Disability Action Plan 2015-2018

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Disability Action Plan 2015-2018

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Disability Action Plan 2015-2018

Contents

1. Introduction
1.1 Background
1.2 Legislative framework for the Disability Action Plan

2. Inclusive Policies

3. Definition of Key Terms
3.1 Disability
3.2 Discrimination
3.3 Reasonable Adjustments
3.4 Unjustifiable Hardship
3.5 Universal design

4. Aspiration Goal

5. Key Roles
5.1 Responsible Officer (Sponsor)
5.2 Designated Officers
5.3 Implementing Officers

6. Implementation Process

7. Reporting and Review

Action Statements

USC Strategic priority 1: To enable access to the USC experience
USC Strategic priority 2: To deliver high quality teaching, learning and graduate outcomes
USC Strategic priority 3: To build research productivity and output significantly
USC Strategic priority 4: To develop USC for a sustainable future

DAP Action Framework

1. Introduction

1.1 Background

The Disability Action Plan is guided by the principles of the Disability Standards in Education 2005 (Disability Discrimination Act 1992), which supports the fundamental right of students with disabilities to participate in all aspects of university life on the same basis as their peers. It is also informed by the University's Equity and Diversity Policy.

The University of the Sunshine Coast is committed to supporting an institutional culture that enables equality of opportunity wherever possible and reasonable for all staff and students including those with disabilities. The University aims to be at the forefront in providing access to reasonable adjustments so that people with disabilities can access facilities and services as independently as possible and is working to ensure its buildings and their surrounds will be designed and developed to meet the access requirements of people with disabilities.

The purpose of the Disability Action Plan is to assist the University in providing equitable access to quality education for students with a disability; to improve the teaching and learning environment for students; to ensure that staff with a disability are able to fully participate and reach their potential; to raise awareness of disability issues and to develop a diversity capable campus. It is intended that this document will assist operational areas of the University to engage in a process of continual improvement, through iterative reflection, evaluation, planning, implementation and review, (praxis) with the intent of achieving leading practice in education and employment for people with disabilities.

The first University of the Sunshine Coast Disability Action Plan was developed in 1999 and has been regularly reviewed and updated since that time. This 2015-2018 Plan results from a review in 2013 at which time it was decided to more closely align the Disability Action Plan with the University's Strategic Plan. The intent of this restructured Plan is to move from a tightly prescriptive document to one that sets key objectives in priority areas to assist the University in improving access and engagement in work and study for staff and students with disabilities. The 2015-2018 Plan also identifies those senior staff whose role it is to ensure that the actions set out in this Plan are appropriately implemented within their portfolio, acknowledging that the designated officers are best placed to identify the appropriate means of addressing those objectives within their areas of responsibility.

While the Disability Action Plan 2015-2018 sets out the priority goals for the University over a three year period, it is anticipated that an annual review of progress will be undertaken and as necessary, these objectives will be modified according to results of that review.

1.2 Legislative framework for the Disability Action Plan

The Commonwealth Disability Discrimination Act 1992 (DDA) makes discrimination against people on the grounds of disability unlawful in specific areas of public life. These include the workplace, accommodation, education, access to premises, clubs and sport, and in the provision of goods, facilities, services and land. The DDA prohibits discrimination against any person, or their associates, on the grounds of actual or assumed disability. This has implications for both employment and education.

The Disability Standards for Education 2005 (the Standards) is subordinate legislation under the DDA. The Standards specifically articulate the obligations of education and training providers under the DDA and the rights of people with disabilities when undertaking education and training in areas of:

  • enrolment
  • participation
  • curriculum development, accreditation and delivery
  • student support services, and
  • elimination of harassment and victimisation.

The Standards confirm that education providers are required to make reasonable adjustments to ensure that students with disabilities are able to participate in education on the same basis as other students, with equal opportunity to realise their individual potential.

The Disability (Access to Premises - buildings) Standards 2010 (Premises Standards) are sub-legislation to the DDA and are applicable to any building refurbishment or new construction undertaken by the University.

The Queensland Anti-Discrimination Act 1991 also clearly identifies obligations on the part of the University to eliminate all forms of discrimination against people with impairment (disability1).

1The terms 'disability' as defined in the DDA, and 'impairment' as defined in the Qld Anti-Discrimination Act 1991 are, for all practical purposes, interchangeable.

2. Inclusive Policies

The University of the Sunshine Coast is committed to ensuring equity of access and engagement for students with disabilities. A number of policies and procedures have direct application in promoting inclusive practice to all members of the University community, including but not limited to:

  • Students with a Disability Managerial Policy
  • Inclusive and Non Discriminatory Language Managerial Policy
  • Equity & Diversity Governing Policy
  • Marketing and Communications Managerial Policy
  • Health, Safety and Wellbeing Governing Policy
  • Staff Code of Conduct Governing Policy
  • Student Conduct and Discipline Governing Policy
  • Discrimination and Harassment Policy and Procedures
  • Student Complaints and Appeals Procedures.

3. Definition of Key Terms

3.1 Disability

The University of the Sunshine Coast recognises the legal definition of disability, as defined in the Commonwealth Disability Discrimination Act 1992, or impairment, as described in the Qld Anti-Discrimination Act 1991. In both instruments, this encompasses temporary or permanent physical, intellectual, psychiatric, sensory, and neurological and learning disabilities and the presence in the body of organisms causing, or capable of causing, disease. It also includes a disability that presently exists, existed in the past, or may exist in the future, as well as a disability that is imputed or presumed to a person.

3.2 Discrimination

Disability discrimination refers to the less favourable treatment of one person over another because they have a disability (or impairment) - this is direct discrimination, e.g. not permitting a staff member with a disability to participate in a staff development program. Indirect discrimination may also occur in situations where a condition is imposed that people with a disability are unlikely to be able to comply with, and that condition is not reasonable in the circumstances (for example, holding an interview or an exam in a room that is not accessible for people with a mobility impairment). The DDA specifies that discrimination can occur regardless of intention. Harassment on the basis of disability is also unlawful. Examples of this could be derogatory comments made in the course of a lecture, tutorial or interview; written derogatory comments by students or staff; or restrictive personnel practices.

Some exceptions to the Standards do exist. It is not unlawful to treat a person differently where it is reasonably intended to ensure they have equal opportunity, or if their condition may pose a risk to the health and welfare of themselves or others. A person must also be able to fulfil the "inherent requirements" as described to undertake a job or course of study, unless their inability can be overcome by making a "reasonable adjustment".

3.3 Reasonable Adjustments

Alternative arrangements or modifications are important for ensuring equal access to employment or education for people with disabilities. The University is required by law to make reasonable adjustments for staff or prospective staff with disabilities to ensure equity in areas such as job applications, interview processes and the capacity to meet the inherent requirements of a position. The University is also obliged to make reasonable adjustments for students with a disability to enable them to equitably participate in courses or programs wherever necessary and reasonable to do so without affecting the essential academic requirements of a course and to use the University facilities and services on the same basis as other students. Adjustments might, for example, include provision of adaptive equipment or software, changing course delivery or assessment procedures, or modification of premises.

3.4 Unjustifiable Hardship

An organisation is not legally bound to make an adjustment if by doing so, it would impose unjustifiable hardship on it.
A number of factors are considered in determining unjustifiable hardship, including:

  • the nature of the benefit or detriment (disadvantage) likely to be experienced by any persons concerned
  • the effect of the disability on the person concerned
  • the financial circumstances and the estimated expenditure required to be made by the organisation claiming unjustifiable hardship, and
  • in the case of services or facilities provision, an action plan given to the Australian Human Rights Commission.

Unjustifiable hardship is assessed on a case-by-case basis by the Australian Human Rights Commission, following the principles established by the DDA.

3.5 Universal design

Resource material from the Australian Disability Clearing House on Education and Training - Creating Accessible Teaching and Support  website  explains that the concept of universal design, which was first developed in the field of architecture, is when "all products, environments and communications ... [are] designed to consider the needs of the widest possible array of users" ADCET: Inclusive Teaching. The concept of universal design is equally applicable to the design and delivery of services such as education. In these terms, universal design means the development of curriculum, instructional materials and instruction to be accessible to and useable by students with different backgrounds and abilities. The key aspect of a universally designed curriculum is its in-built flexibility.

4. Aspirational Goal

The overall goal of the University of the Sunshine Coast is to ensure that staff and students with disabilities are able to fully participate in the life of the University and to reach their full potential as staff or students. To this end, the University commits to eliminating structural and systemic impediments that impact on people with disabilities, and to developing a diversity-capable campus culture where each person is valued for their individual contribution.

The achievement of this goal would see equitable representation of people with disabilities as staff at all levels across the University and as students across disciplines, where students with disabilities are participating and succeeding at a level equivalent to their peers and the feedback from student surveys indicates a high level of satisfaction with their student experience.

5. Key Roles

Every staff member of the University has a responsibility to contribute to ensuring an inclusive work and study environment for staff and/or students with disabilities, nevertheless, it is also understood that the University's senior officers have a particular responsibility to ensure that the Actions detailed in this Plan are carried out within their areas of responsibility. Accordingly, the following key roles have been identified.

5.1 Responsible Officer (Sponsor)

While the Disability Action Plan is a Level 2 Support Plan, given its importance, it is appropriate to have a Responsible Officer (Sponsor) nominated for this Plan to champion the Disability Action Plan and ensure that action is being taken by those who have responsibility for implementation of Action Statements.

Given the dual staff and student focus of this Disability Action Plan, the Responsible Officers (Sponsors) are the Deputy Vice Chancellor and the Pro Vice Chancellor (Corporate Services).

5.2 Designated Officers

The Action Statements in this Disability Action Plan are key objectives for the University in achieving a more inclusive culture and improved outcomes for staff and students with disabilities. It is recognised that the manner in which these action statements may be implemented will vary according to the specific context of different organisational units.

The Designated Officers are those senior staff with direct responsibility for ensuring the implementation of Action Statements relevant to their areas of responsibility. They may allocate responsibility to relevant staff within their portfolio (the Implementing Officers) to develop specific and appropriately contextualised sub actions to address the Action Statements, and to ensure that these sub-actions are carried out. These should be incorporated within the relevant Faculty/Cost Centre Area Operational Plans.

5.3 Implementing Officers

Those staff members who are charged by the Designated Officer with implementing the Action Statements by developing appropriately contextualised and relevant sub-actions.

6. Implementation Process

There are additional resources available in the form of an Implementation Template (staff only link) and examples of leading practice. These are intended to assist Implementation Officers to identify activities that might address the Action Statements, the template will enable recording of "sub actions' taken and facilitate ease of reporting on progress.

In addition to these resources, staff from Student Life and Learning, are available to provide assistance and to discuss options.

7. Reporting and Review

A Review of the outcomes of the previous Disability Action Plan 2011-2013 has identified a number of areas where processes of catering for staff and/or students with disabilities or strategies to ensure continuing improvement have become embedded in the University's daily practices. This review and its report has also identified areas where improvement can still be made and these have incorporated within this new Disability Action Plan, which continues to focus upon embedding equity practices in standard procedure to ensure that an inclusive environment and culture are generated.

It is intended that in future years, reporting against the Disability Action Plan will be undertaken through the usual University reporting procedures. Reports of progress related to the Disability Action Plan will be extracted from the Faculty and Cost Centre reports to contribute to an annual Equity & Diversity report. This will enable the University to gain a clear understanding of how it is tracking in meeting its legal responsibilities and social justice commitments towards staff and students with disabilities and in moving towards achieving its aspirational goal. This Disability Action Plan sets goals for the triennium 2015-2018, and it will be reviewed and updated each year in response to the annual report.

Planning and reporting framework for the USC Disability Action Plan

These diagrams demonstrate the relationship of the Disability Action Plan to the USC Planning and Reporting Cycle and its alignment with the USC Managing Change Guidelines.

Equity and diversity planning and reporting workflow diagram.University managing change guidelines diagram.

Action Statements

The University of the Sunshine Coast - Aspirational Goal

To ensure that staff and students with disabilities are able to fully participate in the life of the University and to reach their full potential as staff or students.

USC Strategic priority 1: To enable access to the USC experience
Key strategies

1.1 Recruit and support a diverse student population
1.2 Provide a high quality student experience
1.3 Develop a vibrant and healthy University community and identity

DAP Action Statements: Section 1
    1. Review all University web pages to ensure accessibility as per the National Transition Strategy.
    2. Incorporate positive images of people with disabilities in a range of university materials, including electronic and print media.
    3. Audit information provided to prospective students in all formats to ensure support information is incorporated, including international students.
    4. Develop and promote guidelines to ensure the accessibility of online-course materials that meet Web Content Accessibility Guideline Standards.
    5. Review procedures to negotiate and implement reasonable adjustments for students with disabilities to ensure these reflect of leading practice.
    6. Develop strategies to ensure students are aware of their rights and responsibilities, and are provided with accurate information and support in any grievance resolution process.
    7. Develop centralised funding process to support reasonable adjustments for international students with disabilities.
USC Strategic priority 2: To deliver high quality teaching, learning and graduate outcomes
Key strategies

2.1 Embed academic excellence in all teaching and learning activities
2.2 Support diverse learning and teaching styles to maximise student participation and success
2.4 Produce graduates with knowledge, skills and attributes to succeed in a world characterised by rapid change

DAP Action Statements: Section 2
    1. Develop Guidelines for the provision of teaching, learning & assessment (including practicums, placements and field work) based on universal design principles that are responsive to the requirements of students with disabilities.
    2. Promote the use of the principles of universal design in all aspects of curriculum design and pedagogy.
    3. Increase the capacity of relevant staff to implement and support students in the use of Assistive Technologies.
    4. Develop a process for the University to identify inherent academic requirements in courses and programs.
    5. Develop inclusive strategies to engage students with disabilities in extension and extra-curricular opportunities; e.g. international study opportunities
    6. Provide an annual report on the access, participation and success rates of students with disabilities across the University.
    7. Provide professional development opportunities for academic staff on their responsibilities regarding students with disabilities and the range of support and information available.
USC Strategic priority 3: To build research productivity and output significantly
DAP Action Statements: Section 3

No specific actions have been developed for this strategic priority.

USC Strategic priority 4: To develop USC for a sustainable future
Key strategies

4.1 Develop and enable staff to manage change and contribute to achievement of the strategic plan
4.2 Invest in and continuously improve information management systems, business processes and workforce planning
4.4 Maximise opportunities to develop well designed, technology rich, and sustainable University sites

DAP Action Statements: Section 4
    1. Review the Vice Chancellor's Equity Advisory Committee composition and Terms of Reference with a view to facilitating a greater capacity for monitoring and providing advice in this area.
    2. Review strategies to encourage suitably qualified people with a disability to apply for positions at all levels across the University.
    3. Promote the University's policies on prevention and management of Discrimination and Harassment and grievance resolution procedures to current and prospective staff.
    4. Assess student and graduate satisfaction and graduate employment outcomes relating to students with disabilities.
    5. Develop an audit process to ensure regular monitoring of physical accessibility and appropriate signage of USC buildings, grounds and facilities.
    6. Develop an on-line process for recording implementation of and progress against Disability Action Plan Action Statements.

DAP Action Framework

Responsible Officers (Sponsor):

  • Deputy Vice Chancellor
  • PVC (Corporate Services)
Section 1
DAP Action Statement Designated Officers Target Date

i. Review ALL University web pages to ensure accessibility as per WCAG 2.0.

KPI

All university web pages will comply with W3C accessibility standards WCAG 2.0. This includes external (public-facing or private) and internal (closed community) sites. That is, conformance is required for all internet, intranet and extranet sites.

  • Director Marketing and Communications (external)
  • Director Information Services (internal)
  • September 2015
  • June 2016

ii. Incorporate positive images of people with disabilities in a range of university materials, including electronic and print media

KPI

There is a representative sample of positive images of people with disabilities across University websites.

Positive images of people with disabilities are found in web-based and hard copy promotional material.
  • Director Marketing and Communications?
  • September 2015

iii. Audit information provided to prospective students, including international students to ensure support information is incorporated in all formats.

KPI

Details of the procedures to self-identify to Disability Services staff, and the nature of support available is included in all information to prospective students.
  • Director Marketing and Communications
  • Director USC International
  • Director Student Administration
  • Director Student Life and Learning
  • September 2015
  • October 2015
  • October 2015
  • June 2016
 

iv. Develop and promote guidelines to ensure the accessibility of online-course materials that meet Web Content Accessibility Guideline Standards.

KPI

Publication and promotion of guidelines to academic staff which are embedded into web-based material development systems.

  • Director C-Salt
  • Executive Deans and Heads of School of Law
  • June 2016
  • Following above

v. Review procedures to negotiate and implement reasonable adjustments for students with disabilities to ensure these reflect of leading practice.

KPI

Annual review undertaken that includes benchmarking against other leading universities.

  • Director Student Life and Learning
  • December 2016

vi. Develop strategies to ensure students are aware of their rights and responsibilities, and are provided with accurate information and support in any grievance resolution process.

KPI

All students are aware of their rights and responsibilities and how to take forward a grievance related to discrimination, harassment or bullying.

  • PVC (Students)
  • December 2015

vii. Develop centralised funding process to support reasonable adjustments for international students with disabilities.

KPI

Process for quarantining of funds from International fee-paying students is established within existing financial management systems.

  • PVC (International and Quality)
  • July 2015
Section 2
DAP Action Statement Designated Officers Target Date

viii. Develop guidelines for the provision of teaching, learning & assessment (including practicums, placements and field work) based on universal design principles that are responsive to the requirements of students with disabilities.

KPI

Guidelines provided to academic staff that assist with developing their understanding of the principles universal design and how they can be applied in the learning and teaching context.

  • Director    C-SALT
  • June 2016

ix. Promote the use of the principles of universal design in all aspects of curriculum design and pedagogy.

KPI

Academic staff are aware of and utilise the principles of universal design in pedagogy in all stages of the learning and teaching process; from curriculum design through to assessment practices.

  • Associate Deans    Learning & Teaching
  • Heads of    School of Law
  • December 2017
  • December 2017
 

x. Increase the capacity of relevant staff to implement and support students in the use of Assistive Technologies.

KPI

Key staff in each Faculty, the University Library and C-SALT are identified and provided with professional development in the use of Assistive Technologies.

  • Director Student Life and Learning
  • June 2017

xi. Develop a process for the University to identify inherent academic requirements in courses and programs.

KPI

An agreed framework and process to identify inherent academic requirements is developed, with a scaffolded timeframe of compliance for all courses and programs.

  • PVC (Students)
  • December 2015

xii. Develop inclusive strategies to engage students with disabilities in extension and extra-curricular opportunities; e.g. international study opportunities.

KPI

Representative percentage of students with disabilities participating in extra-curricular and extension activities.

  • Executive Deans and Heads of School of Law
  • Director USC International
  • December 2016
  • December 2017

xiii. Provide an annual report on the access, participation and success rates of students with disabilities across the University.

KPI

Comprehensive data with accompanying analysis is made available to the Senior Executive and/or relevant committee on an annual basis.

  • PVC (Students)
  • June Annually

xiv. Provide professional development opportunities for academic staff on their responsibilities regarding students with disabilities and the range of support and information available.

KPI

Academic staff understand their obligations related to reasonable adjustment and are appropriately supported in catering for the needs of students with disabilities.

  • Executive Deans
  • Heads of School of Law
  • June 2016
  • December 2015
Section 3: There are no Action Statements for Section 3
Section 4
DAP Action Statement Designated Officers Target Date

xv. Review the Vice Chancellor's Equity Advisory Committee composition and Terms of Reference with a view to facilitating a greater capacity for monitoring and providing advice in this area.

KPI

Draft Terms of reference and suggested models are provided to the Vice Chancellor.

  • Director    Student Life and Learning (as Executive Director to the Committee)
  • June 2015

xvi. Review strategies to encourage suitably qualified people with a disability to apply for positions at all levels across the University.

KPI

Strategies to encourage potential applications with disabilities to apply for positions have been reviewed, with improvements implemented and embedded into normal practice.

  • Director HR
  • December 2017

xvii. Promote the University's policies on prevention and management of Discrimination and Harassment and grievance resolution procedures to current and prospective staff.

KPI

EO online completed by all staff.

Information provided in all relevant staff development programs (e.g. supervisor, sessional staff training).
  • Director HR
  • December 2017

xviii. Assess student and graduate satisfaction and graduate employment outcomes relating to students with disabilities.

KPI

Comparative analysis published related to students with disabilities to ascertain their satisfaction and outcomes.

  • Director SIAU
  • June 2016
xix.Develop an audit process to ensure regular monitoring of physical accessibility and appropriate signage of USC buildings, grounds and facilities.

KPI

Process to facilitate carrying out of annual audit of building accessibility and signage developed and implemented.

  • Director    Facilities Management
  • December 2016

xx. Develop an on-line process for recording implementation of and progress against Disability Action Plan Action Statements.

KPI

Electronic template linked to Disability Action Plan, which can be accessed by Implementing Officers for input, and identified senior officers for reporting processes.

  • Director Student Life and Learning
  • June 2016
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