers

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: 2010-11Lead: Audiences and Marketing teamEvidence/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: 2010-11Lead: Communications teamEvidence/outcomes: A broader range of voices the Trust hears from.

Objective 3In 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: 2010-11Lead: Editorial Standards teamEvidence/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. Due date: 2010-11Lead: Editorial Standards teamEvidence/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

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the way disabled people and carers are treated which is unfavourable and/or unfair. Due date: 2010-11Lead: Editorial Standards teamEvidence/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: 2010-11Lead: Editorial Standards teamEvidence/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: 2010-11Lead: Audiences and Marketing teamEvidence/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: 2010-11Lead: Trust UnitEvidence/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.

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: 2010-11Lead: Audiences and Marketing teamEvidence/outcomes: Improving and raising the awareness of diversity and equality issues within the Trust.

Objective 4We 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 pictorialDue date: 2010-11

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Lead: Audiences and Marketing teamEvidence/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: 2010-11Lead: Trust unitEvidence/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.

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 digital-only 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.

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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 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 call-centres 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 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.

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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.

(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,

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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.

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.

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1 DSHS to initiate a 'Transformation Plan' in identified areas for improvement to the customer journey.Due date: 2010-11 Lead: Operations DirectorEvidence/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 StrategiesEvidence/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: 2010-11Lead: Head of Customer StrategiesEvidence/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: 2010-11Lead: Head of MarketingEvidence/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

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Lead: Head of Customer Strategies Evidence/outcomes: Working in partnership with local communities to help engage potential users of the Help Scheme

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: 2010-11Lead: 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 MarketingEvidence/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 MarketingEvidence/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.

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Due date: 2010-11 Lead: Operations Director / Head of MarketingEvidence/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 StrategiesEvidence/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.

Due date: 2010-11Lead: 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 improvement2 DSHS to promote the involvement of eligible people in delivering the Help Scheme.

Due date: 2010-11 Lead: Operations DirectorEvidence/outcomes: People who use the service are able to influence its further development and improvement

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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 ManagerEvidence/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.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 ManagerEvidence/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 ManagerEvidence/outcomes: Evaluations of delivery of the Help Scheme in each region include consideration of successful engagement of disabled people

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4 DSHS and DUK to track and respond to Awareness and Understanding data by disabled people. Due Date: 2010-11Progress: 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 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 ManagerEvidence/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

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Drivers/informed by: DDA 2005 Government White Paper BBC Values: Audiences; Respect

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 sub-contracts).

Due date: 2010-11Lead: 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: 2010-11Lead: 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: 2010-11Lead: Contracts ManagerEvidence/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: 2010-11Lead: Business ManagerEvidence/outcomes: DSHS develops operational processes, policies and practices which result in better outcomes for disabled people.

Drivers/informed by:

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DDA 2005 Government White Paper BBC Values: Audiences; Respect

Objective 7To 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: 2010-11Lead: 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: 2010-11Lead: 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: 2010-11Lead: Business Manager Evidence/outcomes: 4 DSHS to participate in Finance Division Equality & Diversity action group activities.

Due date: 2010-11Lead: 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

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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.

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: 2010-2011Progress: 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.

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Due date: 2010-2011Lead: 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: 2010-2011Progress: 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 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:

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DDA 2005 Government White Paper BBC Values: Audiences; Respect

Objective 3 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: 2010-2011Progress: 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: 2010-2011Progress: 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: 2010-2011Progress: Ongoing Lead: BBC Finance Director Evidence/outcomes: Policy on standards in place. Code of Service Standards.

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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: 2010-2011Progress: 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: 2010-2011Lead: 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. 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: 2010-2011Progress: Completed annually

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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: 2010-2011Progress: 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: 2010-2011Progress: 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. 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

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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: 2010-2011Progress: 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 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

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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)

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

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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 • 10% audio-description on qualifying services rising to 20% by 2016 • 5% signing Due date: Ongoing Lead: Wilf WhiteEvidence/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). Due date: Ongoing Progress: Ongoing Lead: Wilf White

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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

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:

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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 • 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.

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• 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.

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.

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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.

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.

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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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