Chapter 3: The planning duties and main priorities for the accessibility strategy
1. This Chapter provides guidance to responsible bodies on the Act's requirements for increasing access to school education for disabled pupils.
2. As noted previously, the accessibility strategy must refer to how the responsible body intends to:
- increase the extent to which disabled pupils can participate in the curriculum;
- improve the physical environment of schools to increase the extent to which disabled pupils can take advantage of education and associated services; and
- improve communication with disabled pupils along with communicating to them information that is provided in writing for pupils who are not disabled, in appropriate alternative formats and taking account of any preferences expressed by them or their parents.
3. Further guidance on aspects covered by the three planning duties above is provided below.
4. It is for responsible bodies, in drafting their strategies, to decide whether or not they wish to include their improvements under separate headings or combined, or in any other way. For example, for local authorities improvements may be detailed in respect of each school that will benefit from them, with a separate heading for authority-wide initiatives.
5. In preparing accessibility strategies, authorities will be required to consider the duties, once commenced, under the Children and Young People (Scotland) Act 2014, to consider and assess wellbeing, and report on outcomes for children in terms of wellbeing.
6. Education authorities' strategies should cover all the schools, nurseries and pre-school centres for which they have responsibility. They should also cover the provision of nursery classes in local authority centres, which are not schools, such as community centres, and any education provided by the authority in, for example, portable cabins on Gypsy/Traveller sites. Wherever this guidance refers to schools this should be interpreted as including nursery schools and classes, local authority nursery classes in non-school centres and any education provided on Gypsy/Traveller sites. Education authorities may also wish to include provisions in relation to children receiving education in hospital settings, however, there is no requirement under the Act to do so.
7. Education authorities' duties under the Act regarding children under school age do not cover education provided by private and voluntary sector bodies working in partnership with education authorities. In particular, education authorities are not required to include these providers in their accessibility strategy. However, in negotiating contracts with these providers education authorities will wish to ensure that these providers are committed to improving access to education for disabled pupils.
8. Responsible bodies, which are also public bodies, should take account of their responsibilities under the general duty of the Equality Act  to advance equality of opportunity and to make accessible any out-of-school care services provided on school premises. This would apply even though a voluntary or private organisation may be the provider of such a service. In these circumstances the responsible body would be expected to work with the group providing the out-of-school care to ensure that these facilities are accessible to disabled pupils under the Equality Act.
Guidance on the three planning duties to increase access to school education for disabled pupils
Improving access to the curriculum
(2) An accessibility strategy is a strategy for, over a period prescribed by regulations -
(a) increasing the extent to which pupils with a disability can participate in the school's curriculum or, as the case may be, the schools' curriculums;
9. The Act does not define what is meant by the curriculum. However, through Curriculum for Excellence  the curriculum in Scotland is recognised as the totality of experiences which are planned for children and young people through their education, wherever they are being educated. This totality includes the ethos and life of the school as a community, curriculum areas and subjects, interdisciplinary learning and opportunities for achievement.
10. Disabled pupils have exactly the same curriculum entitlements as their non-disabled peers.
- a curriculum which is coherent from 3 to 18
- a broad general education, including the experiences and outcomes which are well planned across all the curriculum areas, from early years through to S3
- a senior phase of education after S3 which provides opportunity to obtain qualifications as well as to continue to develop the four capacities
- opportunities for developing skills for learning, skills for life and skills for work with a continuous focus on literacy, numeracy and health and wellbeing
- support to enable them to gain as much as possible from the opportunities which Curriculum for Excellence can provide
- support in moving into positive and sustained destinations beyond school.
Curriculum for Excellence: building the curriculum 3
11. Many of the barriers to full participation in education may be similar for groups of children and young people and, therefore, it will be useful for the responsible body to take a strategic approach to removing these barriers. For example, an authority may wish to describe in its accessibility strategy how learning support and auxiliary provision could be better distributed across the authority's schools. Or, responsible bodies may wish to establish a policy for the provision of auxiliary aids, such as specialist equipment, for pupils with certain disabilities and to negotiate new contracts, where necessary, for supplying auxiliary aids. Similarly, they could consider implementing a strategy to make curriculum resources, that are currently paper-based (such as textbooks or worksheets), available in electronic formats to assist pupils with print disabilities.
12. Accessibility strategies should include details of how the responsible body intends to help increase the extent to which disabled pupils can fully access the curriculum by securing staff training and considering the use of alternative approaches for teaching and support. Schools should be encouraged to share good practice and collaborate on initiatives with other schools or agencies, such as therapists and other health professionals. When preparing strategies, school staff should be encouraged to inform the planning group preparing the strategy not only about areas for improvement, but also to contribute examples of good practice, where initiatives are working well.
13. For pupils with complex education, health and/or social needs, education authorities should aim to ensure that their accessibility strategies plan for an integrated approach to delivering improved access to the curriculum in line with the ASL Act, and the principles of Getting it right for every child. While individual children may have a Child's Plan outlining the targeted interventions to be provided by a range of services, a key principle of GIRFEC is that better early intervention and prevention should enable more children to have their wellbeing needs met in a more inclusive way through universal services.
14. When considering provision for disabled children and young people with significant health needs, professionals, social workers and other stakeholders such as third sector organisations should be involved fully and consulted in the preparation of the strategy. The strategy can also usefully describe arrangements for improving working with health professionals other agencies and the third sector as part of the Getting it right approach.
15. In considering how disabled pupils' access to the curriculum can be improved, responsible bodies should not just look at specific curriculum areas and subjects such as, English, mathematics, languages, sciences, music and physical education. In line with Curriculum for Excellence and its broader framework for learning and teaching they should also consider aspects of the curriculum as set out in Chapter 3, paragraph 8 above. Planning should include initiatives to:
- overcome any barriers which prevent or make it difficult for disabled children and young people to participate fully in school trips and activities such as school plays, after-school clubs and study support clubs; and
- ensure that the ethos of the school is one which celebrates diversity and encourages inclusion.
Information and Communications Technology
16. Information and Communications Technology ( ICT) has an important part to play in ensuring that disabled children and young people maximise their opportunities for accessing the curriculum. As part of their accessibility strategies, responsible bodies should make certain that contracts for any future supply of computers or upgrade of existing stock ensure that the computers (and associated furniture) are accessible or can easily be modified to be accessible to pupils with disabilities. They should also ensure that teaching staff are aware of, and can receive specialist advice on, the use of accessible software and websites which are available.
In reviewing existing contracts and, if necessary, negotiating new ones, a commissioning body should ensure that:
- specialised items of hardware and software, such as an alternative keyboard, mouse or switches can be added easily;
- software needed by pupils with disabilities, such as speech output or screen magnification, can be installed and used;
- the full range of accessibility options within the operating system can be utilised, for example, to slow down mouse speed or keyboard repeat rate, or to enlarge screen fonts or reduce screen clutter, or to access context menus;
- equipment can be placed in accessible locations, for example, so that wheelchair users can reach the keyboard and see the screen;
- access privileges are flexible enough to enable staff to make necessary changes to afford access (for example, to adjust control panels or save individual settings for specific programs)
- personal devices used by disabled pupils for curriculum access can be connected to the school intranet;
- where such changes are required to improve access these do not occur additional cost.
17. As noted the Equality Act includes different forms of disability discrimination - including indirect discrimination and discrimination arising from disability. Responsible bodies can use their accessibility strategies to demonstrate how they will address these forms of discrimination. For example a local authority may identify continuous professional development needs to address the specific requirements introduced by the disability discrimination duties.
18. A number of responsible bodies are considering transferring responsibility for managing school computer networks to external arm's length organizations or private providers. For example, some are transferring responsibility to local authority corporate IT personnel. Responsible bodies will want to ensure that when undertaking ICT planning, provision is made for disabled pupils to access the curriculum through ICT. Accessibility strategies could describe:
- How websites or other curriculum materials in digital form are to be accessed.
- How assistive technology, possibly made available through auxiliary aids and services, can be used to access the curriculum or school information.
- Steps to be taken to ensure managed networks / corporate IT structures allow for changes to be made to individual computer operating system without additional costs incurred, thus helping to avoid discrimination arising from disability.
- How, when conducting regular housekeeping of school or authority network for MP3 or other files, files used by pupils are not deleted.
- Computer refresh arrangements that will take account of existing assistive technology software and associated files used by a disabled pupil or pupils
19. Appendix D provides a series of questions on communication and assistive technology that responsible bodies may wish to consider for planning purposes and in commissioning and procurement discussions.
20. Local members of ICT Support for Learning in Scotland ( ICTSLS)  can advise on ICT and inclusion as can Education Scotland  . CALL Scotland  can also provide more information on more complex improvements to provide improved access to the curriculum using ICT.
Books for All
21. Pupils who are blind or partially sighted generally benefit from printed materials made available in alternative formats such as in large print or Braille. Many other groups of print disabled pupils may also benefit from curriculum materials provided in alternative formats. Pupils with dyslexia may benefit from material provided in large print, or using a particular font, or printed on coloured paper. Some may prefer to use audio books or to use a computer which reads out text. Pupils with a physical disability may require material presented digitally on a computer which they then access using switches or other form of assistive technology.
22. The Books for All website  provides advice on how learning materials can be obtained, used and prepared in accessible alternative formats.
23. Since 2010, the Copyright Licensing Agency  ( CLA) has operated a 'Print Disability Licence'. This free licence, obtainable from the CLA, allows non-profit making organisations, such as local authorities and schools, to reproduce, and circulate, copyright works in a format accessible to print-disabled pupils. Alternative formats include large print, Braille or audio books. The licence covers provision of material to include not just those people who have a visual impairment but also those with any print disability that prevents them from accessing print materials such as books.
24. Responsible bodies may want to include in their accessibility strategies how they will implement arrangements like Books for All to benefit print disabled pupils by improving their access to curriculum materials.
25. The above examples demonstrate how a responsible body's duties to an individual disabled pupil under the Equality Act can be complemented by its planning duties through accessibility strategy reporting. In the former, there is a duty under the Equality Act to provide accessible information in an alternative format. This could be seen as a reasonable adjustment. At the same time the responsible body may introduce school based or system wide approaches to producing accessible information that will benefit larger numbers of print disabled pupils. Accessibility strategy planning encourages a systematic approach to evaluating current and future arrangements for disabled pupils.
Scottish Qualifications Authority
26. The Scottish Qualifications Authority ( SQA) allows for adjustments to be made to their published assessment arrangements so that disabled students are not placed at an unfair disadvantage when being assessed. The particular arrangements possible are described on the SQA website  and may include the provision of extra time to sit an examination or the use of a scribe or a reader. Since 2008 the SQA has also made available digital question papers which allow students to type directly into the paper on the screen  . The text in the paper can be magnified and can be used with assistive technology such as text reading programs and speech recognition software. The resources section also outlines support available for literacy qualifications.
Improving the physical environment
(2) An accessibility strategy is a strategy for, over a period prescribed by regulations-
(b) improving the physical environment of the school, or schools, in relation to which the strategy is prepared for the purpose of increasing the extent to which pupils with a disability are able to take advantage of education and associated services provided or offered by such school or schools
27. In Building Better Schools: Investing in Scotland's Future  the Scottish Government and the Convention of Scottish Local Authorities ( COSLA) set out jointly their vision and aspirations for the school estate. One of their aspirations is that all children and young people will be educated in schools that are 'fit for purpose' in terms of suitability. A suitable school environment is one which is fully accessible to all disabled pupils.
28. Advice for local authorities in assessing the suitability of school buildings is provided in the Scottish Government publication The Suitability Core Fact  published in 2008. Advice on internal design is provided in the Scottish Government publication School Design: Optimising the Internal Environment  , published in 2007.
29. In developing the school estate and improving its suitability with regard to meeting the needs of disabled people whether these are learners, staff or others accessing schools and their facilities, local authorities will have regard to the advice already issued by the government. Non-statutory advice produced by the Department for Education in Building Bulletin 102  Designing for disabled children and children with special educational needs: Guidance for mainstream and special schools is particularly helpful in optimising the design of mainstream and special schools to meet the needs of those who are disabled.
30. Useful advice is contained in the Handbook on Accessibility  published by the Scottish Council for Independent Schools and available as a free download.
31. Strategies may want to include accessibility of any boarding houses/residential facilities. In a similar way to its considerations under the 'access to the curriculum' category, the responsible body preparing the strategy should take a broad approach and also look to improve access outside as well as within schools; for example, through a negotiated contract to ensure that buses provided for all school trips are accessible to pupils with physical disabilities. Further guidance on outdoor learning, planning for school trips has been published by Education Scotland  . The responsible body should also consider whether changes are needed to their policy on transport for pupils, to and from school.
32. Improvements to arrangements will include:
- physical access (such as architectural planning for accessibility: the installation of ramps, handrails, widened doorways, lifts, automatic doors, accessible toilets, showers and changing areas, adapted/adjustable furniture and equipment, ensuring sufficient space for manoeuvring and storing equipment, floor coverings and evacuation procedures)
- access for pupils with visual impairments (such as: improvements to signage, route finding systems to enable pupils to find their way round a school easily, colour contrasting for example door handles and steps to enable pupils to make best use of their residual vision, adjustable lighting, blinds, tactile paving outside the school, evacuation procedures)
- access for pupils with hearing impairments (such as: induction loops/radio systems/infrared systems, adjustable lighting, sound insulation for walls, floors and ceilings, evacuation procedures, floor coverings)
- access for pupils with other disabilities (such as requirements for space: the provision of pupil support bases, quiet rooms, sensory rooms/play areas, therapy rooms, etc. and way finding systems). Occupational therapists and access officers should, wherever possible, be consulted for advice.
Improving communication and the provision of school information
(2) An accessibility strategy is a strategy for over a period prescribed by regulations-
(c) improving communication with pupils with a disability and, in particular, improving the communication to pupils with a disability-
(i) within a reasonable time; and
(ii) in ways which are determined after taking account of their disabilities and any preferences expressed by them or their parents,
of information which is provided in writing for pupils, or persons who may be admitted as pupils, who do not have a disability.
33. Improving the communication and delivery of information to disabled pupils is a key component of the Act and its requirements. The Act requires responsible bodies to improve their communication with disabled pupils generally. This means taking steps to ensure that in communicating with all pupils responsible bodies make sure that disabled pupils are included fully. For example a deaf pupil in a mainstream school may need to use an induction loop or have access to a sign language interpreter at school assemblies. School staff may need in-service training tailored to help them communicate effectively with pupils with specific language and communication difficulties. The role of the Named Person in health for pre-school children, and in education for school age children, will be key in supporting communication with disabled children and their families.
34. The third duty requires responsible bodies to improve communication with pupils with disabilities. Responsible bodies should take steps to improve how these pupils can give their views on any issue about which they have an interest, gather in those views and consider them. Consideration should be given to whether class work or homework could be given in alternative forms. This would include how any homework, or other work pupils do in alternative forms, can best be marked/commented on by school staff. Pupils' communication with teaching and auxiliary staff as part of their learning should also be considered under the "access to the curriculum" duty.
35. However, there will be other non-curricular activities, which pupils will be informed about and pupils with disabilities should be able to give their views or ask questions about these activities in the same way as their peers. Pupils should also be able to communicate with other staff, pupils or people working in a school, for example, in the dining room or in the school office.
36. Responsible bodies should consider how improving communication can be addressed through, for example, ensuring that awareness is raised amongst all school staff about the difficulties pupils with particular disabilities may have in communicating with other people.
37. The Act makes specific provision that the accessibility strategy should make reference to improving communication to disabled pupils regarding information provided in writing to pupils, or prospective pupils, who are not disabled. This provision covers written information which responsible bodies provide to prospective pupils in the form of, for example, brochures about the school, school development plans or other information such as inspection reports.
38. This information must be provided in a form which takes account of their disabilities and preferences expressed by them or their parents. For example, a blind pupil may require information provided in Braille or in digital form so the file can be downloaded on to a personal computer and read in large print or used with text-to-speech software. While auxiliary aids and services duties  under the Equality Act will require reasonable adjustments to be made in these circumstances, the Act encourages authorities to take a more strategic approach. Useful guidance on making text accessible is available as a free download from CALL Scotland  .
39. Information includes, for example:
- school newsletters
- handouts and worksheets
- test and examination papers
- posters and information about school events
- signage used in the school
40. The above example demonstrates again how the Act can be used to complement arrangements made under the Equality Act. Provision of homework, handouts and worksheets in accessible format may be within the scope of the Equality Act whereas school newsletters, posters and information about school events may relate more to a school's associated services. The same approach to producing accessible information may apply and accessibility strategies provide scope for authorities to engage in a more strategic approach to information production.
41. The provision of information in an alternative format must be provided within a reasonable time. The Act does not define what a 'reasonable time' is but determining what is reasonable must be related to the context and purpose for which the information is required. For example, if a teacher provides information about homework to the class then the disabled pupil should receive it in alternative format at the same time as their peers. In other circumstances for example providing information about a school trip arranged for the following term, a short delay may be acceptable.
42. Ensuring that the above is achievable will require accessibility strategies to include procedures for making information available in a range of formats (see Chapter 2, paragraph 14):
- large print;
- digital formats including PDF
- audio formats - CDs & MP3;
- sign language;
- symbol system;
- improving the accessibility of language e.g. easy read or simplified text;
- accessible web pages. Web sites should follow the Web Accessibility Initiative Web Content Accessibility Guidelines  .
43. It is important that quality assurance measures are in place to ensure that the content which is placed on web pages will continue to be accessible in the future.