Irish Congress of Trade Unions response to Improving the job prospects and working careers of people with disabilities in Northern Ireland.
1. About Congress
The Irish Congress of Trade Unions (ICTU) is the trade union federation and largest civil society organisation on the island of Ireland representing and campaigning on behalf of some 832,000 working people. There are currently 55 unions affiliated to Congress, north and south of the border.
In Northern Ireland, there are 39 trade unions and Councils of Trade Unions affiliated representing over 230,000 workers. Through Congress, workers play an important role in the economic and social life of our community.
Congress strives to achieve economic development, social cohesion and justice by upholding the values of solidarity, fairness and equality.
Congress also constructs and advocates for a platform of policies capable of delivering our vision of a just society.
2. Introduction
In considering a response, ICTU has consulted with the NIC ICTU Disability Committee which is made up of representatives from affiliated unions and has the aim of promoting decent work for people with disabilities and advocating for a fair society for all citizens.
The NIC ICTU Disability committee welcomes the opportunity to respond to this draft strategy and commends the Minister, his Department and the Officials who put in considerable work to develop this draft. We would like to note that the restructuring of the Government Departments has the potential to reduce this level of commitment to the implementation of the strategy. The retention and location of the Disability Employment Service is of crucial importance to the success of this strategy.
ICTU works with a range of Disabled People’s Organisations and expects that they will be closely commenting on many aspects of this draft strategy. We are pleased to endorse many of the recommendations made by Disability Action in their response to the consultation and will highlight particular points at the end of this submission.
3. As the representative body for trade unions throughout Northern Ireland, ICTU welcomed the opportunity to join the strategic working group which advised the Department on this draft strategy. In general, we endorse the five broad themes laid out in the consultation document and we welcomed the collaborative approach from the Department in relation to the development of the draft document.
However we are disappointed that the role of trade unions in developing and implementing an employment strategy for people with disabilities is barely mentioned in the document.
For example, in theme 3, working with employers, we consider that trade unions should play a significant role in ensuring that disabled people have equal access to the workplace.
One of the proposals that will introduce something new – ‘establish a network of high profile disability advocates’ is of particular relevance.
Over the last number of years, ICTU has led on a number of initiatives which have made a real difference to the lives of disabled people. Chief among these has been the Disability Champions project.
Through the Disability Champions project, ICTU has trained trade union members and representatives, many of whom are disabled, to become advocates for disability in the workplace. Disability Champions have a positive role in the workplace supporting colleagues and members on issues such as reasonable adjustment. Disability Champions also work closely with employers to develop and promote a positive working environment for all employees, including people with disabilities.
After their initial training, Disability Champions are supported by their unions and also by ongoing training which is delivered by organisations such as the Equality Commission.
ICTU would strongly suggest that there is a positive role that Disability Champions can play in the development and success of this strategy, particularly in relation to theme three.
We note that the Department has liaised with DWP in relation to their Disability Confident Campaign in GB which includes establishing a network of disability advocates. The Department is aware that, as outlined above, establishing a network of Disability Champions is something that the trade union movement has been engaged with over the last ten or so years. We would therefore recommend that the Department liaise with ICTU in relation to the Disability Champion project and consider how this valuable network of people can be best utilised and supported in relation to this strategy.
We would further recommend that trade unions, along with organisations from the disability sector, are consulted in relation to the development of a best practice recruitment support model. We would recommend that any such best practice model contain information on the rights of all employees to join a union and is also compliant with all of the relevant employment and equality legislation. In this regard, we believe that it would be useful to consult the Equality Commission for Northern Ireland.
We agree that it would be useful for employers, and others, to be able to access information and support from the Department.
We would recommend that this is done on a joined up basis and includes other Departmental initiatives such as apprenticeships and career, advice and guidance.
We agree that the Department should prioritise strategic partnership and engagement. However we are again disappointed that there is no mention of trade unions in relation to this.
The draft document states that the membership of the Disability Stakeholder Forum should consist of senior officials, senior management from the disability sector as well as representatives from other departments together with employer representation, a disability champion and a disabled person. Given the valuable role which the representative from ICTU played in the strategic advisory group, we are surprised not to see trade unions included.
We would recommend that trade unions are included as a strategic partner in the Disability Stakeholder Forum.
4. International Human Rights Framework
All strategies produced by the NI Executive must be compliant with international human rights obligations.
The disability employment strategy must be contextualized within International Human Rights Law. The strategy should therefore address, through it’s actions, the obligations issuing from, inter alia, the United Nations Convention of the Rights of the Child (UNCRC), the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD), the UN Convention on the Elimination of Discrimination against Women (CEDAW) and the International Covenant on Social, Economic and Cultural Rights (ICSECR).
Recommendation:
The strategy is underpinned by the obligations on the NI Executive arising from human rights law.
5. Research and Development
We are pleased to see that research and development has been prioritised.
We agree that independent research should be commissioned and that this should be done in close partnership with disabled people and the organisations which represent them.
We would recommend that the strategy includes detail of how it will be monitored and evaluated. This should include clear targets against each of the actions and the collection of baseline information against which the targets can be monitored. This should be done in a timely fashion to allow the Department and key stakeholders to evaluate whether the strategy is succeeding.
Other points:
- We welcome the supported employment approach to securing and maintaining employment and welcome the adoption of this model;
- We are concerned that changes to the welfare and social security system will impact disproportionately on disabled people and their families. The strategy must ensure that the work opportunities available for disabled people have the flexibilities built into them that allow people to work without it affecting their benefit – for example the 16 hour rule. We agree with Disability Action in relation to offering Workable NI below 16 hours and note that the model of best practice in relation to Supported Employment suggests that there should not be a minimum number of stipulated houses.
- We have argued elsewhere that there should be a joined up approach in relation to other strategies and we agree with Disability Action in relation to their recommendation that frontline staff such as employment and careers advisers should be trained in the particular needs of disabled people.
- We agree that setting targets are an important way of measuring the success of the strategy. However, we agree with Disability Action in relation to the concern they raise that setting targets has the potential to drive services towards recruiting people who can quickly and easily progress to employment.
- The consultation document contains no proposed actions relating to self -employment and this could usefully be addressed in the implementation plan.
- We agree that the strategy should address the limited opportunities available for disabled people to progress throughout their careers. We believe that Disability Champions, as outlined earlier in the response, could play a useful role in this regard. We also believe that this issue cannot be considered without considering issues such as reasonable adjustment. Many of the issues which give rise to claims under the DDA could have been resolved if the employer had considered reasonable adjustments. Therefore we recommend that the ‘one stop shop’ offered for employers should also provide signposting to the training already offered by the Equality Commission NI.
- We agree that the strategy must prioritise engagement with employers. We agree with Disability Action’s comments in regards to this and consider that one large engagement event may not be as effective as a number of smaller and more localised events.
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