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Disability action plans

Disability Disability Rights

Disability action plans

Michael Small
Senior Policy Officer, HREOC

Employers Making a Difference Breakfast Briefing
Sydney 8 June 2004


Good morning and thanks to EMAD and AMP for providing us with this opportunity
to talk about Action Plans.

Over the past 10 years I have been involved in developing resources and
providing informal assistance to organisations developing Action Plans
throughout Australia. This has included assisting in the preparation of
the initial guides to developing action plans produced in 1995 and the
subsequent publication Developing an Effective Action Plan produced in
1999 both of which can be found on our website at

Quite a few organisations here today have prepared Action Plans and a
number have sought our informal comments at various stages in their development.

What I would like to do this morning is present the Commission's views
on the value and benefits of developing and lodging Action Plans with
the Commission.

However, I also want to acknowledge that having a formal 'stand alone'
Action Plan registered with the Commission is not a pre-requisite to going
about the task of eliminating discriminatory barriers to your goods and

There are clearly many reasons why an organisation might want to commit
to eliminating barriers, but choose not to follow the same path as others
and I will comment on some of them later.

Overall picture

Currently the Commission has nearly 300 plans registered on its website.
There is particularly good representation from the Government, tertiary
education, financial services and telecommunications sectors.

In addition to those registered plans the Commission is aware of many
hundreds of plans addressing access issues that are not formally lodged
with us. This is particularly so in the State and Territory Government
area where in some States access plans are mandatory, but registration
with the Commission is not required.

Why do organizations develop Action Plans?

Our experience has shown that Action Plans are developed for a number
of reasons including:

1. Organisational leaders initiate their development because of a desire
to 'do the right thing' or as part of the organisations general corporate
citizenship commitments
2. Key individuals within organisations see an Action Plan as an appropriate
means of managing risk
3. State or Commonwealth Government policy decisions lead to a requirement
that they are developed
4. Organisations develop them as a result of agreements reached in the
conciliation process arising from complaints
5. Advocates with a passion for equity within the organisation successfully
lobby for their development
6. Community advocacy organisations advocate with key organisations that
they be developed
7. Organisations develop them as part of an application for Temporary
Exemptions, and
8. Organisations develop them as a means of managing change over a period
of time


Those of you who have used our guides will be familiar with the Commission's
views on the benefits of developing an Action Plan.

For people with disabilities and their families, friends and associates
the benefits are obvious. Barriers to participation and opportunities
are progressively removed without the need for individuals to lodge complaints.

For an organisation to benefit from the work involved in developing an
Action Plan, however, the plan must do more than merely meet the requirements
of section 61.
I would suggest it must be effective in meeting the objects of the DDA
and the expectations of your organisation.

A well-constructed and implemented Action Plan provides benefits to an
organisation by:

  • eliminating discrimination in an active way
  • improving services to existing consumers or customers
  • enhancing organisational image
  • reducing the likelihood of complaints being made
  • increasing the likelihood of being able to successfully defend complaints
  • increasing the likelihood of avoiding costly legal action
  • allowing for a planned and managed change in business or services
  • opening up new markets and attracting new consumers or customers.

Unless your organisation can see benefits in most or all of these areas
the chances of getting managerial support and committed implementation
are minimal.

Ultimately an Action Plan will be effective in the event of a complaint
if it convinces complainants or the Federal Court that it:

  • demonstrates commitment to eliminating discrimination
  • shows clear evidence of effective consultation with stakeholders
  • has priorities which are appropriate and relevant
  • provides continuing consultation, evaluation and review
  • has clear timelines and implementation strategies and
  • is in fact being implemented.

Developing an effective Action Plan

Essentially the process of developing an effective DDA Action Plan can
be divided into five elements:

  • understanding your organisational environment
  • creating a favourable climate for implementation
  • undertaking effective consultation
  • developing an effective evaluation, monitoring and review strategy
  • structuring and writing your plan clearly and accessibly.

It seems to me that it is the first two of these elements, organisational
culture and favourable climate that pose the greatest difficulties for
those responsible for developing a plan and ensuring it is implemented.

What are the benefits of registering an Action Plan?

The Commission sees a number of benefits from registering a plan:

1. The process provides an opportunity for internal education and promotion
of the plan
2. Registering makes a positive public statement about commitments to
eliminating barriers
3. A public statement enhances the image of the organisation
4. It may have an effect on possible complainants, and
5. From the Commission's perspective it increases the visibility of the
DDA and allows for better public and internal accountability.

What factors lead to an organisation not registering
their plan

As we know not all organizations choose to register their plans with
the Commission and, of those organisations I am aware of, the reasons
for that include:

1. A concern that making public statements about eliminating barriers
that exist might make the organisation a 'target' for complaints - I am
not aware that this has ever been the case
2. A concern that if implementation strategies are behind time or change
because of organisational change the organization will loose 'public face'
3. A concern that the plan, if made public, might give some commercial
benefit to competitors
4. Some organisations integrate their access plans into broader organisational,
employment or business plans that are not appropriate for registration
as a stand alone

Action Plan

At the end of the day an organisation must make its own decision about
whether or not to formally register a plan - all I can say to you is that
I am not aware of any negative consequences of doing so.

On a final note I would remind us all that at some point in our lives
we will all benefit from changes to the way we provide goods and services.
Action Plans provide organisations with a means of planning for that change
in a way that best suites the organisation.

See Also

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