Photo: Pexels
Picture an illustrative week in modern Britain.
Monday: A Deaf woman who uses British Sign Language (BSL) tells her hospital she needs an interpreter for an upcoming scan.
Tuesday: Her bank flags a suspicious transaction and asks her to ring to confirm a payment.
Wednesday: Her solicitor posts a twelve-page client care letter to sign and return.
Thursday: Her airline emails about a gate change and advises passengers to "listen out for lounge announcements."
Friday: She contacts the bank's complaints team to explain why she couldn't call, and starts her explanation from scratch.
By Friday afternoon she's explained her basic communication needs to four separate organisations, and to a fifth team inside one of them. Each was probably trying to do the right thing. Each started from a blank page.
In her podcast Unlocking Vulnerability, Helen Pettifer highlights the first step: listening to customers in vulnerable circumstances. My interest is what has to happen next. Once a person has explained the support they need, why should that information stop at the boundary of one organisation?
It's time to build a universal Access Profile: a single voluntary record, controlled by the individual, that public and private sector providers can receive and act on to make their communications accessible.
Each was probably trying to do the right thing. Each started from a blank page.
An Access Profile isn't a medical archive. Nobody should have to relive their medical history to get an accessible invoice. It sets out functional communication preferences in plain terms.
The Access Advantage: Subscribers Only
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The full article covers how a profile would work, what regulated wording really requires, the data protection architecture under UK GDPR Article 9, failures from aviation to stadium safety, and six practical steps for organisations.
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What's in the full article
Regulated wording, decoded
Four different kinds of requirement get lumped together. Knowing which you're dealing with changes what you can adapt.
The privacy architecture
How a cross-sector profile can handle special category data under UK GDPR Article 9, with control kept by the individual.
Six steps for now
A practical programme any organisation can start this month, from testing one journey to measuring whether it works.
Chris Fry
Accessibility specialist and legal professional. Postgraduate legal qualifications, CEDR mediation accreditation. Contributor to House of Lords and Commons Select Committee proceedings and Court of Appeal cases. Founder, Strategic Access Advisory Limited.
This article provides general legal and operational information and isn't legal advice on the circumstances of any particular organisation.
Sources
- Equality Act 2010, sections 20 and 29, Schedule 2 and Schedule 22 paragraph 1.
- Rowley v Minister for the Cabinet Office [2021] EWHC 2108 (Admin).
- UK GDPR Article 9 and Data Protection Act 2018, Schedule 1 Part 2. FCA Consumer Duty and Handbook, SRA Code of Conduct, NHS England Accessible Information Standard and CAA Airline Accessibility Guidance (CAP2990). Full source list in The Access Advantage edition.