Third Disability Action Plan

2013 - 2016

Contents
Introduction............................................................................................................... 3
About the TIO............................................................................................................ 4
The current environment...........................................................................................4
Legislative context.................................................................................................5
Dispute resolution schemes...................................................................................5
The principles......................................................................................................... 6
Methodology.......................................................................................................... 6
Monitoring and evaluation......................................................................................7
Key findings and lessons............................................................................................ 7
TIO staff survey outcomes......................................................................................7
Action plan................................................................................................................. 8
Objectives and strategies.......................................................................................8
Goals...................................................................................................................... 8
Action plan table........................................................................................................ 9
Appendix 1.............................................................................................................. 14
Review of the TIO Second Disability Action Plan...................................................14
Objective 1 organisational culture.....................................................................14
Objective 2 accessible information....................................................................14
Objective 3 accessible complaint resolution services........................................15
Objective 4 physical environment......................................................................15
Objective 5 monitoring and evaluation..............................................................15

Third Disability Action Plan

Page 2 of 17

Introduction
I would like to dedicate this, our third Disability Action Plan, to the memory of the
Reverend Dr Christopher Newell AM, who served on the TIOs Council as a
representative of the Australian Federation of Disability Organisations.
Christopher, who lived with an illness that caused him to be wheelchair bound, was the
driving force behind the TIOs first and second disability action plans. Our second
disability action plan formally concluded in 2010. But many of the lessons that we
learned are being continually applied in our work today.
Some of the major deliverables of our second plan were:
our website, which meets WCAG 2.0 A standard, was delivered in September
2011.
a significant training program, which included disability awareness, deaf
awareness and National Relay Service training
an outreach program through which the TIO attended conferences and visited
organisations that represented people with disabilities.
Since the advent of our last plan in 2007, the telecommunications industry has changed
substantially, offering challenges and benefits for people with disabilities. The
underlying principle of this plan is inclusion. Through it we aim to capitalise on the
diversity and dedication of our staff, the creativity of our member companies and the
cooperation of our external stakeholders to provide a first-class complaint resolution
service for all Australians.
Simon Cohen
Ombudsman
October 2013

Third Disability Action Plan

Page 3 of 17

About the TIO

The TIO operates with a vision to deliver an exceptional telecommunications dispute
resolution service for consumers, service providers and the Australian community. It
also aims to contribute to better customer service and complaint handling within the
telecommunications industry.
The TIO plays four main roles in the telecommunications industry:
Resolving disputes: the TIOs first and primary role is to provide a dispute
resolution service that is accessible, independent, fair, efficient, responsive and
effective.
Improving telecommunications services: the TIO assists telecommunications
service providers and their industry to improve their services to consumers,
through identifying systemic issues and engaging with industry representatives.
Being an independent voice: the TIO is an independent and expert voice about
matters affecting telecommunications consumers. We provide information and
analysis to government and industry, and reach out to the community.
Leading by example: the TIO is innovative, adaptable, collaborative,
responsive, resilient and forward thinking. We value very highly the work of our
people and support their ongoing development of knowledge and skill.
These roles are articulated in our strategic plan and are the building blocks for our
action plan (see page 8).
The TIO is the elevated complaint handling body for the National Relay Service
This is the third disability action plan for the TIO and seeks to deliver maximum service
benefit for people with disabilities and cultural growth and development for the TIO.

The current environment

The Australian Bureau of Statistics (ABS) records that one in five Australians have a
disability thats close to four million Australians. Further, over six per cent or 1.2
million Australians have a profound or severe level of core activity limitation, and the
rate of disability increases with age.
65% of people with a disability would consider moving to a service provider that shows
leadership in providing disability confident customer service (Australian Network on
Disability, 2012).
5.5 million Australians are carers of children, ageing parents and family members with
disabilities or health issues (Australian Human Rights Commission, 2013 as sourced
from the Australian Bureau of Statistics).

Third Disability Action Plan

Page 4 of 17

Age
group
Aged 15

Likely to have a
disability
1 in 15

Aged 25

1 in 10

Aged 45

1 in 5

Aged 60

1 in 3

Aged 75

1 in 2

Table 1 Disability by age

92% of primary carers for children with disability are women (Australian Human
Rights Commission, 2013 as sourced from the Australian Bureau of Statistics).
Telecommunication services play a vital role in the lives of all Australians. They
facilitate business, employment, community participation and social interaction.
However, some people with disability find it difficult to make effective use of
telecommunications services.

Legislative context
There are four important Acts and policies that inform the development of disability
action plans within the telecommunications industry. They are:
The Disability Discrimination Act 1992 provides protection for everyone in
Australia against discrimination based on disability.
The Telecommunications (Consumer Protection and Services Standards) Act
1999 mandates a Universal Service Obligation to ensure that standard telephone
services are reasonably accessible to all people in Australia on an equitable basis
and internationally.
The United Nations Convention on the Rights of Persons with Disabilities.

The Federal Governments National Disability Strategy, launched on 18 March

2011, which sets as a policy direction the need for communication and
information systems to be accessible, reliable and responsive to the needs of
people with disability, their families and carers.

Dispute resolution schemes

As part of the preparations for this plan, the TIO reviewed practice in other Ombudsman
schemes. No industry dispute resolution schemes have disability action plans.
In 1997 the Commonwealth government facilitated the development of a set of
benchmarks to guide industries to develop and improve complaint resolution schemes.
There are complaint resolution schemes for banking, telecommunications, insurance,
and energy and water.
The benchmarks were developed to apply primarily to nationally-based customer
dispute schemes set up under the auspices of an industry and drafted primarily with a
focus on individual consumers as users of the schemes.

Third Disability Action Plan

Page 5 of 17

The benchmarks have a three-fold purpose.

They act as a guide to good practice for those industry sectors with a scheme to
resolve disputes between their industry members and individual consumers of
their goods or services.
They provide objective guidance on the practices to aim for in the operation of
complaint resolution schemes.
They serve as a guide for consumers in giving them some idea of what they
should expect from such schemes.

The principles
Accessibility
The scheme makes itself readily available to customers by promoting knowledge
of its existence, being easy to use and having no cost barriers.

Independence
The decision-making process and administration of the scheme are independent
from scheme members.

Fairness
The scheme produces decisions which are fair and seen to be fair by observing
the principles of procedural fairness, by making decisions on the information
before it and by having specific criteria upon which its decisions are based.

Accountability
The scheme publicly accounts for its operations by publishing its determinations
and information about complaints and highlighting any systemic industry
problems.

Efficiency
The scheme operates efficiently by keeping track of complaints, ensuring
complaints are dealt with by the appropriate process or forum and regularly
reviewing its performance.

Effectiveness
The scheme is effective by having appropriate and comprehensive terms of
reference and periodic independent reviews of its performance.
The principles underpin the service delivery of the TIO and are inherent in the
actions of the DAP.

Methodology
Successful DAPS are the result of considered and extensive planning and preparation.
The development of this DAP has included:

Third Disability Action Plan

Page 6 of 17

a review of best practice around the world and the identification of key learnings
and strategies
consultation with all key internal (Council members, Executive and staff) and
external stakeholders from the telecommunications and disability sectors
a survey of staff and stakeholders
feedback on the draft plan with the TIO Disability Action Committee and key
stakeholders

Monitoring and evaluation

This DAP will be delivered by the Disability Action Committee at the TIO.
The review of the DAP will become a standing agenda item at each quarterly meeting of
the Disability Action Committee and an annual report will be produced independently
and provided to the TIO Council (or in the event the Council ceases to exist, the Board)
as part of their ongoing governance role.

Key findings and lessons

This information was gleaned during the development of the TIOs Third Disability
Action Plan. Telecommunications accessibility varies around the world. Australia is
well advanced in research and philosophy. However, it is behind in action.
People with disabilities rely on industry to introduce technological advances into
accessible practice. Delay in doing so impedes the human rights of people with
disabilities. There is an overwhelming amount of research into best practice for people
with disabilities.
The next iteration of DAPs (evidenced by what is occurring in the United States) is
focused on how to create diversity and maximise inclusion in the workplace rather than
how to deal with a diverse workplace. Progressive organisations seek to influence
others through vehicles such as procurement policies and enable through proactive
recruiting policies.
Lots of plans are still going through the motions at a very low evolutionary stage.
Leadership is key. The most evolved plans focus on leadership to enable cultural
change.
Best-practice plans ensure ownership is included and assured through performance
plans. Proactivity is in best practice plans creation of networks, active recruiting, links
to values and behaviours
Best practice organisations have quotas for people with disabilities and other minority
groups. If your market is diverse, then to lead and understand that market you must be
diverse from within.
There is great variety around the world in approaches legislation is in place, its the
implementation that varies. The United States based global corporates are leading the
world focusing on inclusion and proactively seeking diversity.

TIO staff survey outcomes

More than half the current staff of the TIO were unaware of the existence of the
previous DAP and staff were not aware of reporting.
Third Disability Action Plan

Page 7 of 17

Action: More staff awareness through reporting and socialization of the plan is
required.
The most successful activities of the previous DAP (as viewed by employees) were the
establishment of the new website and disability awareness training.
Responsibility for actions in the previous DAP were viewed as belonging to a very
small number of people across the business and were not included in performance plans.
Action: Broaden ownership of DAP goals to all employees through links to the TIO
strategic plan, ownership by Disability Advisory Committee and actions included
in performance plans
Two of the major challenges for staff in assisting people with disabilities are equipment
or tools that do not support the complainant or the staff member or a lack of
understanding of the process by the complainant.
Action: Staff training and improved clarity of complaints process for TIO
members, consumers and TIO employees

Action plan
Objectives and strategies
An over-arching theme resulting from consultation was the interaction and engagement
of the TIO with its key stakeholder groups including people with disabilities. The
establishment of a critical friends group with a benchmark accountability to represent
key customer groups of the telecommunications sector will provide a voice directly to
the TIO.
The TIO is committed to promoting inclusion for people with disability and ensuring
that they have equal awareness of, and access to, our service. The TIO Disability
Action Plan identifies actions which, as well as being aligned with our broader business
strategy, will mean the TIO fulfils its obligations under State and Commonwealth laws
to eliminate discrimination based on disability.

Goals
1. People with disabilities are aware of, and have equitable access to, the TIO
2. People with disabilities have a voice, influencing how the TIO delivers its own
services, and how it provides key consumer information to industry about the
disability issues sector.
3. The TIO promotes an organisational culture that is responsive to the needs of
people with disabilities.

Third Disability Action Plan

Page 8 of 17

Action plan table

Action

Performance
Responsibility
Timeframe
indicator
Leading by example
Where we want to be
An organisation that scans our environment and responds to our stakeholders' needs
through innovative strategies and work practices.
Engaged people who are highly motivated in their roles, and continuously learning.
Establish a Critical
Friends Group
composed of
people with
disabilities to
ensure that the TIO
is actively engaged
with the disability
sector.
Develop a recruiting
strategy to identify
positions which are
suitable for
employment of
persons with a
disability.

Critical Friends
Group meets
annually and works
effectively to
identify and discuss
emerging disability
issues

Disability Action
Committee led by
the Community
Liaison Manager

Annually with first

meeting to be held
by June 2014

Employ a person(s)
with a disability
during the life of
the plan

Manager People and

Development

Strategy by June
2014
Recruitment by June
2015

Consult with staff

members who
advise the TIO of
disability issues,
about how those
issues affect their
employment or the
employment of
their colleagues.

Report completed
each year to
satisfaction of
Council and
Executive.
Executive to
consider and decide
on any
recommendations
from the report
within three
months.

Manager People and

Development

June 2014
June 2015
June 2016

Third Disability Action Plan

Page 9 of 17

Action

Performance
indicator
Review to be
completed to
satisfaction of
Council and
Executive.
Executive to
consider and decide
on any
recommendations
from the Review
within six months.

Responsibility

Timeframe

Manager People and

Development

September 2014

Establish terms of
reference for the
Disability Action
Committee (DAC).
Review
membership of the
committee
periodically to
ensure that
appropriate
business units and
expertise are
represented.

A committed and
engaged DAC that
will be responsible
for the deployment
and monitoring of
the disability action
plan. DAC
responsibilities to
be incorporated into
individual
performance plans.
Disability action
committee to meet
monthly.

Executive Director
-Industry
Community &
Government

Committee
members to be in
place by October
2013

Develop a
community
awareness strategy
that delivers a
consistent schedule
of engagement with
key stakeholder
groups.

A communications
plan is developed
which incorporates
feedback from the
Critical Friends
Group.
Opportunities to
increase access to,
and for, people with
disabilities are
explored through
liaising with other
Ombudsmen
schemes and
through potential
partnering.

Community Liaison
Manager to
coordinate. All
divisions within TIO
to participate.

Annual calendar to
be completed by
December each
year.

Review TIO
practices to identify
potentially
discriminatory
practices and
opportunities to
promote inclusion

Third Disability Action Plan

Page 10 of 17

Action

Performance
indicator
Revised audio files
to be uploaded on
the website by June
2014

Responsibility

Timeframe

Community Liaison
Manager
Communications
Officer

June 2014

Annually review for

potential
improvements to
office accessibility
for people with
disabilities.

TIO arranges for

annual,
independent review
of our offices and
develops
appropriate action
plans for
substantive
recommendations

Administration and
Facilities manager

Jan 2014
Jan 2015
Jan 2016

DAC reports
annually to the
Council (in the
event the Council
ceases to exist, the
Board) and TIO
Executive about
progress against
the DAP and to
identify emerging
consumer issues

Report completed
to satisfaction of
Council and
Executive

Executive Director
-Industry
Community and
Government,
Community Liaison
Manager

June 2014
June 2015
June 2016

Review plan
annually and at
completion, report
to the TIO
Executive and the
Critical Friends
Group.

Satisfactory report
from reviewer
Independent review
to occur at end of
plan

DAC, Executive
Director -Industry,
Consumer and
Government

June 2014
June 2015
June 2016

Review the TIO

brochures to ensure
that they are
accessible by
people with vision
disabilities.
Develop revised
audio versions of
the TIO's
promotional
materials.
Develop accessible
versions of this
plan.

Third Disability Action Plan

Page 11 of 17

Action

Performance
indicator

Responsibility

Timeframe

Resolving disputes
Where we want to be
Increase TIO accessibility through:
increased hours of operation
appropriate use of new technologies
appropriate guidelines to determine if matters referred or conciliated at first
instance
Ensure that all
complaint channels
are accessible by
people with
disabilities.

TIO will monitor

and refine
complaint channels
to ensure they are
accessible for
people with
disabilities.
Annual review of
complaint channels
with Critical
Friends Group

Deputy
Ombudsman,
Manager Dispute
Resolution
Operations

June 2014
June 2015
June 2016

Online channel to
meet best practice
accessibility
guidelines.

TIO website to be
WCAG 2.0 AA
compliant.
Social Media
platforms to meet
equivalent of
WCAG 2.0 AA
standard
All documents
posted to TIO
website to be
available as html,
MS Word, PDF and
rich text formats.

Communications
Manager and Online
Communications
Officer

December 2014

Establish a
proactive training
program to ensure
staff understand
the diversity of
disabilities and the
specific
communications
issues for people
with different
disabilities.

Establishment of an
efficient and
effective training
program that runs
through the life of
the disability action
plan.

Manager - Dispute
Resolution Quality,
Learning and
Development
Officer

Third Disability Action Plan

Page 12 of 17

Training program to
commence by July
2014

Action

Performance
Responsibility
Timeframe
indicator
An independent voice
Where we want to be.
We want to continue to be smart users of new media to increase the accessibility of our
information and awareness of our services.
TIO publicises
information about
disability issues and
about industry
improvement
activities it has
undertaken
Establish an up-todate
Communications Community
Relations database.

Consumers are
informed through
bi-annual articles in
TIO publications
about emerging
issues and how TIO
has sought to
address them
Existing TIO Talks
database to be
reviewed and
segmented into
target audiences,
ie:

Community Liaison
Manager and
Communications
Officer

Two articles per

annum in
2014/15/16

Community Liaison
Manager

Review to be
completed by
December 2013
Segmentation to be
completed by March
2014

financial
counsellors
disability
advocacy
organisations
CALD groups
service providers
regulators
Indigenous
service providers

Establish a mailing
list of disability
related
organisations in
Australia

Ensure that 20% of

Communications,
Mailing list to be
all disability-related Community Liaison
established by
organisations
Manager.
February 2014
subscribe to TIO
20% target to be
Talks database
achieved by June
during the life of
2014
the plan.
Click through rate to
Attain a click
be established by
through rate of 15%
December 2014
on all TIO Talks
articles from
disability related
groups.
Improving telecommunications services
Where we want to be
More effective and responsive use of TIO information including complaints, statistics
and other intelligence to identify and act or root causes of detriment to consumers (as
evidenced by complaints to the TIO.)
An identified role for the TIO to build the capacity of TIO members and the
telecommunications industry, to more effectively respond to consumer complaints.

Third Disability Action Plan

Page 13 of 17

Action
TIO analyses
complaints data
and information
provided by
disability consumer
advocates to
identify accessibility
and other issues
affecting consumers
with disabilities,
and to raise these
issues with Industry.

Performance
indicator
TIO Industry
Improvement Team
analyses
complaints data
and reports to
Disability Action
Committee
quarterly on
disability issues.

Third Disability Action Plan

Page 14 of 17

Responsibility

Timeframe

Industry
Improvement Team

Quarterly during life

of plan

Appendix 1
Review of the TIO Second Disability Action
Plan
The second plan focused on five key areas and identified actions required in each of
these areas. The areas were:
organisational culture: to develop and maintain a responsive and nondiscriminatory organisational culture
accessible information: to improve accessibility to information about the TIOs
services
accessible complaint resolution services: to provide equitable access to the TIOs
complaint resolution services
physical environment: to ensure that the TIOs physical environment is
accessible to all
monitoring and evaluation: to ensure that the DAP is regularly reviewed and
evaluated.
The second plan achieved a number of significant goals, some of which are outlined
below. Several other initiatives, which were not part of the second plan, were achieved
subsequent to its completion in 2010.

Objective 1 organisational culture

Staff training

Extensive training was conducted during the life of the plan and shortly after its
completion. At the commencement of the plan, all TIO staff received disability
awareness training. In 2011, VicDeaf conducted training in deaf awareness and the
operation of the National Relay Service.
EEO employment

The TIOs recruitment policy was updated in November 2011. All TIO employment
advertisements encourage people with disability to apply. We have worked with
specialist employment agencies that provide employment for people with disabilities. To
date no suitable candidates have been identified.
Updated versions of the Equal Employment Opportunity (EEO) and Occupational
Health and Safety policies (OH&S) have been approved.

Objective 2 accessible information

Since the inception of the second plan, all promotional information, with the exception
of our brochure in languages other than English, has been produced in consultation with
Vision Australia. All promotional material is also available on our website in audio
formats.
Third Disability Action Plan

Page 15 of 17

Although not specifically related to people with disabilities, the plan required the TIO to
review, update and make available fact sheets in languages other than English. During
the course of the plan, 31 fact sheets have been produced. The same information has
produced in a brochure. A total of 50,000 of these brochures have been distributed
nationally.
During the life of the plan, the Community Liaison Manager produced a fact sheet,
Consumers with Disabilities and the TIO, which was distributed nationally. The
Community Liaison Manager also met with key government officials in all the eastern
states. We communicated similar information to their counterparts in other states by
email.
Since the inception of the plan and beyond, the TIO has also regularly attended at least
three conferences each year involving people with disabilities

Website
The website, which was unveiled in September 2011, was developed to meet Web
Content Accessibility Guidelines 2.0 (WCAG) standard Level A1 with Level AA where
possible. Since its inception, a number of features have been added to the site to make it
more accessible for people with disabilities. This includes an Auslan video, produced in
cooperation with VicDeaf.

Objective 3 accessible complaint resolution

services
More than a third of new complaints to the TIO are lodged via the online form on our
website. In 2012, the TIO worked with Vision Australia during the development of the
online form by Resolve, the software vendor for our Radar complaints management
system. Resolve has assured us that the form meets WCAG 2.0 Level A and will meet
Level AA in 2014.
During the life of the plan, the TIO met formally with several advocacy groups for
people with disabilities. Of note were several conversations with the Australian
Communications Consumer Action Network. These organisations provided information
to allow us to identify barriers to accessibility and modify our processes accordingly.

Objective 4 physical environment

A disability access audit of our premises was conducted in June 2009. The TIO has
made many of the changes recommended by this audit on a one-off basis. Others were
made during regular maintenance work.

Objective 5 monitoring and evaluation

Several performance measures were developed to evaluate the plan. They were:
1

Web Content Accessibility Guidelines 2.0 (WCAG 2.0) is an international standard

that defines how to make web sites more accessible to people with a range
disabilities. These are arranged in three levels with level A (the lowest), being the
most fundamental and essential. The Federal Government mandated that the
websites of all its agencies meet WCAG 2.0 Level A by December 2012. All Federal
Government sites must meet Level AA in 2014.
Third Disability Action Plan

Page 16 of 17

the number of formal staff and complainant grievances relating to disability

access
the number of grievances dealt with efficiently and effectively with positive
outcomes
awareness of the TIO among people with disabilities according to TIO public
awareness survey
feedback from people with disabilities and disability groups regarding
accessibility of the TIO to people with disabilities
the disability action plan is monitored and reviewed on an ongoing basis

the disability action plan is evaluated and revised as required.

Rather than focussing on raising awareness directly with consumers, with the
second plan the TIO resolved to focus on intermediary groups representing those
consumers.
The plan was monitored by the TIOs Disability Action Committee, with
occasional reports provided to the Ombudsman and Council members.

Third Disability Action Plan

Page 17 of 17