Out in the_open_dhi_manifesto

Out in
the open
Tackling disability-
related harassment

A manifesto for
change

Tackling disability-related harassment – A manifesto for change

Contents
Foreword Page 3
Introduction Page 5
Following up the Commission’s inquiry Page 6
Government responses Page 7
Developing the manifesto for change Page 11
Section 1: Reporting, recording and recognition Page 12
Section 2: Addressing gaps in legislation and policy Page 16
Section 3: Ensuring adequate support and advocacy Page 19
Section 4: Improved practice and shared learning Page 21
Section 5: Redress and accessing justice Page 23
Section 6: Prevention, deterrence and understanding motivation Page 25
Section 7: Transparency, accountability and involvement Page 29
Evaluating results Page 32

2

www.equalityhumanrights.com

Foreword
by Mike Smith
Lead Commissioner for the Inquiry into disability-related harassment,
Equality and Human Rights Commission

One year on from the report of our original shows that more people feel able to report it,
inquiry – Hidden in plain sight – and the and we need more reporting to demonstrate
circuit of speaking events that followed, it the true scale of this issue. But it could also
would be easy to imagine that disability- suggest that the underlying incidence of the
related harassment is finally being problem has got worse.
understood and tackled.
I am also concerned about the apparent
The responses from government and ‘postcode lottery’ in recording patterns,
authorities discussed in this ‘Manifesto for with a variation of 255 cases in
change’ show that many are already taking Leicestershire down to just four in some
significant steps and more are planned, as police force areas, with 12 forces2 recording
set out in the detailed reports of what they less than 10 cases during this period. It is
intend to do over the next few years, which difficult not to conclude from these figures
are posted on our website alongside this that some police forces are simply not trying
report. Together they show progress, hard enough to encourage disabled people
individually and collectively, towards to report these incidents or to take them
making a real difference. seriously when they do.

Yet almost every person I talk to who is not Contrast these figures with the Crime
part of the criminal justice or equality sector Survey for England and Wales; they show
still doesn’t appear to recognise what is the number of people experiencing a
happening to disabled people. If you follow disability hate crime in the year to the
the Disability Hate Crime Network – an Spring of 2011 was 65,000. So, just under
online community of disabled people from 3 per cent of hate crimes experienced by
disabled people end up being included in
across Britain sharing their experiences –
the official figures. This means that for
you will see daily reports of attacks against
around 34 out of every 35 incidents of
disabled people. Day after day, people are
disability hate crime, the victim was either
being targeted because of their disability.
unable or unwilling to report the hate
It has just been reported that the number crimes committed against them. This
of disability hate crimes recorded by police could be because, as the same crime
forces in England and Wales for the year survey consistently shows, victims have low
ended December 2011 was 1,877.1 This is an expectations about what, if anything,
increase of 24.1 per cent on the previous reporting the crime might actually achieve,
year, and is the only equality strand to have or it could be that these incidents are not
seen an increase in the police recording of recognised as being disability-related even
hate crimes. This could be a good thing if it when they do. There is a long way to go.

1 See http://www.report-it.org.uk/files/final_acpo_hate_crime_data_2011_
(revised_oct_2011)_1.pdf
2 Excluding the small City of London Police Force.
3


It is important to remember that hate crime
is only the tip of the iceberg. So-called hate
incidents – the name-calling, bullying, and
other treatment that wears people down –
are what the majority of disabled people
experience on a much more frequent basis
and can escalate to more serious crimes.
It is refreshing to see that at least some
parts of the media are picking up on the
contradiction between the positive
reporting on disability surrounding the
2012 Paralympics, and the day-to-day
reality for many disabled people, often
labelled as scroungers or benefit cheats
or ‘not trying hard enough’.

This ‘Manifesto for change’ sets out our
revised recommendations for action
over the next five years. These have been
developed following consultation with a
large number of government, national and
local bodies who have helped refine and
nuance the recommendations to make sure
that they work, and to ensure that those
organisations own them.

The issue of disability-related harassment
might be ‘Out in the open’ but it is, most
certainly, not yet sorted. It is incumbent
upon us all to work to overcome this blight
on our society.

4


Introduction
Research on the safety and security It did not cover harassment in the
of disabled people conducted by the workplace, which is covered by a separate
Commission in 2009 found that violence legislative framework.
and hostility is a daily experience for some
disabled people.3 In September 2011, the Commission
concluded the formal part of the inquiry
These findings led the Commission when it published the report Hidden in
to launch its largest inquiry to date. It plain sight.4 This report highlighted
analysed over 500 pieces of evidence and systemic failures by organisations in
held formal hearings with expert witnesses. preventing disability-related harassment
and in tackling it effectively when it
The terms of reference for the inquiry happens, and gave draft recommendations
were to investigate the causes of disability- for action.
related harassment and the actions of
public authorities and public transport In this follow-up to Hidden in plain sight,
operators to prevent and eliminate it. we summarise a wide range of formal
responses from relevant organisations
The scope of the inquiry covered: and set out our final recommendations.

England, Scotland and Wales The responses are, overall, positive and
disability-related harassment carried encouraging. There are some very
out by individuals or groups of people, promising signs of action and commitment
including strangers, neighbours, from those with the power and
acquaintances, friends, family, relatives responsibility to create change. There is less
and partners progress so far in terms of measureable
practical actions. However, we expect
harassment in public places such as significant progress over the next few years
streets, parks, schools, leisure facilities, towards achieving better outcomes for all
on public transport and in private places disabled people.
such as in the home.

3 Sin et al. (2009) Disabled people’s experiences of targeted violence and hostility,
Equality and Human Rights Commission research report 21.
4 Hidden in plain sight: Inquiry into disability-related harassment, Equality and Human
Rights Commission (2011). Available at: www.equalityhumanrights.com
5


Following up the
Commission’s inquiry
Hidden in plain sight proposed seven core The Commission will ensure that
recommendations and a further 79 more consideration of the findings, and the
detailed recommendations. The recommendations from the inquiry, inform
Commission put these recommendations our own work and, where appropriate, we will
out for a six-month consultation period so monitor the performance of organisations
that government, organisations and that have a specific responsibility to tackle
individuals could comment on how disability-related harassment.
effective they felt they would be in reducing
disability-related harassment. During the inquiry we heard evidence from
public authorities about serious incidents
We wrote to relevant organisations to ask: which had happened in their area. Part 2 of
for formal responses to the inquiry’s Hidden in plain sight included reports on
recommendations 10 of those cases. Those authorities also
provided evidence on the steps they have
what they were planning to do differently taken to improve practice in preventing and
as a result of the inquiry. dealing with disability-related harassment.
We reported on that in Appendix 17 of
The approach varied across England, Hidden in plain sight. Alongside issuing
Scotland and Wales to fit with the legal, this report we have asked a number of those
policy and cultural context in each country. authorities to tell us more about the
progress they are making in improving
We received 81 formal responses and the practice in their area and to explain how
three national governments published they have taken the public sector equality
their commitments. These responses, duty into account in doing so. If the
taken together, show how our evidence shows that inadequate action has
recommendations are likely to be met in been taken to improve, we will consider
coming years. The responses are published invoking our formal enforcement powers
on the Commission’s website: under the Equality Act 2006 to make
www.equalityhumanrights.com. Each authorities take the issues and their
response is a public statement by that obligations seriously.
organisation of what they have already done
to make progress and their commitments We have already committed to conduct a
on what they will do in the future. We review in 2015 in our three-year strategic
encourage individuals, disabled people’s plan, and we expect organisations to have
organisations and others to use these to made significant progress in implementing
hold each organisation to account. our recommendations. We also expect that
other inspection and regulatory bodies, and
Based on the responses, and our own disabled people’s organisations, will
review, we have produced a final list of continue to work in their sector or local area
43 strategic recommendations grouped to support relevant organisations to take
under seven sections in this report. action and to hold them to account.
6


Government responses
The UK Government and the devolved The Commission will be continuing
administrations in Scotland and Wales discussions with government departments
have responded formally and positively on other areas including:
to the Commission’s inquiry. Across the
three countries of Great Britain, there better understanding of the motivations
are different starting points in terms of of perpetrators and societal causes
legislation and policy and consequently of disability-related harassment
different areas of focus. the collection of comprehensive data
on disability-related harassment, to
The UK Government improve decision-making and
accountability
The UK Government’s formal response5 to
Hidden in plain sight was published on 17 empowering local leadership and other
July 2012. It refers to a number of local agents of change to have access to
significant new policy or legislative the right information and support to
approaches that have been or will be hold authorities to account and make
influenced by the inquiry’s change happen
recommendations. addressing cyber-bullying

The Commission considers the UK the impact of terminology and language
Government’s response to be in bringing about cultural change.
comprehensive and robust in relation to:
Scottish Government
the Government’s clear commitment to
tackling this issue The policy drivers in Scotland
commitments to improving data
There is a unique range of distinctive policy
collection on the application of section
drivers in Scotland directly relevant to the
146 of the Criminal Justice Act and data
inquiry:
sharing
safeguarding measures in health services The Scottish specific equality duties6
require public authorities to set
tackling antisocial behaviour in social
equality outcomes for all protected
housing
characteristics by April 2013, gather and
a commitment to developing reciprocal act on evidence, involve equality groups
reporting arrangements in transport. and assess the impact of all new policies
on protected groups.
Priorities for the Scottish Government
and, through Single Outcome

5 Available at: http://odi.dwp.gov.uk/docs/odi-projects/hidden-in-plain-sight.pdf
6 See http://www.equalityhumanrights.com/scotland/public-sector-equality-duty/
specific-duty-regulations/
7


Agreements, local agencies are set with 2002.8 The outcome of this case had a
reference to the National Outcomes and wide impact across public authorities in
Priorities. Scotland. It became a catalyst for change
Reform of the scrutiny landscape,7 with a to the legislative and policy context for
shift to a more proportionate, risk-based tackling disability-related harassment
and shared scrutiny process. across the nation.

Welsh Government
The response in Scotland
The Commission set out four areas for
Following the launch of the inquiry report intervention in Wales:
in September 2011, the Commission in
Scotland concentrated on the sectors A determination to eliminate
central to effective delivery of the inquiry harassment needs to be shown by
recommendations. These are: leaders. Partnerships to prevent and
respond to harassment and share
central government effective practice should be encouraged,
criminal justice authorities including piloting Multi-Agency Risk
Assessment Conferences (MARACs).
leadership bodies such as the Association
of Chief Police Officers in Scotland and the The new equality duties should be used
Association of Directors of Social Work to prioritise tackling disability-related
harassment.
the audit and scrutiny sector,
particularly the Care Inspectorate. A human rights-based approach to
safeguarding should be introduced by
the Welsh Government.
The response from these sectors has been
very encouraging, with recognition of the Increased reporting and public
scale and seriousness of the challenge. authorities to put in place measures to
Respondents have also effectively identified ensure a positive reporting experience
the legal and policy levers particular and effective support.
to Scotland.
As a result of our report, in December 2011
The Scottish Government’s Health and the National Assembly’s Communities,
Well-Being Directorate, Justice Directorate Equality and Local Government Committee
and Finance and Public Reform Directorate held an Inquiry into disability-related
all submitted formal and positive responses harassment. In its report,9 the Committee
to the Commission’s inquiry. calls on the Welsh Government to set a
strategic direction in tackling disability-
There has been strong action in some local related harassment by driving through a
areas, such as that following the case of the collaborative action plan.
‘vulnerable adult’ in Lothian and Borders in

7 See http://www.scotland.gov.uk/Topics/Government/PublicServiceReform/
IndependentReviewofReg/scrutinyimprovement
8 Hidden in plain sight: Inquiry into disability-related harassment, Equality and Human
Rights Commission (2011), pp. 26-9. Available at: www.equalityhumanrights.com
9 Available at: http://www.senedd.assemblywales.org
9


The Commission considers the Welsh adoption of an objective to reduce the
Government’s response to be incidence of all forms of violence against
comprehensive and strong, particularly women, domestic abuse, ‘honour’-based
in relation to: violence, hate crime (including
work with stakeholders to take forward disability), bullying and elder abuse
an action-focused framework to tackle within the Wales Strategic Equality Plan10
hate crime across the protected commissioning of research Who commits
characteristics of race, disability, religion hate crime? (available autumn 2012)
or belief, sexual orientation and gender publication of anti-bullying guidance
reassignment Respecting others: anti-bullying
overview.11

10 Available at: http://wales.gov.uk/topics/equality/equalityactatwork/?lang=en
11 Available at: http://wales.gov.uk/topics/educationandskills/publications/circulars/
antibullying/?lang=en
10


Developing the
manifesto for change
In reviewing responses to the draft In each section below, we set out a summary
recommendations within Hidden in plain of the relevant findings and original
sight, we saw that a number of sector- recommendations from Hidden in plain
specific recommendations were equally sight and our analysis of responses to
applicable to all sectors, and removed these recommendations. Our final
duplicates. recommendations are listed at the
end of each section.
We have, where relevant, moved from a
focus on one sector to wider agencies and Details of how we will evaluate how these
partnerships. We have also recognised the recommendations have been implemented
need to address a range of de-regulated can be found at ‘Evaluating results’ at the
service providers by changing our focus end of this report.
from ‘public authorities’ to ‘authorities’.
We have also amended some
recommendations in the light of very useful
feedback to our consultation, and grouped
them into the following seven sections:

1. Reporting, recording and recognition
2. Addressing gaps in legislation and policy
3. Ensuring adequate support and
advocacy
4. Improved practice and shared learning
5. Redress and accessing justice
6. Prevention, deterrence and
understanding motivation
7. Transparency, accountability and
involvement

We are pleased that the majority of
respondents have already begun to
draft their action plans. We realise
these were based on the original draft
recommendations. Our intent is that these
revised recommendations serve as a guide
for the ongoing development of sector
action plans.

11


Section 1: Reporting,
recording and recognition
What we found Responses received highlighted potential
difficulties in a number of key areas,
Hidden in plain sight found that under- including data capture and the sharing
reporting of disability-related harassment of information across authorities
was widespread; that disabled people often and agencies.
saw incidents as so commonplace as to be
part of daily life and not ‘hate crimes’ and Authorities have indicated that establishing
that those receiving reports of harassment whether a victim is disabled is sometimes
were failing to ask about disability or see it difficult for police forces in England and
as a potential motivation. As a result, the Wales (the legislation to do so already
prevalence and impact of disability-related exists in Scotland). Our amended
harassment were greatly underestimated. recommendation asks for this data to
be included in the data already collected
Our original recommendations on other protected characteristics.

Hidden in plain sight made a range of draft There were mixed views on our
recommendations to tackle these issues. recommendation about the language of
These included identifying and recording ‘hate crime’. The UK Government rejected
whether a victim is disabled, changes to this recommendation on the basis that it did
the use of language on hate crime and on not fit within a widely internationally and
special measures, and ensuring robust publically recognised framework for hate
safeguarding alerts and accessible crime. The Commission recognises this
reporting systems for residents living problem and the associated problem of
in institutions. tackling multiple-identity hate crimes but
we maintain the view, based on the evidence
Response to the presented to us, that understanding of and
recommendations identification with ‘hate crime’ language
is a barrier for both victims and others in
The Commission received a positive recognising, reporting and tackling the
response to these recommendations breadth of experiences of disability-related
from most organisations. There was harassment. On that basis, we have
consensus that greater reporting, recording incorporated the removal of the barriers
and recognition are required to address created by terminology into a general
disability-related harassment. Although recommendation on the removal of barriers
there were some questions about the to reporting.
practicalities of implementation, there
were encouraging commitments to action. In relation to our recommendation on use
of the term ‘special measures’, the UK
Government helpfully provided

12


clarification. We have removed this harassment and the outcomes and
recommendation and replaced it with a consequences for perpetrators. This could
general one that requires the removal of act as a deterrent to perpetrators and help
barriers for disabled people through all build the confidence of disabled people
stages of the process of accessing justice, to report.
and in later sections we explain how this
will be realised. It remains a key priority for the
Commission to encourage further
Summary of our findings exploration of the problems and solutions
to recording and reporting, particularly
There has been some significant progress at a local level, in the promising work on
in recognising and addressing the barriers partnerships identified through the formal
to reporting. We recognise the problems in responses. The new Police and Crime
linking up data collection systems and commissioners in England could play
appreciate that this can only be addressed an important role here.
as part of a longer-term strategy. There are
also some very promising developments in Final recommendations
the area of training.
Having reviewed the responses, the
We welcome the Government response Commission has agreed the following
on cyber-bullying in education, however final recommendations under Section 1:
cyber-bullying is a wider problem and
Government should work with a range 1. Authorities should remove barriers
of partners to address it. to all disabled people reporting crime,
antisocial behaviour or bullying,
There has been promising progress by some including ‘cyber-bullying’. Authorities
police forces on police call screening for should also consider how they
repeat victims. However, this is yet to be communicate with disabled people
effective across the majority of forces in and use terminology that service users
England and Wales, particularly where identify with.
repeat calls rather than repeat incidents 2. Staff responding to harassment should
are used to trigger action. be trained in how to better gather and
record personal information about
Our evidence indicates that incidents may
disability in an appropriate and
mount up before a first call is made, for
sensitive manner.
a variety of reasons. A move towards
recording repeat incidents will enable 3. Authorities should adopt recording
better triggers for deploying resources systems that record whether the
for effective early intervention. victim was disabled (along with other
protected characteristics), and whether
We recognise the challenges that recording hostility/prejudice to disability was a
and reporting of incidents presents to motivation.
organisations, and note the commitment 4. Authorities should recognise the
and significant progress made by some potential for escalation and record
organisations on this issue. We believe this incidents leading up to crimes in order
data should be publicised, with information to support the implementation of
on action undertaken to challenge preventative actions.

13


5. Health and social care providers should
put robust and accessible systems
in place so that residents living in
institutions can be confident when
reporting harassment that they will
be treated sensitively.
6. Police call screening should focus on
acknowledgement, risk of harm and the
number of incidents rather than the
number of calls in order to identify
and address repeat victimisation.
7. Staff delivering health and social care
services to the public should be trained
in safeguarding adults and children,
including how to refer to appropriate
services.

14


Section 2: Addressing gaps
in legislation and policy
What we found sentencing in England and Wales for
murder motivated by hatred or hostility
Hidden in plain sight identified a number of towards disabled (and transgender) victims
significant gaps in current legislative equal to sentencing for murder motivated
frameworks, including a disparity in by hatred or hostility to the other protected
sentencing guidelines for different groups characteristics of race, religion and sexual
and an insufficiently robust safeguarding orientation. (This was already covered in
referral process that means people are put Scotland under the Offences (Aggravation
at risk and criminal acts are not promptly by Prejudice) (Scotland) Act 2009.)12 We
referred to the police. have removed this recommendation as it
has now been achieved.
Our original recommendations
In July 2012, the Government published the
Hidden in plain sight made a range of draft Care and Support White Paper and the draft
recommendations to tackle these issues. Care and Support Bill. These documents set
These included a review of eligibility criteria out the Government’s ambitious plans for
to increase social interaction and reduce transforming care and support so that
social isolation for disabled people, everyone in England can plan and prepare
revisions to the ‘No Secrets’ guidance in for their care needs, access high quality care
England, statutory recognition of adult when they need it, and exercise choice and
safeguarding boards and parity in control over the care they receive.
sentencing guidelines for all types of
The Bill contains clauses that puts
identity-based murders.
Safeguarding Adult Boards on a statutory
footing, better equipped both to prevent
Response to the abuse and to respond when it occurs. Further
recommendations clauses ensure local authorities establish and
maintain a service to provide advice on how
There has been substantial progress in to raise concerns about risk and
implementing these recommendations, safeguarding. These reforms will set out a
particularly from national governments. clear framework within which organisations
We were particularly pleased about the must act which resounds significantly with
amendment to Schedule 21 of the Criminal the inquiry recommendations.
Justice Act 2003 to achieve parity in
sentencing guidelines for identity-based We have retained the recommendations
murders. on these important issues in recognition
of the fact that at the time of publication of
This will amend the Criminal Justice Act this report the amendments are still at the
2003 to make the starting point for Bill stage.

12 See http://www.legislation.gov.uk/asp/2009/8/pdfs/asp_20090008_en.pdf
16


Government rejected the draft to consider the impact of the public
recommendation to build reports and plans sector equality duty in tackling
to tackle disability-related harassment into disability-related harassment within
government strategies. The Commission their jurisdiction.
supports the Government’s role in
devolving decision-making to a local
Final recommendations
level, but is still of the view that national
Government strategies should address Having reviewed the responses, the
disability-related harassment and so Commission has agreed the following
have retained this recommendation. final recommendations under Section 2:

Summary of our findings 1. National governments should:

We welcome the significant progress and review the adequacy and
commitment made to addressing the gaps effectiveness of the legal framework
in legislation and policy that support action for offences that are motivated by
to tackle disability-related harassment: hostility to disability
review all statutory and common law
An amendment to the Health and Social restrictions on the public
Care Bill on the application of the Human participation of disabled people, and
Rights Act; the UK Government restated other laws which unnecessarily and
its view that local authority- inappropriately treat disabled people
commissioned care services in England differently to others
and Wales are covered by the Human
ensure government reviews of the
Rights Act.13
public sector equality duties facilitate
The Welsh Assembly Government’s draft eliminating disability-related
Social Services (Wales) Bill is based on a harassment
human rights approach.
place adult safeguarding boards on a
The UK Government’s hate crime plan statutory basis
‘Challenge it, Report it, Stop it’14 will
introduce and develop human rights-
consider whether there is a case for
based approaches to safeguarding
changing the law on incitement of hatred
on grounds of disability, which falls working with other departments,
under the Public Order Act. The plan ensure ownership within and
also includes a commitment to placing amongst statutory authorities for
Safeguarding Adult Boards on a tackling disability-related
statutory basis, and defines the six harassment
principles governing the actions of the build reports and plans to tackle
boards as empowerment, protection, disability-related harassment into
prevention, proportionality, partnership government disability strategies.
and accountability. This is in line with
our recommendation to all governments

13 Specific legislation, almost a decade old, already makes this explicit in Scotland.
14 Available at: http://www.homeoffice.gov.uk/publications/crime/hate-crime-action-
plan/action-plan?view=Binary
17


2. The Ministry of Justice and the wider
criminal justice system should ensure
that section 146 of the Criminal Justice
Act 2003 is appropriately, consistently
and transparently applied.
3. Authorities should ensure that policy
developments on social inclusion
incorporate the recommendations from
the inquiry recognising the potential link
between propensity for social isolation
and segregation, taking a social model
approach. These should work towards
capacity for decision-making being
supported, where appropriate, with a
human rights-based approach.
4. Eligibility criteria for services should not
be focused just on vulnerability or risk
of harm, but instead on an individual’s
circumstances preventing them from
fully achieving their human rights, and
targeting resources to enable them to
do so.
5. If a disabled person moves in order to
avoid disability-related harassment,
their security of tenure should not be
adversely affected.

18


Section 3: Ensuring
adequate support and
advocacy
What we found However, we welcomed governments’
support for this recommendation, their
Hidden in plain sight found failings in proposed work to review victims’ services,
the provision of special measures15 to help pilots to focus enhanced services to all
disabled or intimidated witnesses give intimidated and vulnerable witnesses and
their best evidence in court across England, the commitment to build in quality
Scotland and Wales. There were also assurance systems to this work. We have
significant gaps in provision of support retained a focus on accessibility in our final
services, not just at the reporting stage but recommendations.
throughout and beyond the process of
accessing justice. We acknowledge the difficulties of early
identification and follow through of special
Our original recommendations measures but retain this recommendation
because of its importance to achieving
Hidden in plain sight made a range of draft justice.
recommendations to tackle these issues.
These included: changing the procedure for Summary of our findings
special measures, early identification that a
victim is disabled and the need for special There have been some very promising
measures, the availability of good quality developments in terms of accessibility of
accessible and independent advocacy services with all authorities demonstrating
throughout a case, and access auditing of a commitment to meeting the needs of
support services. disabled people. We recognise that the
current economic climate may restrict the
Response to the available resources for addressing
recommendations accessibility of support services. We believe
that it is only by undertaking an audit that
A number of authorities indicated that service providers will be able to identify
resources could impact on the ability to resource requirements and build these into
implement the recommendation to their long-term service plans.
undertake access audits of services.

15 ‘Special measures’ are a series of provisions that help vulnerable and intimidated
witnesses give their best evidence in court and help to relieve some of the stress
associated with giving evidence. Special measures apply to prosecution and defense
witnesses, but not to the defendant.
19


We are disappointed to note slow progress Final recommendations
in improving the application of special
measures and believe that for special Having reviewed the responses, the
measures to aid continuous transition Commission has agreed the following
through the criminal justice system, final recommendations under Section 3:
authorities and jurisdictions will need to
work together. 1. Requirements for special measures
should be identified and implemented
We realise that the complexity of different at the police investigation stage, and
authorities within the criminal justice appropriate reasonable adjustments
system means there is work to be done to should be provided throughout
align procedures. However, we do feel this investigation and prosecution. Lack of
is a critical area for ensuring access to provision of either must not be a barrier
justice and sending out important messages to progression of a case nor a rationale
to disabled people about their rights to for dropping a case. Authorities should
access justice. These include that disability- refer disabled victims of harassment,
related harassment will be taken seriously antisocial behaviour and crime to
and that victims and witnesses will receive support services (specialist services
the support they require to give evidence. if appropriate).
2. Safeguarding Boards and Community
We welcome the commitment made by the Safety Partnerships should ensure that
Ministry of Justice and Crown Prosecution accessible information and advocacy
Service to tackle the challenges of bringing services are available to enable disabled
together different systems for the purpose people to understand and exercise
of overall monitoring and recording the their rights.
application of special measures.
3. Where authorities have obligations to
provide or commission local support
services, they should take into account
their own public sector equality duties at
the planning stage, and reflect adequate
provision for access to disabled people.
4. The Ministry of Justice should provide
a framework for a review of all barriers
within the courts system for disabled
people whether legal, attitudinal or
physical, such as restrictions on jury
service or provision of advocacy or
interpreter services or access to court
buildings. Disabled people should be
involved in challenging the barriers.

20


Section 4: Improved
practice and shared
learning
What we found Good examples of strong partnership
approaches included the commitment from
Hidden in plain sight found barriers to joint police forces to work with social housing
working. These included problems with and education providers and transport
sharing data, failure to recognise providers to develop links with education
‘incidents’16 and a failure to pick up providers for the purposes of preventative
incidents at an early stage. work on disability-related harassment.

Our original recommendations Some transport providers and
intermediaries indicated that was not
Hidden in plain sight made a range of draft practical. However, the British Transport
recommendations to tackle these issues. Police and Department of Transport are
These included developing reciprocal taking a lead on this.
reporting arrangements between public
transport providers, reviewing the Transport providers identified problems
guidelines for serious case reviews, with referring all allegations of crimes
developing and disseminating procedures committed against disabled children and
and standards to minimise the risk of adults to the police and reciprocal reporting
harassment, developing a strong arrangements. However, the British
citizenship and human rights agenda in Transport Police and Department for
schools, and ensuring security of tenure for Transport have committed themselves to
a disabled person forced to move to avoid support reporting of disability-related
disability-related harassment. harassment including across deregulated
services, and we have adopted this as a final
Response to the recommendation.
recommendations
Summary of our findings
We welcome and have adopted the
Government’s proposed amendment to Some responses received indicate a
our draft recommendation on schools significant move towards joint and
promoting understanding of disability innovative approaches. The Director of
and sharing good practice, which Public Prosecutions, Keir Starmer QC, and
recognises the role of national and the Association of Chief Police Officers’
local leaders of education. (ACPO) lead officer, Chief Constable Simon

16 Hidden in plain sight defined incidents as those experiences deemed to be low level and
not recorded as a crime or criminal activity e.g. name calling.
21


Cole, have taken very public leading roles 2. Local Authorities should play a lead role
within the criminal justice sector. We are in driving local partnerships to deliver on
pleased to see this beginning to take preventing and tackling disability-
shape in other sectors. related harassment, and all authorities
should develop approaches for effective
A number of responses were silent on our joint working.
recommendation about improved practice
3. Regulators, inspectorates and
and shared learning. Given how important
ombudsmen, along with senior
we found effective joined-up working to be
representatives of service providers and
in tackling the issue, especially at a local
their clients, should work together to
level, we call on all authorities to develop
devise and disseminate procedures and
approaches for more effective joint working.
standards which seek to minimise the
risk of harassment.
The 2012 Her Majesty’s Inspectorate
of Constabulary report17 reflected our 4. Adult safeguarding boards should use
conclusion that there is a need for further professional networks to ensure:
evidence and stronger data on repeat lessons learnt from local serious case
victims and perpetrators. reviews are embedded in training
and practice, and shared and
For example, while many police forces are evaluated nationally across all
now able to ‘flag’ repeat victims, this can authorities
only be done on a ‘repeat call’ basis. This
will not record those callers who have summaries of serious case reviews
experienced repeat victimisation and make are publicly available and
their first call some way into experiencing disseminated
harassment. Currently only five police educational establishments share
forces (out of 44 in England and Wales) continuous developments and
consistently question the caller to establish practice in tackling disability-related
whether repeat victimisation has occurred. harassment.
5. Serious case reviews should be
Final recommendations mandatory for cases involving adults
at risk unless proved unnecessary.
Having reviewed the responses, the
Commission has agreed the following 6. Transport providers should develop
final recommendations under Section 4: reciprocal reporting arrangements and
work in partnership to address
1. Local agencies and partners should disability-related harassment.
review the priority they give to
eliminating harassment, and their
information sharing systems, using joint
intelligence to identify and stop repeat
victimisation or repeat perpetrators and
prevent further escalation.

17 Available at: http://www.hmic.gov.uk/media/a-step-in-the-right-direction-the-
policing-of-anti-social-behaviour.pdf
22


Section 5: Redress and
accessing justice
What we found Summary of our findings
Hidden in plain sight found that very few We have revised our recommendation on
cases of disability-related harassment go access to the court system, and disabled
through the courts; and even when they do, people’s experiences, based on the
sentencing does not always follow. There is significant commitment and progress
very limited application of section 146 of the made by Government.
Criminal Justice Act 2003,18 a failure to
apply special measures properly and cases Responses to the draft recommendations
are often dropped because of perceived were promising. They included a
witness credibility. commitment to review the recording of
whether disability is a motivating factor in
Our original recommendations crimes, to establish whether this is being
overlooked currently, and the consistency
Hidden in plain sight made a range of draft of application of section 146 of the Criminal
recommendations to tackle these issues. Justice Act.
These included: ensuring the seriousness
of the offence, rather than the capacity of We also welcome the UK Government’s
the victim, determines the basis for an proposal to put quality assurance systems
investigation; investigation for potential in place to ensure that these commitments
aggravated offences throughout the are being met.
progression of cases, where disability
may be a factor, and ensuring that disabled Final recommendations
people have equitable access to the
court system. Having reviewed the responses, the
Commission has agreed the following
Response to the final recommendations under Section 5:
recommendations
1. The perceived capacity of the victim
The most promising responses throughout should never form the basis for decisions
the inquiry relate to access to justice. There about police investigation.
is currently a dearth of knowledge on the 2. Whenever repeat perpetrators or repeat
motivations of perpetrators of disability- victims are identified, the priority given
related harassment and we welcome the UK to solving the case should always be
and Wales Governments’ commitments to
increased to urgent.
begin to address this. This will help police
forces and other agencies begin to develop 3. Crimes motivated in part or in whole by
early intervention measures once profiles hostility/prejudice to disability need to
and motivations are better understood. be recognised, investigated and

18 See http://www.disabilityhatecrime.org.uk/index.php/cjs/section-146
23


prosecuted as such. Where there is 4. Government should undertake an
evidence of hostility/prejudice police extensive review of how disabled people
should gather evidence to support could be better protected within an
prosecution as an aggravated offence adversarial justice system, including
utilising section 146 of the Criminal consideration of limiting when the
Justice Act where appropriate. victim’s impairment can be used as
evidence or in questioning in court.

24


Section 6: Prevention,
deterrence and
understanding motivation
What we found better monitoring of the performance of
those responsible for dealing with it.
Hidden in plain sight found a lack of
investment in research into the motivation We have retained the existing
and profile of perpetrators. Equally recommendation but do not define how
significant, there is no statutory this should be achieved. We acknowledge
requirement to conduct a serious case the Government's point that achievement
review for the murder of a disabled person, of this recommendation can include using
as there is in England and Wales following existing data sources more effectively.
the death of a child or adult from domestic Where a review of existing data highlights
violence. gaps, we expect that Government will
fill these.
Our original recommendations
We were also pleased that the UK
Hidden in plain sight made a range of draft Government agreed with our draft
recommendations to tackle these issues. recommendation on transport providers
These included: appointment of taking steps to ‘design out’ conflict, for
harassment co-ordinators; implementing example between wheelchair users and
interventions to prevent occurrences and those with pushchairs utilising shared
escalation of harassment; understanding spaces on public transport. In reviewing the
the characteristics and motivations of draft recommendations, we recognised this
perpetrators; designing out potential for as an issue that extends beyond transport
conflict in transport; commissioning of and we have therefore reworded it to
primary research on the impact of address the new recommendation to
segregated education on attitudes to all architects, planners and designers.
disabled people, and research to fill the
knowledge and data gaps on disability- The UK Government recognised the
related harassment. benefits of adopting ‘lesson learned
reviews’ and the sharing of good practice.
Response to the
recommendations The Department for Education did not
agree with the recommendation about
The UK Government partially agreed with primary research into the impact of non-
our recommendation that definitive data inclusive schooling for disabled pupils.
should be available to spell out the scale,
severity and nature of disability-related There were also gaps in responses from
harassment and that this would enable government departments on the effective

25


dissemination of learning from serious the UK cross-government hate crime
case reviews, other than in the ‘case of programme) and are better placed to
the vulnerable adult’ in Scotland. There respond.
was also some disagreement with the
recommendations from the social Research will allow authorities to develop
care sector. an in-depth understanding of motivation
of perpetrators.
The Commission would like to see further
progress on sharing of lessons learnt from We have had some promising responses
serious case reviews, across authorities to learning more about perpetration
and geographical areas. and motivation. We welcome the UK
Government’s commitment in this area and
We recognise the challenge this look forward to reviewing the outcomes.
recommendation represents but
have retained it because progress on We welcome the significant gains the new
communication and learning will be sentencing powers bring. In order to be
even more crucial when power is an effective deterrent, it is important the
devolved to a local level. criminal justice authorities make full
use of the opportunities these bring to
Summary of our findings tackle disability-related harassment.
Consideration is also needed on whether
A significant issue for the inquiry was that specific aggravated/incitement offences
the new sentencing guidelines in England would act as a further deterrent.
and Wales should be used to enable
monitoring and evaluation of consistency The UK Government has recognised the
of sentencing for disability-related link between bullying and harassment and
harassment offences. The response from strengthened teachers’ powers to tackle
the Ministry of Justice was that this is poor behaviour and bullying.
already possible. The Commission has
removed reference to the new sentencing However, they have rejected our
guidelines from the final recommendation recommendation for the Department for
but kept the reference to monitoring Education to commission research on
and evaluation. the impact of segregated education. The
Government made the point that quality of
We were very pleased that the UK provision rather than setting is important.
Government agreed with our However, the Commission believes that
recommendation that authorities and setting may also be important and that
agencies should include provisions against separating disabled children from their
disability-related harassment within peers at an early stage may have a long-term
tenancy agreements and in taking action impact. We suspect that this could be in
against breaches. terms of social isolation and resilience of
disabled people, attitudes among non-
We have changed the responsibility for disabled children and adults, and the
the recommendation on investment in capacity for positive interaction. We
research from the police to national therefore believe research on this would
governments. This is because governments be beneficial.
have already taken a lead (for example in

26


Final recommendations identify and implement interventions
to prevent harassment occurring in
Having reviewed the responses, the the first place and develop responses
Commission has agreed the following to prevent escalation. This should
final recommendations under Section 6: include using legal and non-legal
sanctions as deterrents to would-be
1. National governments should take the lead perpetrators, such as provisions
in developing collective understanding against disability-related harassment
of the motivations of perpetrators of within tenancy agreements
disability-related harassment, including
ensure that perpetrators of
for the purposes of prevention, profiling
harassment face consequences and
and early intervention.
that these are properly implemented.
2. The Department for Education and
5. Authorities should identify and
devolved administrations in Scotland
implement ways to design out potential
and Wales should review existing
for conflict in use of shared space within
evidence on the extent to which
environmental infrastructures.
segregated education (or inadequately
supported integrated education) affects 6. Police forces should develop an in-depth
the ability of disabled children to be understanding of the characteristics and
included within mainstream society. motivations of perpetrators, design local
They should also consider evidence on prevention strategies accordingly and
the extent to which segregation adversely evidence their effectiveness.
affects non-disabled people’s views of 7. Schools and colleges should develop
disability and disabled people. Where material for helping students
sufficient primary evidence is understand disabled people and the
unavailable, they should consider social model of disability, and the
commissioning new research. prejudice that disabled people face
3. Public authorities should use the public within society. The materials should
sector equality duty as a framework for encourage a better understanding and
helping promote positive images of respect for diversity and difference and
disabled people and tackle the low help students know what to do when
representation of disabled people across they see others perpetrating bullying
all areas of public life. and harassment, both in school and
outside (on public transport, in public
4. All authorities should:
places, etc).
develop, implement and review
8. Schools and colleges should ensure
awareness raising campaigns to
disabled pupils and those with special
encourage victims and witnesses of
educational needs (SEN) are able to
disability-related harassment to come
participate in all school/college and
forward
after-school/college activities on an
encourage all individuals and equal basis with non-disabled pupils
organisations to recognise, report (mainstreaming as a prevention).
and respond to any incidences of
disability-related harassment they
may encounter

27


Section 7: Transparency,
accountability and
involvement
What we found These included:

Hidden in plain sight found that the the availability of comprehensive data to
absence of data is a major problem to enable performance monitoring
identifying, preventing and tackling
the use of the new sentencing guidelines
disability-related harassment. This makes
in England and Wales to monitor
it harder for individuals and organisations
consistency of sentencing
at a local level to hold authorities to
account for their performance. the review of no-criming and ‘motiveless’
procedures
In addition, regulators, inspectorates, the ability to make limiting judgements
ombudsmen and authorities themselves where schools under-perform in
need to better understand the nature of equality-related areas e.g. identity-based
the problem in order to address it, and bullying
the collation of relevant data will help
identify where and how to best implement that regulators should include
necessary changes. performance measures for dealing with
disability-related harassment and other
There is already promising progress in the forms of hate crime
criminal justice sector from inspectorates regulators intervening in serious cases
in starting to identify the nature of the of repeat disability-related harassment
problem, but as yet little is evident across
the identification of hate ‘crime’ and hate
other sectors.
‘incident’ levels within crime figures.
Schools are hugely important in shaping
and changing young people’s attitudes Response to the
towards disabled people. Their recommendations
interpretation and application of the
national curriculum can make a significant We recognise that it would be difficult to
impact on the inclusion of disabled people report on historic data and see the new
in everyday life. sentencing guidelines as an opportunity to
begin to collect and evaluate current and
Our original recommendations future data to inform future policy.

Hidden in plain sight made a range of draft We have retained the recommendation that
recommendations to tackle these issues. all authorities should have monitoring

29


systems in place to record details about developing more effective deterrents
victims, alleged perpetrators, the nature of will remain key priorities for tackling
incidents and repeated harassment. disability-related harassment.
However, we recognise the significant
resource implications of this We recognise the importance of effectively
recommendation and welcome the feasibility using existing data and research but also
study proposed by the UK Government. believe that an additional investment in
new research to address the gaps in
ACPO and the National Policing intelligence on disability-related
Improvement Agency, in their response, harassment could potentially realise
stated that all forces work within the similar benefits to that of work on domestic
framework of the NCRS (Home Office violence.
Counting Rules for Recorded Crime) in
relation to recording incidents as crimes and Final recommendations
when a recorded crime is re-classified or
deleted – ‘no-criming’.19 Forces are audited Having reviewed the responses, the
for compliance on this and on the quality of Commission has agreed the following final
their data. The recommendation around no- recommendations under Section 7:
criming has been retained but re-worded
slightly to help pick up disability-related 1. Leaders of authorities and elected
harassment hidden within other crime data representatives should show strong
such as domestic violence, rape and sexual personal commitment, ownership and
assault in order to help properly understand determination to deliver change.
the scale of the issue. 2. Authorities should:

Following clarification from regulators and proactively work with disabled people
inspectors we have amended the and their representative organisations
recommendation that regulators should to identify where risks of disability-
always intervene in serious disability- related harassment are higher and
related incidents leading to death take appropriate action to address it
or significant injury. Our new proactively engage with disabled
recommendation refers to the need for people to improve services and
regulators and inspectors to be satisfied practice on preventing and tackling
that action is taken by the appropriate disability-related harassment,
agency, and to intervene when it is not. ensuring the provision of reasonable
adjustments to aid involvement and
Summary of our findings participation.
3. Authorities should collect and share data
We understand that the progress of the
about victim(s), alleged perpetrator(s),
localism agenda will ensure that local
nature of incident(s) and repeat offending.
agencies dictate local priorities and that
national regulation will play a much-
reduced role. Preventative work,
understanding perpetrators and

19 ‘No-criming’ is the term used for actions taken when it is established that a crime did
not in fact occur.
30


4. Regulators, inspectorates and 6. Police should review their rates of ‘no-
ombudsmen should: criming’ where the victim is disabled,
ensure that comprehensive data is across all crime types, and address any
collected and shared which spells issues (i.e. disbelief) that may emerge
out the scale, severity and nature of as a result.
disability-related harassment within 7. Disabled people should be involved in
localities public transport policy development
ensure that application of section 146 and transport providers should work
of the Criminal Justice Act 2003 is in partnership with criminal justice
monitored, evaluated and reported on authorities to reduce risk on and around
to ensure appropriate application is transport provision.
considered in all cases. 8. Regeneration and social housing design
5. Regulators, inspectorates and and planning should involve disabled
ombudsmen should: people at planning stages in order to
help ‘design out crime’ from future
limit judgements of inspection and developments.
regulation by performance on equality
objectives, including measures taken 9. The Ministry of Justice should encourage
to prevent and tackle disability- the publication of accessible performance
related harassment. Poor performers statistics that clearly identify:
should be identified and sanctioned if the number of reported incidents
no improvement is apparent within a recorded as crimes
reasonable period of time the number of reported incidents
ensure their responses to harassment resulting in prosecution
are joined-up and use common harassment crime and harassment
standards and criteria for its incident levels within crime figures
identification
the performance of local agencies and
ensure a proportionate intervention partnerships in addressing harassment
when a serious or repeat case of
disability-related harassment service guarantees.
emerges within their sector.

31


Evaluating results
The Commission acknowledges the difficult Schedule
economic climate in which authorities
are working and the policy and structural October 2012 – baseline measures
changes that are taking place. These include agreed
the moves towards localism and new September 2013 – at the end of year one
commissioned and locally managed we will review progress against the initial
police, health care and other services. baseline measures and publish a review
on the initial response by authorities to
The Commission believes implementation the inquiry’s recommendations
of the final recommendations will deliver
the changes required to ensure disability- September 2015 – at the end of year three
related harassment is prevented where we will update our review of changes
possible and dealt with effectively when against the baseline data and publish a
it does occur. further review to assess the extent to
which our recommendations have been
Current data availability does not provide implemented by the relevant authorities
a full picture of disability-related September 2017 – at the end of year five
harassment. This is addressed within our we will conduct a final review of changes
recommendations, and we are committed in the baseline data, assess the ultimate
to following up in a fuller review in 2015 impact of the inquiry and publish a final
how and where those recommendations review of the inquiry.
have been acted upon to enable
measurement of authorities’ response to
disability-related harassment.

The Commission proposes to evaluate the
emerging impact of the inquiry at various
points over the five year period following
the launch of this Manifesto:

32


Outcome measures This data will be compared to that compiled
and published by ACPO on those hate
At each stage of the evaluation, the crimes which have been recorded by police
Commission will analyse future waves forces in England and Wales.
of Crime Survey for England and Wales
(CSEW)20 data to monitor: This will be supplemented by CSEW data on:

the overall incidence of disability-related the overall crime rates experienced by
harassment (defined as those incidents people with impairments analysed by the
which the victim felt were motivated by age of the victim
factors relating to their impairment)21
disabled people’s fears about being a
the report rate of such hate crimes to victim of crime (including their
the police and other authorities 22 perceptions of safety)
the main reasons given by respondents victim satisfaction with police actions in
for not reporting incidents of hate crime dealing with incidents which appeared
to the police and other authorities.23 motivated by a strand characteristic.24

20 The Crime Survey for England and Wales (CSEW) is the new name for the British Crime
Survey. CSEW is a face-to-face victimisations survey in which people resident in
households in England and Wales, aged 16 and over, are asked about their experiences
of crime in the 12 months prior to interview.
21 Based on the following question (for all who mentioned an incident):
‘Looking at the things on this card do you think the incident was motivated by the
offender’s attitude towards any of these factors?
Your religion or religious beliefs
Your sexuality or sexual orientation
Your age
Your gender
Any disability you may have
Don’t know
None of these’ (respondents can select all that apply)
The responses to this from the CSEW will be grossed up using demographic data to
provide an overall estimate of the incidence of crimes against disabled people which
were motivated by their disability.
22 Proportion of CSEW hate crime incidents reported to the police (or came to be known
about via other means). Because data on report rates are very small sample sizes overall,
this will be monitored for all strands.
23 Because data on report rates and the reasons for non-reporting are based on very small
sample sizes overall, this will be monitored for all strands.
24 This will be measured using CSEW data relating to victim satisfaction with the police
handling of crime incidents for crime in general and for those motivated by the factors
listed in footnote 21. Again, as a result of sample size issues, this monitoring will be for
all strands.
33


Existing Commission research25 will be Next steps
used to set the baseline for each of the above
measures, and changes in them will be To measure progress and drive the agenda
reviewed in 2013, 2015 and 2017. for the inquiry recommendations the
In particular, the Commission will be Commission will:
looking for a reduction in the current gap encourage, guide and monitor the
between the underlying incidence of progress of public authorities in meeting
disability-related harassment, the number their equality objectives, including in
of such incidents that are being reported by relation to their devolved contexts
victims and the number recorded by police where different
and ultimately prosecuted. monitor progress made towards
compliance with the Human Rights Act
The Commission has chosen to use the and the UNCRPD in respect of
CSEW because it believes it to be the best safeguarding and disability-related
data source, at this time, for estimating the harassment
underlying incidence of various forms of
work with adult protection professionals
crime and for tracking trends in these
in Scotland and Wales at the local level
over time.
to capture useful learning.
However it notes that, as is discussed in To measure progress and drive the agenda,
Home Office (2012, pp. 16-17),26 there are we expect governments, public authorities
various factors which may lead it to either and leadership organisations to:
under- or over-record the incidence of hate
use the Human Rights Act 1998 and the
crimes. These may include, for example,
public sector equality duties as enabling
a lack of understanding of the concept by
frameworks for data gathering, sharing
respondents or other factors which may
and analysis, identifying priorities and
render an individual to be more likely to
involving service users from the outset
become a victim of crime that they may
in developing and implementing policy
attribute to their personal strand
characteristics. demonstrate that the partially hidden
and under-reported issue of crime and
As well as the evaluation measures listed harassment targeting disabled people
above we will also be using the equality is effectively addressed, and
duties, the Human Rights Act and the demonstrate commitment, clarity
United Nations Convention on the Rights of and transparency in setting clearly
People with Disabilities (UNCRPD) to understood and shared equality
monitor progress. outcomes for people and communities
at risk of harm.

25 Some of these can be found in two recent Commission Briefing Papers. One, by Nocon
et al. (2011) analyses disabled people’s experiences of, and concerns about, crime.
This can be downloaded from: http://www.equalityhumanrights.com/uploaded_files/
disabilityfi/briefing_paper_3_new.pdf
The other, by Botcherby et al. (2011), provides a comparison of the experiences and
concerns about crime for several equality strands. This paper can be downloaded from:
http://www.equalityhumanrights.com/uploaded_files/research/bp4.pdf
26 See http://www.homeoffice.gov.uk/publications/science-research-statistics/research-
statistics/crime-research/hosb0612/hosb0612?view=Binary
34



The Commission’s publications are available to download on our website:
www.equalityhumanrights.com. If you are an organisation and would like to discuss
the option of accessing a publication in an alternative format or language please contact
engagementdesk@equalityhumanrights.com. If you are an individual please contact the
Equality Advisory and Support Service (EASS) using the contact methods below.

Equality Advisory and Support Service (EASS)
The Equality Advisory Support Service has replaced the Equality and Human Rights
Commission Helpline. It gives free advice, information and guidance to individuals on
equality, discrimination and human rights issues.

Telephone: 0800 444 205
Textphone: 0800 444 206

Opening hours:
09:00 to 20:00 Monday to Friday
10:00 to 14:00 Saturday

Website: www.equalityadvisoryservice.com
Post: FREEPOST Equality Advisory Support Service FPN4431

 Equality and Human Rights Commission
October 2012
ISBN 978 1 84206 466 5

Artwork by Epigram
www.epigram.co.uk
35

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