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Is Your Recruitment Process Safe for Disabled Candidates?

A self-audit for HR directors and hiring managers: 15 questions covering AI screening, prohibited health enquiries under s.60 EA 2010, reasonable adjustments, and decision documentation. Around 20 minutes. Work through them honestly.

Most disability discrimination claims in recruitment do not arise from deliberate intent. They arise from processes designed without disabled candidates in mind: application forms that ask the wrong questions, screening tools that were never audited, interviewers who were never trained, and decisions that were never documented.

This self-audit is designed for a director or HR manager who wants an honest read on where their process stands, before a complaint, a claim, or a court ruling makes that assessment for them. Where your answers fall short of the legal standard, you will find plain guidance on what the gap is and why it matters.

Section 1: AI Screening Tools

1.If you use AI or automated screening tools (CV parsing, video analytics, gamified assessments), have they been audited for disability-related bias?

2.Do you actively invite candidates to request reasonable adjustments at every stage of the recruitment process?

Section 2: Pre-Offer Health Enquiries (s.60 EA 2010)

3.Does your application form contain any questions about health, disability, or sickness absence history?

4.In interviews, do your interviewers ask about health, disability, or physical or mental capacity to carry out the role before a conditional offer is made?

5.If you use occupational health assessments, are they conducted after a conditional offer is made?

Section 3: Adjustments for the Recruitment Process

6.When a candidate requests an adjustment for the interview itself (extra time, accessible venue, BSL interpreter, written questions in advance), is there a clear internal process for reviewing and implementing it?

7.Do you offer alternative formats for any tests or assessments used in your selection process?

Section 4: Interview Practice

8.Have the people who conduct interviews in your organisation received specific training on disability, prohibited questions under s.60, and reasonable adjustments in the last 12 months?

9.Are your interviews structured around defined competencies, skills, and demonstrable experience rather than personal background, circumstances, or character?

10.Do your interview guides explicitly exclude questions about career gaps, caring responsibilities, or other personal circumstances unrelated to the requirements of the role?

Section 5: Hiring Decisions and Documentation

11.Are all hiring decisions recorded with clear, written justification against your defined selection criteria?

12.When a disabled candidate is unsuccessful, is the rejection documented in a way that demonstrates the decision was based purely on the selection criteria?

Section 6: Post-Offer and Onboarding

13.Do you proactively discuss reasonable workplace adjustments with a successful disabled candidate before their start date?

14.After making a conditional offer, is any health or disability information gathered kept separately from the recruitment file and accessible only to those who need it?

15.Have you reviewed your end-to-end recruitment process in the last 12 months with specific reference to its impact on disabled applicants?

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This checklist is provided for information only and does not constitute legal advice. For organisation-specific advice, contact us.

CF

Chris Fry

Director, Strategic Access Advisory Limited

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