3. Standards of Accessibility and Customer Care
Services operating to these Standards should be accessible to all members of the community and operate with the highest standards of customer care.
All service providers must be committed to providing equity of access to services for all.
A quality service is dependent upon services being available to those members of the community most in need without discrimination either at the point of service delivery or in the planning of which services are to be delivered and how those services are to be delivered. This does not preclude providers from identifying particular client groups or ensuring their services are targeted at those in greatest need.
All service providers seeking to comply with this Standard are required to have a clear statement of intent with regard to meeting the needs of all. This applies except where the aims and objectives clearly define them as a specialist service for a defined sector of the population. The statement should explain how the service intends to implement this policy and how it intends to measure its effectiveness in meeting this policy.
All of those involved in the planning, management and delivery of the services should be able to explain the service's policy and how this impacts upon their role.
The overall effectiveness of any strategy for information and advice depends upon a range of providers' ability to serve the whole community and upon recognising the special needs some individuals and minority communities may have in accessing and benefiting from the service provided. Considerations of both equity and equality of opportunity must be an essential part of each service's work.
There are legal requirements about equal opportunities in relation to both employment practices (see Standard 5.1) and service delivery. Legal requirements are focused on six equality groups:
In addition, good practice emphasises the importance of equal opportunities in underlining all of the policies, procedures and practices that are a fundamental part of ensuring access - both to the service and to employment within it.
Training is an essential part of this process, in developing awareness in staff, volunteers and management committee members about the barriers that can affect people from disadvantaged, oppressed and marginalised groups. This includes the development of a sensitive approach which can benefit all service users.
Where a service offers a clearly designed service for a defined sector of the population, this needs to be indicated in the mission statement. However, any Equal Opportunities Policy needs to show that practices and procedures within the service are not discriminatory, but reflect the operational objectives of the service in a public and open way.
Equal Opportunities awareness includes addressing the issue that some groups within the community may not see themselves as oppressed or disadvantaged. Services need to look sensitively at these issues - they need to aim for a comprehensive approach, which ensures that specific groups are mentioned where, in the opinion of the service, there may be indirect or hidden discrimination as a result of the service's practice or where perceived discrimination may deter members of these communities from seeking their rights or access to services or employment.
In drawing up an effective and meaningful equal opportunities policy, services must take account of the fact that discrimination can take many forms, some of which may not be obvious. This is very different from just acknowledging direct and indirect discrimination. For instance, in the field of disability awareness, it is important to understand that disability can take many forms, some of which are not obvious. People with visual and hearing impairments are not obviously disabled in the way that wheelchair users are, but can be significantly affected by the ways in which services are delivered.
Standards 3.3 and 6.1 provide additional information on ensuring accessible premises. This may be supplemented by reference to the Standards produced by the Scottish Accessible Information Forum: www.saifscotland.org.uk/publications/publicat.htm.
TIP Equal Opportunities Policies need to incorporate the following elements:
- A clear statement of policy which should include employment practice, governing structures and service strategy
- Definitions of direct and indirect discrimination (see below under Legal Requirements)
- What responsibility the service takes in respect of equal opportunities - this section needs to address the action that the service will take in ensuring compliance with its statement, and may indicate key activity areas where the policy will be implemented
- What the responsibility of the individual is within the service - clearly, implementing the policy not only requires the service to commit itself, but also requires the active commitment of all its staff and volunteers
- Monitoring and review and measuring effectiveness in equal opportunities - the policy should include reference to the ways in which progress on equal opportunities will be reviewed and monitored by the service (this may be included in the section above on the service's responsibilities)
- Training and awareness development - this area needs to be covered in the policy, including a commitment to provide appropriate training
- Grievance and disciplinary procedure in respect of breaches of equal opportunities - many equal opportunities policies contain specific clauses which relate to the grievance and disciplinary procedures of the service
All service providers must have a clear commitment to treat service users with respect and be clear about any expectations of behaviour they have of service users.
Ensuring access to the service and ensuring that the service users may apply the information or advice given is greatly assisted by a service maintaining a level of courtesy to all. This is particularly true in any cases where service users may come to a service in considerable distress or may not be able to present themselves in the most favourable light. The courtesy commitment is a two way process and services should expect a level of courtesy in return which includes an absence of abusive behaviour which may threaten staff or restrict the access of other service users.
All service providers should be able to evidence their commitment to this Standard by a written policy that requires all of those involved in the delivery of service, including non-technical staff, such as reception staff, to relate to the public in a courteous and respectful way. Compliance with the service's policy may be evidenced by:
- A statement of customer care displayed in public spaces (such as reception areas)
- Customer care training for staff
- Telephone skills training for staff and
- Anti-discrimination training for staff
TIP Any expectation that the service has of its service users - including what may cause the service to be removed, for example, meeting appointment times, the use of verbal abuse, and so on - should be documented and prominently displayed.
Standard 3.1 stresses a need for service providers to ensure that there are no barriers which exclude people from access to the highest standards of service provision. In emphasising the need for a courtesy commitment, good practice suggests that users of a service be treated with the courtesy and respect that will enable them to feel enough trust to support them through what may be a distressing period in their lives.
In addition, people wishing to use a service may have their access restricted by the behaviour of other users. For this reason, it is important to provide explicit information on the behaviour expected from service users generally and have procedures for dealing with unacceptable behaviour.
The policy should include the explicit standard of behaviour expected from paid and unpaid staff in dealing with the public, either in person, on the telephone or in any written communications. This will include the use of appropriate language and behaviour; how the service will deal with offensive remarks that may be aimed at specific types of users; appropriate conduct in public areas of a centre such as inappropriate consumption of alcohol whilst at work, or other activities which may diminish the user's confidence in the professionalism of the service; things which could cause affront to service users, for instance inappropriate posters or pictures in public areas; expected standards of dress and cleanliness.
Services should ensure that any expectations stated in this policy should also be included in other appropriate policies and procedures, for instance in the complaints procedure and in employment procedures. Disciplinary procedures should be reviewed to ensure that they clearly specify how breaches of this policy will be handled. Training for staff to support the implementation of this policy should be undertaken.
Services may wish to develop policies that specify the type of behaviour that they will not accept from service users, for example, behaviour that may endanger their staff or that may restrict access to other users. This may include physical or verbal violence or aggression, racist or sexist behaviour, remarks or comments or other threatening behaviour directed at staff or other users. It may also include a prohibition on the consumption of alcohol by users in waiting room areas or smoking in non-smoking areas.
Policies aimed at service users should be written in clear language and displayed in a prominent position in public areas, for instance the reception area, waiting areas, interview rooms, and so on. It should be presented in a format that will clearly communicate the expectations of the service provider to its users. Where appropriate, it should be translated into other languages. Sanctions for any breach of the code for service users should also be displayed. These may include asking people to leave, for instance if they are abusive or threatening as a result of substance misuse, to the circumstances in which the police would be summoned.
Services providing advice through home visits should pay particular attention to ensuring that staff respect the conventions within the homes of the people that they are visiting. Similarly, identification should be considered for staff and volunteers for individuals attending home visits; some public services have introduced code words that can be used with the elderly and with visually impaired users of service to assure them of the visitor's bona fides. Wherever possible appointments should be made in advance. The safety and security of the user of service should be considered in all cases.
Services must also consider the safety of staff and volunteers. If there are any doubts about safety, services should always err on the side of caution. Records should be kept of when and who staff are visiting. Where staff or volunteers feel that their safety may be jeopardised or their professionalism compromised, agencies should accept that accompanied visits are appropriate. Some staff carry mobile phones and use a buddy system with colleagues to keep each other in touch. Where a member of staff has encountered a difficult situation time should be allocated for debriefing.
TIP Home visits
You must also consider cultural factors in going into people's homes. For example, it would be inappropriate for a man to undertake a home visit to an unaccompanied Muslim woman.
All service providers must have procedures to review their premises at least once every three years.
The quality and maintenance of premises play a crucial role in ensuring access to a service. Access in this context means not only physical access, but also people's willingness to use a service because of its location and its appearance. This standard does not apply to Telephone Helplines.
Type I providers seeking to comply with this Standard will be expected to have procedures to review the premises from which the service is delivered (including own offices, outreach and surgery locations) at least once every three years. This should include:
- Physical accessibility for those with physical and sensory impairments and
- Location to ensure that it is relevant to the service's catchment area
This should be produced as an action plan or strategy paper.
In addition, for Type II and Type III providers this review should include:
- The adequacy of resources such as confidential interview rooms
Further requirements regarding premises can be found in Standard 6.1 and regarding confidential interviewing space in Standard 3.9. These Standards should be referred to in planning a premises review.
There are four main areas that a review of premises should cover:
- Accessibility and adaptations
- Services and resources and
- Health and safety
The primary consideration for an advice service in terms of premises is its location. The location should be tested against the catchment area established for the service. Many services will not have any choice if they already have established premises, but this does not mean that the premises position should not be regularly reviewed as part of the planning process. Even where there are many constraints within existing premises, imaginative thought can make them more attractive for current and potential service users.
Even where the location is appropriate, the premises themselves may not be adequate. The decision services have to consider in these circumstances are do we move, or do we stay put and make improvements to the existing premises? It is important to consider whether a move would improve the whole range of factors that need to be considered in relation to premises - services should prepare their own checklist of what is important and weigh each consideration. Where standards are not met at present, services should draw up timetables and costings to achieve the standards within a realistic time frame.
TIP Where the cost of travel to the service premises is an issue, some providers' procedures allow them to pay fares to assist clients to come to the service.
Accessibility and Adaptations
Improving access is a core aim of these Standards. Physical barriers to access can be one of the most difficult factors in reducing overall access to information and advice. It is important that services develop disability awareness in all aspects of their work, and this is particularly critical in relation to premises.
As well as wheelchair access, there are other things that should be considered. For example, directional notices in Braille, paint applications or raised services can help visually impaired people find their own way about premises. Induction loop systems and minitel in interview rooms can help those with hearing impairment who wear hearing aids. Loop systems in particular need not be expensive to install. Toilets should be available in all premises. At least one of these should be adapted for people with mobility problems, not only to provide wheelchair access with sufficient space for a wheelchair, but also with a raised seat, handrails, wheelchair level washbasin and call system in case of emergencies. Doors with hinges that assist entry and ramps are also important for people with mobility problems.
Advice on improving access for disabled people is readily available from local and national groups of disabled people. Many of these groups already undertake premises audits for a range of service providers and provide advice on relevant adaptations. It should be noted that there is now a legal requirement upon all service providers to provide access, or make reasonable alternative provision, for disabled people. In undertaking premises reviews consideration should be given to these legal requirements and to alternative ways of delivering service - elsewhere by arrangement or by home visits. Further guidance on developing physical accessibility for disabled people to information and advice services is available from the Scottish Accessible Information Forum: www.saifscotland.org.uk.
The costs of adaptations can appear daunting. However, without such adaptations a service may, in effect, deny its service to those most in need. The adaptations made to improve access for service users can also be beneficial in terms of staff and volunteers. Improving disabled access to premises means that a service can recruit both staff and volunteers with disabilities.
Services and Resources
The availability of confidential interview space is a requirement under Standard 3.9 for Type II and Type III providers, to ensure that current service users receive a confidential and private service. Services may wish to note that office based advice sessions are not the only way of delivering services. Services with inadequate office premises may wish to consider other means of confidential service delivery, such as home visits or telephone advice.
Reception space provides many service users with their first impression of a service. If people are to wait for longer than 20 minutes it is important to provide distractions, such as books, magazines, board games.
For service providers operating in areas with people from some minority ethnic communities it may be important to have a space where women can wait separately from men who are not of their immediate family. If there is not enough space for this in reception, a service may consider an arrangement whereby women or men are ushered into an interview cubicle upon arrival.
Many people accessing information and advice services will need to bring their children with them. It can be very distressing for a parent if they have to wait for some time to be seen and there is no distraction for their children. Whilst not all services will be able to provide either a dedicated child's play space or crèche facility, even a small area with some cushions and a box of toys and books for various ages can be a great help. Parents with prams and pushchairs are also assisted by the adaptations made for people with mobility problems. The installation of a nappy changing table (where space is limited this can be a foldaway table) in a lavatory can be very helpful.
TIP For service providers operating in areas with people from minority ethnic communities a quiet and appropriate space for staff and service users to carry out religious requirements should be considered. This can be a cubicle or other room with a different use set aside for religious purposes at specified times. It should not be next to the toilets or the kitchen (although people should be able to wash as necessary) and it should be free of distractions and not include inappropriate imagery (including any representations of people). It should be clearly indicated in reception, staff information and meeting spaces.
A key question that many services fail to address is whether they are making the best use of available space. It can sometimes be helpful to ask an architect to look at premises and to give advice as to whether more efficient use could be made of the space. For example, is the meeting or training room currently under-used? Is there a room somewhere nearby that could be used for training or meetings thus freeing up this space? Would budgeting for the occasional use of other premises free up space that could be converted for interview rooms or as an improvement on current reception space? Would it be cheaper to do this than to move and lose a good location? Analysing all the options is important in ensuring that premises are suitable for the service that is offered.
The general aspect of premises is important. Keeping premises clean and brightening premises up can make the service a more welcoming place. Painting and decorating, using pictures and plants, the arrangement of the furniture can all make a difference between a depressing environment and one that feels friendly.
Health and Safety
Under the Workplace Regulations (Management of Health and Safety at Work Regulations 1992), employers are responsible for ensuring that the service adheres to the following requirements:
- Working environment - temperature, ventilation, lighting, room dimensions, and the suitability of workstations and seating
- Safety - safe passage of pedestrians and vehicles, windows and skylights, doors, gates, floors and falling objects
- Facilities - toilets, washing, eating and changing facilities, clothes storage, drinking water, rest areas and rest facilities for pregnant and nursing mothers, and
- Housekeeping - maintenance of workplace, equipment and facilities, cleanliness and removal of waste materials
Staff safety is a key responsibility for all services. Health and Safety issues are covered by legislation, and form part of an employer's statutory responsibilities. Other issues, which are not covered by the law, should be seen as important for services. With regard to premises, services should consider the good practice points below.
- Interview rooms should be fitted with panic alarms
- Interview rooms should be clearly visible from space that is in constant use by others - for example, facing the reception area if this is staffed
- Interview rooms should have windows facing onto an area in constant use by others - for example, doors should be fitted with glass panels
- Seating arrangements in interview rooms should ensure that service user is never seated between the adviser and the door
Every service should draw up a health and safety policy which goes beyond the statutory minimum, and addresses issues of safety in the service and for service staff in working with service users. Identifying good practice procedures which are service specific and deal with situations likely to be encountered by the service and its staff and volunteers is recommended. Where necessary, resources should be identified that can be applied to improving safety in a service. Other areas of staff safety that service providers should consider include:
- Advising staff never to interview when alone in the premises
- Developing a policy on dealing with violent users - this will relate to the requirements in Standard 3.2
- Considering training for staff in coping with difficult or potentially aggressive service users - training in conflict avoidance and assertiveness can help staff develop strategies for dealing with potentially difficult situations
- Setting up a reporting system for incidents and ensure that they are documented; and
- Developing a safety conscious attitude in staff, particularly if they are involved in evening or out of hours work and home visits
Clearly, many of the good practice notes above are resource demanding. There are possible sources of help available to carry out some types of improvements, for instance grants for adaptations to improve disabled access. Local authorities and councils of voluntary service should have local information on these. Before undertaking any such improvements, however, service providers should speak to local disability groups about their views as to the best way to improve access.
In general, it is helpful to ask service users for feedback on how they feel about the premises and ask for suggestions. Services have often found that doing this results in donations of chairs, curtains, toys for children, and so on.
In reviewing premises needs and finding ways of meeting the standards, networking with other services can help in identifying premises for outreach work or to fill a need for additional space, for example, for meetings and training sessions.
All service providers must regularly review the methods of delivery for their service to ensure both accessibility and the effective use of resources.
Access to services and reviewing the methods of delivery against the aims and objectives of the service can ensure the effective use of resources.
Type I providers should be able to demonstrate that the service has a process for reviewing each method of delivering information at least once every two years.
In addition, Type II and Type III providers should be able to demonstrate that this review includes consideration of:
- Traditional office based information and advice
- Telephone helplines and advice
- E-mail enquiries
- Internet information
- Surgeries and outreach in other services' premises
- Home visits and
- Impact assessment
All service providers should be able to demonstrate that this review includes consideration of the services provided by other services and the views of different groups of current and potential service users.
Home-visiting services can greatly improve accessibility. However, this is a resource intensive method of delivery and services should be clear about who can and cannot access the service.
The rapid development of information and communications technology is likely to have a dramatic impact upon the way in which information and advice services are delivered. Changing methods of delivery will also change the profile of service users. It is therefore important to review the methods of delivery regularly to ensure that the service is meeting the needs of its local community.
For example, e-mail enquiries have been identified by a number of people with sensory impairments and impaired mobility as a preferred means of accessing services. The rapid introduction of this technology is likely to increase demands for services delivered in this way. Similarly, if a service discovers that it is failing to attract young people in its area it may decide to make its own premises more attractive to this group or operate a surgery at a youth group.
Alternatively, an information provider may have a large printing budget for its leaflets. However, if people in the area have ready access to the Internet - for example, in public libraries or through digital TV - the information may be better placed on the Internet.
Reviewing the methods of delivery is a key element in ensuring that the service is both accessible and efficiently run.
TIP The review will need to consider whether current methods of delivery are the most effective means of meeting the aims of the service and reaching its target service users and must take into account client feedback on accessibility and effectiveness. The resources applied to current methods of delivery and resources required to provide services with alternative methods should be part of the review. This should be accompanied by an analysis of service use against the community profile and under-represented groups should be asked what might make the service more attractive to them. This should be informed by knowledge of what other services are provided in the area.
All service providers must regularly review their hours of service to ensure that these meet the needs of their current and potential service users.
Traditional office hours of opening may exclude many people most in need of services from accessing that service.
All service providers are required to demonstrate that their service has a process for reviewing hours of service at least once every two years.
Community needs change over time. Many existing advice and information services were established in the 1970s, 1980s and early 1990s at times of very high unemployment. For many service providers their target service users could easily attend advice services during normal office hours, but this is not always the case. Whilst most services are likely to continue to experience high levels of demand, for many the profile of service users is changing. To ensure that the service can continue to meet the needs of its community regular reviews of hours of service are required.
The review of opening hours should consider who is using the service and at which times. This should be tracked over a period of time to identify any changes. This information should be compared with the community profile and any variance noted. If any groups or communities are under-represented in service use the service should consider the impact of changing the hours of service. This may be undertaken by consulting with those potential service users about the impact of operating with different hours of service or by running experimental sessions and monitoring use. It is important to factor in consideration of the hours of service of any other service providers in the locality. In running any experimental new hours of service these changes should be publicised.
All service providers must ensure that potential service users are aware of the service that is provided.
Services should ensure that their target service users are aware of the services available. To ensure that this is the case, services should regularly publicise their services using appropriate media (such as leaflets, posters, and referral networks).
To comply with this Standard, all providers are required to:
- Produce a marketing plan or promotional summary that details how the service's target users will be informed of the existence of the service. This should be clearly linked to the community profile and needs assessment requirement in Standard 2.2
- Identify a separate promotional budget.
It is important that information and advice is available to all. Services can play a key role in this by ensuring that their target service users are aware of the service available. Regular publicity is essential. Communicating what a service does ensures that it continues to reach those people who have a need for the service. Even when a service is over-stretched, it is possible that some groups are excluded from the service because they do not know about it, rather than because they do not need it. Services should never assume that just because they are well known in their local area everyone who needs the service can find and access it.
For some services, the promotional strategy may need to describe how the service will limit demand to an acceptable level in line with service resources, rather than seeking to encourage additional use. Services that experience heavy demand at certain times may wish to consider explaining that, for example, Mondays are very busy and that callers may receive a quicker response on Wednesday afternoons.
Contingencies and emergencies may also arise which need to have a procedure - for instance how will the service inform its users if the service has to be curtailed because of staff holidays coinciding with a flu epidemic? In addition, emergencies can arise in which the service is asked to assist, for instance in a local catastrophe. Changes in legislation that may impact quickly on some service users and the service will decide to set up special sessions to provide an effective service in these instances.
The service needs to publicise what it does, when it is available and how it can be accessed. Specific parts of a service that may be relevant to particular groups should be publicised in different ways. For instance, if a service is open on one evening a week for people who are in work and cannot reach it in normal office hours, it should ensure its publicity reaches relevant places and is worded in such a way as to show that this is what this session intends to do.
If a home-visiting service is offered, it needs to be clearly publicised. Remember that if the only place people can pick up leaflets or information about a home-visiting service is from the advice centre, people who can't get to the centre will not know about this part of the service. Networking with other agencies whose staff or volunteers regularly visit people in their homes and asking them to give out information leaflets out can extend the range of information about the service. Using the local media - newspapers and local radio - can also help with this type of publicity.
If a home-visiting service covers anyone living in an outlying area, because access to transport is difficult, or if it is designed to serve only the elderly and house bound, it should ensure that its publicity indicates this to avoid inappropriate demands for this part of the service. Publicity can also explain why callers may receive a quicker response on some days rather than others, and how long they may have to wait for an interview.
In addition, publicity is a means to ensure accountability of the service to the wider community, through, for example, publicising annual reports. Services should also publicise any changes that are made to the service as a result of user feedback, for instance as a result of a user satisfaction exercise or as a result of complaints that have been received.
Publicity should be budgeted for as a regular activity. Services cannot assume that advertisements in the local paper, which may be free, are as much promotion as is needed. A budget heading is needed for publicity, and a programme should be developed and costed.
Publicity needs effective distribution.
Which is the best local paper for advertisements?
Which are the important notice boards in community centres (for example, health centres, churches, and so on)?
Are there shop windows which are used by other services for posters?
Is it best to leave bundles of leaflets in the local health centre, or could the service ask staff there who visit outlying areas or home visit to take the leaflets with them?
Is a door-to-door delivery of leaflets in a particular area helpful?
TIP The promotional strategy will need to decide who the service needs to reach and research how it can best reach them. For example, if monitoring shows that a service is reaching very few young people, but they have a need for advice and information, research the best means of reaching them. This may include talking to community education and youth workers, putting posters up in local youth services and other places where young people gather.
The scope of promotional material may include:
- Leaflets - which specify: the service available; when it is available; how it can be accessed (through drop in, appointments only, telephone, home-visiting, and so on); what to expect when the service is contacted, plus any other facilities that are offered (for example, a crèche); leaflets should be available in relevant community languages
- Posters - which publicise the service and its opening hours, placed on public notice boards, in shop windows, and so on; these do not need to be expensive, but must be clear and unambiguous
- Using the local media - local newspapers and radio always want local news and often carry specific slots for service information; local radio is a particularly effective way of getting immediate messages across, for instance, if a service is likely to be closed or limited for a short period, or if it is targeting a particular group because of a change in legislation
- Using other services - through, for example, newsletters sent out by other services, which could carry an advertisement for the service or an article about its work. This can be helpful if a service wishes to reach a specific target group
- Websites - increasing numbers of information and advice providers are setting up their own web pages; these can be a useful means of providing information, both about the service and about advice topics and
- Corporate publicity - which is service specific; for example, in Council newsletters
All service providers must be able to provide information in a range of formats and community languages that are appropriate to the needs of disabled people and the local community.
Services should ensure that all written information can be produced in a way that is impact assessed to ensure it is accessible to disabled people and people whose first language is not English. This may include provision for the translation of leaflets or the development of all alternative means of ensuring accessibility. It should be noted that, with regard to disabled people only, this Standard is a statutory requirement.
To comply with this Standard, all service providers should have plans for meeting the needs of people in their communities for information in accessible formats/appropriate languages. This may include self-production of the material or partnerships with other providers.
Where such formats/languages are not automatically available, the plan should include a means to ensure the provision of information in alternative formats/languages to be timely, with people being able to receive such information within a time agreed between the service user and the information provider. This may include provision of the information directly or sign-posting agreements to other services that agree to undertake this work on the service's behalf.
Increasing access to a service includes being aware of the needs of people who may have difficulty with spoken and written English. This need applies not only to people whose first language is not English, but also to people who are hearing and speech impaired or who have literacy difficulties.
Services should also be aware of the barriers to advice and information if they do not use clear language in all communications. Much written material can be impenetrable, and a barrier to effective communication. Effective information and advice work is part of the empowerment process - services must ensure that they help people to know the questions they should ask, as well as providing them with answers to those questions. In some cases leaflets which are over reliant on the written word may be a barrier to people with learning disabilities or literacy needs. Visual images, used in a non-patronising way, can convey information effectively.
Local authorities and community relations councils should be able to provide services with a profile of the languages appropriate to their area. They also may have resources available to facilitate the translation of materials.
Local disability groups and the Scottish Accessible Information Forum ( SAIF) www.saifscotland.org.uk/index.htm can provide further details of the range of alternative formats that may be required. Information held digitally (for example, on computer disk) is often relatively easy to translate into different formats such as large type, Braille and so on, and new technology is becoming available to turn written text into synthesised voice texts. SAIF produces a directory of services providing alternative format services.
For other languages and alternative formats, service users should not be unduly disadvantaged by having to wait long periods for translated materials. The translation resources available in different parts of the country vary considerably. However, service providers should develop a policy, and inform service users, on how long people should wait for such materials.
TIP It should be noted that the translation of materials can be costly. Services should work with other services in their areas to ensure that, between them, no one is excluded from access to information.
Services must not disadvantage users whose first language is not English. All Type II and Type III services must have access to interpreters in appropriate languages and clear procedures for the use of interpreters.
Services should be accessible to all members of their communities and individuals should not be excluded from service use, or receive a qualitatively different service, because of their mother tongue. The use of interpreters should be consistent with other policies, in particular those regarding confidentiality.
To comply with this Standard, Type I services must demonstrate that they can provide an 'active' sign-posting service to all members of the community. Service providers should also maintain referral sources in appropriate languages.
To comply with this Standard, Type II and Type III services must have clear policies and procedures on the use of interpreters. They must also maintain contracts or other arrangements with interpreters in community languages appropriate to their catchment.
As in Standard 3.7 increasing access to a service includes being aware of the needs of people who may have difficulty with spoken and written English. This need applies not only to people whose first language is not English, but also to people who are hearing and speech impaired. Interpretation should include all languages, including sign language systems used by hearing and speech impaired people. In considering this Standard, it should be noted that there are legal requirements relating to ensuring accessibility to services for disabled people.
Many services say that there are relatively few, if any, people in their area who need this type of service. However, even though the numbers may be small, the risks of excluding people from access to services by failing to discuss the issue and working out a clear policy of what to do when such a service is needed, are considerable. Each service needs to look at how it could provide such a service.
Work undertaken to comply with Standard 3.7 should identify current and potential levels of need in the community for this type of service. Even where planning has not indicated an existing need, services should consider how they could provide such a service if it is required. A good policy will include Guidelines on the use of interpreters. You can get help with this from Happy to Translate www.happytotranslate.com.
In this respect, leaders of an ethnic or language community who may be in a position of power over the individual needing support from the service should not normally be used as interpreters. For instance, local business leaders may be employers of individuals or members of their families, or may have cultural or religious authority that would disadvantage the individual. In the case of women from minority ethnic communities who may have experienced domestic violence, or may be seeking to leave their partners for other reasons, the use of interpreters from within their specific local community may jeopardise their safety. The young children of individuals approaching the service should also not be used. It is in general inappropriate to ask a young child to interpret for a family member, given that the subject matter may be distressing both for the child and for the service user. Where older children or other relatives need to be deployed as interpreters, the service user's approval must be sought in advance and where there is any reluctance, an alternative interpreter should be sought.
TIP Other advice services can be a great source of assistance in this area and in addition, local authorities and Councils of Voluntary Service often maintain lists of translating services. Developing links with other services can provide not only sources of information about interpreting services, but may give access to individuals with language proficiency.
Local and national disability groups maintain lists of interpreters for the hearing impaired. It may also be worth considering sending a member of staff on a signers course. Courses are run by specialist services, are not normally expensive and a basic level of knowledge can be acquired quite rapidly.
For larger (and some smaller services) it is worth conducting a language audit within the service of paid and unpaid staff and committee members. It is interesting how often services do not know that their staff or volunteers have language skills. A question about language skills can be included on volunteer application forms. Where research and the planning process has identified that a particular language could be needed regularly in a service, it is worth considering whether it would be appropriate to advertise a particular staff vacancy with an emphasis on proficiency in that language. Specific recruitment of volunteers from particular communities can also be considered.
It is also worth investigating access to remote interpretation services, through telephone links to specialist services.
Whatever arrangements are made to assist service users who have difficulty in written, spoken or heard English, notices should give service users information about the arrangements. These posters should not be written solely in English, even in areas where translation needs appear to be rarely needed. A wide range of leaflets are available in ethnic community languages from the Benefits service and other similar statutory bodies, as well as a number of voluntary services. Stocks of appropriate leaflets should be kept, but services should ensure that out of date stocks are regularly removed and updated versions ordered.
TIP Many local authorities subscribe to translation services such as Languageline which offers over the phone translation where your client can speak to an interpreter in any of 150 languages. The interpreter participates in a three way information exchange with you and your client helping both sides to communicate with the other.
All service providers must have effective and appropriate policies on confidentiality and access to information.
Every service user has the right to expect that the service they receive is provided in confidence and that any records about them kept by the service are fair and accurate.
To comply with this Standard, Type I service providers should have policies that cover:
- The way in which information is provided by the service and any provision for carers if appropriate
- Details of any information that may be held about the service user by the service provider
- The circumstances in which this may be passed on and
- How the service user may access any information held about them
To comply with this Standard, Type II and Type III service providers' policies should also cover:
- The way in which the service will be provided (for example, private interviewing space) and any provision for carers if appropriate
- The extent of the policy and any limitations to it
- What any exceptions are and why
- Breaches of confidentiality and how these will be dealt with and
- Forms of authority enabling the service to speak or act on behalf of the service user
The right to be advised confidentially and privately should be seen as central. Services that do not currently have access to confidential interview space should consider how safe it is for the service user to disclose confidential information in a space to which other service users and staff have access. In relation to access to information, the business of the advice session is the service user's and therefore they should have access to any records kept about their case.
Confidentiality policies should include what detail a service user may be asked to give in a public reception area, as well as interviewing procedures, case files and enquiry records. Many advice networks and services will have policies on confidentiality and service user access to information held about them. However, there is often confusion about confidentiality in services and it is possible for a service to conceal bad practice behind this issue.
The need for confidentiality can be inappropriately used to preclude discussion of a case with anyone, even within the service, and to prevent the implementation of casework audits. This view of confidentiality means that no assessment can be made as to whether standards of advice are being met. Services need to examine their policies and procedures in this respect and set clear boundaries which enable quality checking of casework and information to be undertaken and ensure that bad practice does not hide behind the mask of confidentiality. Services should be aware that there is a distinction between confidentiality and anonymity - client profiles can be prepared which protect a service user's anonymity but which allow the service to develop its social policy role.
Confidentiality can also be used as a barrier to effective referral, where a service may decide that formal referrals cannot be made to another service because this would breach confidentiality safeguards. Whilst the reasons for this can be understood, to offer a truly client centred service, there is a need to balance respect for the personal details that clients give with mechanisms to ensure that the client's needs are met effectively. Good practice would suggest that information is given in confidence to a service to enable that service to pursue the service user's needs in the most effective manner. Provided service users are informed of the way in which information is being used, and give their consent, confidentiality should not be used to obstruct the advice process.
TIP One agency has devised a procedure that allows the service user to be in control of the information they provide. Each service user whose information may be shared between agencies is given a personal log, very much like a personal organiser. It allows the service users to note relevant information about their case to share with each of the agencies involved. The personal log allows them to share as much or as little as they choose with services with whom they come into contact.
There may also be a need to separate out issues of confidentiality from issues of impartiality. For instance, where a service is working with one party in a dispute, and the second party approaches it for assistance, does it breach confidentiality to inform the second party of the reason why they cannot be assisted, or should they merely be told that they cannot be helped? In the latter case, this could give rise to a complaint if the service publicly declares that it will assist anyone. Some services lay down clear guidelines which state that in this type of case, the second party must be informed that they cannot be assisted and the reasons for not advising them clearly stated. Wherever possible individuals should be referred either to another adviser in the service or to another appropriate service.
Confidentiality may not be an absolute, even without the client's permission. If there is a clear danger to the client or to someone else, some services will breach confidentiality. Fraud is an issue that concerns many services in respect of confidences passed to them by service users, and in some cases staff and volunteers are trained to stop a service user from disclosing information if this could lead to a potential legal conflict in respect of the volunteer or staff member being privy to information about a criminal offence.
The use of volunteers in areas where clients and volunteers are likely to be known to each other can also raise issues of confidentiality. Many services have developed policies that ensure that where a service user and volunteer or staff member are known to each other, the client must be asked if they would prefer to be seen by someone else, if possible. However, a barrier to access to advice and information services may be that people will not use a service if they know that someone they know is a volunteer or member of staff there. Each service will need to judge this issue as it arises.
Ensuring confidentiality in many areas, particularly rural areas, also raises broader issues in relation to access. Some services have found that if they establish a specialist service, which will identify the problems of people visiting the service, the take-up will be low. In some areas, the preservation of confidentiality may need to be accomplished through non-specified sessions or through specialist support and help being made available through other services and means.
TIP Confidentiality is important in relation to home-visiting. For example, the agency minibus with the logo on the side should not be parked outside an individual's house, unless they have been asked if it is all right to do this. If a service user asks for discretion that wish should be respected.
You must also consider confidentiality within the home. For example, can an interview be conducted in line with your confidentiality policy if other family members are present?
Services should regularly review their policies in respect of confidentiality and ensure that they have clear procedures for dealing with breaches of confidentiality. At the same time, they should ensure that these policies enable good practice to be developed in other aspects of their service. Other professional bodies, often backed by legislation, have developed good practice models. For example, medical general practices have a policy whereby patients may see any notes written by their doctor, but they do not have a right to examine information, such as letters, from a third party.
Consent forms are important in gaining permission from a service user to pass on information about their enquiry or case to a third party, wholly in pursuit of the advancement of their case or for the purpose of quality assurance audit processes (including audit for adviser competence under the statutory debt arrangement scheme). Agencies need to ensure that service users are fully aware of what they are signing when asked to sign a consent form.
TIP In one accredited agency the client consent form has been adapted to allow individual service users to opt in or out of any audit process being undertaken by an external agency. This is explained to service users at the outset. Advisers in the agency report that in virtually every case service users are happy to give consent to their file being used for audit purposes.
The issue of criminal activity being disclosed to a member of staff or volunteer needs to be addressed. Staff and volunteers need to be trained in stopping service users from disclosing anything of an illegal nature but a policy must be in place which outlines the procedure where information supplied by the client suggests that the client is involved in or about to be involved in criminal activity such as illegal money tendering.
Similarly, a policy should be in existence which outlines the procedure used if the adviser discovers a fraudulent claim for benefit.
It is recommended that all services consider the conditions under which such a policy should be applied and consider the adoption of such a policy. In respect of some criminal activities, there is a clear legal duty of disclosure on the advice service. A prime example of this is that it is an offence under terrorism legislation to withhold information from the relevant authorities about acts of terrorism.
Services should also be aware of their responsibilities in relation to data protection and access to information legislation. In particular, if case records with names and addresses are computerised, services will be required to register as a holder of such information with the Data Protection Registrar. This must include certain procedures for individuals to access information held about them. The Registrar has produced a useful series of free booklets about the Data Protection Act and its requirements. Statutory services are also subject to the requirements of the Freedom of Information Act - guidance will be available.
Service providers must have procedures for the safe maintenance of files and for file destruction.
Careful storage of information is essential both to maintain the confidentiality of users' case notes and to ensure the efficiency of the service. Users of service should feel confident that information on their enquiry or case will not be stored indefinitely and that care will be taken in disposing of old case records. This includes both paper and electronic records.
All service providers are required to:
- Keep case notes stored in a safe and secure place and
- Have a policy for the length of time case notes are stored which details how and when these notes will be destroyed (for services maintaining case notes)
As a minimum, service users should expect that their case notes will be kept in a locked and fireproof filing cabinet. For particularly sensitive case notes, the service may wish to consider storing files in a safe.
Where data and case notes are kept on computer, services must ensure that their systems are secure. This will include keeping discs in a secure and fireproof place, ensuring that any casework or confidential files kept on hard discs can only be accessed through pass words and that these passwords are known only to those who need to have access to the information.
A written policy on the length of time case notes are stored should be included in the case management manual and this policy should be explained to the service user. For most advice providers this will be for a minimum period of seven years (after which time a service user cannot sue for incorrect advice).
Special arrangements should be made for the careful destruction of case notes, through, for example, shredding. Where the service does not have its own paper shredding facilities, careful arrangements should be made to ensure the safe transportation of files to their place of destruction.
TIP Local authorities may be willing to offer a shredding facility for services.
Service providers must have an effective complaints procedure and adequate insurance to provide rights of redress.
Complaints provide a valuable means of service user feedback on the service provided. Service users should feel confident that if the service provider makes mistakes they can be dealt with promptly and that there is sufficient provision for redress.
To comply with this Standard, Type I service providers should have a complaints procedure that:
- Explains to the service users who to complain to and how the complaint will be dealt with
- Is publicised and
- Is monitored by those responsible for managing and planning the service
To comply with this Standard, Type II and Type III service providers should have a complaints procedure that also:
- Ensures information from complaints is incorporated into the Services Plan and
- Ensures changes that have been made to the Services Plan as a result of complaints information are publicised
Services exist to provide appropriate information and advice to people in need. For this reason, when things go wrong, they must make every effort to ensure that service users do not pay for the service's mistakes. All service providers are required to have adequate Professional Indemnity Insurance to ensure that service users are not disadvantaged by any mistakes the service may make in the delivery of its services.
Service users should feel confident that if mistakes are made by a service they can be dealt with promptly and that there is adequate provision for redress.
Complaints can also provide a valuable means of user feedback which can assist in planning and developing services so that they are responsive to need and accessible to all. Having a clear and effective complaints procedure that is easy to access, safe and responsive ensures this process.
A procedure of ensuring redress or complaints procedure should contain a number of elements:
- What a service user can complain about - for example, general level of service; the behaviour of a member of staff or volunteer; wrong advice
- How they can complain - who to; if there are forms; how these can be obtained
- How their complaint will be dealt with - how quickly; by whom; how they will be involved
- What they can expect as a result of their complaint - apologies, compensation and
- What general action to change the service is taken as a result of complaints
In addition, the service should have a strategy on how it will publicise changes made as a result of complaints, including information about how and why they have occurred.
TIP Information for service users which tells them about the complaints procedure should be clear about how to complain about the attitude or behaviour of particular staff/volunteers. This can be a very difficult area for service users, and users must feel safe in making a complaint directed at a specific individual rather than at the overall quality of a service, without feeling at risk of intimidation or loss of service. Clear guidelines should also be drawn up as to how complaints against specific individuals will be dealt with, to ensure that staff or volunteers are not victimised through an aggrieved user attempting to use this procedure just because their needs have not been satisfied through the service.
Information on how to access the complaints procedure should be well advertised in public areas of the service. This may be on a poster and/or through leaflets. In some services, forms are made available at reception areas. Services may wish to consider making forms available generally and not only on request. Having to request a complaints form may act as a barrier to potential complainants, who may feel that the act of asking for a form could prejudice their continued use of the service. It is helpful if complaints could be made in the first instance on a form, as many service users might experience difficulty in composing a letter of complaint. Forms can be coupled with detailed information about the procedure and can be designed to give spaces which can lead the complainant through their complaint, for instance asking for the day and time relevant to the complaint, the nature of the complaint, and so on.
In many instances, complaints are made anonymously. It is inappropriate for the service to act upon an anonymous complaint if the complaint concerns a member of staff. If the service has any reason to believe that the complaint has a foundation, it must find ways of asking the anonymous complainant to identify themselves confidentially, possibly through a contact with a member of the management committee who can be seen to be a trusted individual. This can be very relevant in smaller communities, where complainants may be reluctant to identify themselves. Where an anonymous complaint is received on general aspects of the service, it can be assessed alongside any attributable complaints.
Procedures for handling complaints differ. In some services, complaints are dealt with by the most senior member of staff, who will take action under the procedure and ensure that all complaints are regularly reported to the Board. In other services, complaints are only dealt with by the Board as a whole or by designated members of the Board. Any complaints against the Director or most senior member of staff of a service can only be dealt with by the Board.
In many cases adequate redress may be a simple verbal or written apology. However, where a service user has been financially disadvantaged by the action or inaction of the service, the service may need to provide some financial compensation. This raises the question of professional indemnity insurance cover. Services should ensure that they are properly covered by professional indemnity insurance to meet any resultant claims. The main advice service networks will provide this service as part of their membership fee or at additional cost. It should be noted, however, that many insurance policies of this type specifically exclude the service advertising the fact that they have this insurance and the service would risk not being covered if they do so. This point should be borne in mind when services are publicising their complaints procedures and the type of redress that service users can expect.
Some services will be covered by industry-wide schemes where their membership of a professional body will be designed to provide additional protection to service users. Other services will be covered by various Ombudsman schemes. These should be included in the complaints procedures if relevant.
TIP The confidence of service users will be greatly enhanced by the publication of information on complaints received and remedial action taken. This can take the form of notices in public areas, items in the Annual Report which are advice service specific and such other means as may be appropriate for the service.
All service providers must have procedures that actively encourage feedback from service users.
Service providers must have documented procedures that will enable service users to provide feedback on the quality of service they have received.
To comply with this Standard, Type I service providers must have procedures that include a feedback mechanism to address the issues below:
- How easy was the service to access in terms of location, hours of service, and so on?
- Was the service approachable and friendly?
- Was the service delivered in a competent and timely manner?
- Was the information and advice explained sufficiently?
- How and when should service users provide feedback?
- The frequency and way in which feedback is analysed
- The way in which this will be used to influence the planning process
To comply with this Standard, Type II and Type III must also have procedures to address the issue below:
- Was the service user informed of progress in the case?
There are many ways of listening to service users. Most services should consider using a variety of different methods, depending on the objectives they have set. Methods include:
- Customer feedback and survey forms which are given to each service user - they are usually anonymous
- Small surveys of users conducted face to face (for example, exit interviews) - if this method is used, people must feel safe in answering questions honestly and feel that any information given will not prejudice them as service users
- Involving service users in Users' Forums, which may be organised on a regular basis
- Inviting service users to sit on committees or working groups, including possible membership of the Management Committee
- Involving service users in review and evaluation processes
- Use of 'citizens panels' and
- Annual General Meetings and other forums open to the public - AGMs can be opened out to include discussion time, with views and questions being invited from the floor.
TIP Some services have found additional ways of involving service users in the delivery of services, through volunteering opportunities and through ensuring that they are not unfairly discriminated against if they apply for employment vacancies. It is recognised that for some services, this last method of involving service users could cause difficulties, particularly in smaller communities. However, if the service is clear about its objectives and in operating its Equal Opportunities policies, there should be no reason for excluding service users either as volunteers or as members of the paid staff team.
Phone: 0300 244 4000
Central Enquiry Unit
St Andrews House
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