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GOOD PRACTICE GUIDANCE CONSULTATION WITH EQUALITIES GROUPS

PART 3: CARRYING OUT CONSULTATION

This section sets out some of the practical issues that are important in making consultation inclusive. The following issues are covered:

• the importance of staff attitudes and skills
• the timing of consultation
• the way in which information is provided
• accessibility of venues
• the importance of providing feedback

STAFF ATTITUDES AND SKILLS

Every consultation will involve a number of staff to different degrees depending on the methods chosen in different roles. The attitudes of staff can have a significant impact on the accessibility of the process (written or face to face). Most organisations now provide equality awareness training to staff at a variety of levels and although all staff should understand and promote equality, this is not always the case. Some staff involved in the process may have neither experience nor understanding of equalities issues.

You should ensure that any staff likely to be directly or indirectly involved in consultation have been trained. Equality training and staff awareness also need to be refreshed regularly, as the issues and acceptable standards change over time. One council gave an example of using staff newspaper articles to draw attention to ways of enabling equalities groups to participate in consultations and wider council issues.

Staff attitudes to groups and individuals can create barriers or can enable participation. There are many issues which staff need to be aware of when communicating with groups, and the most important are:

• to avoid making inappropriate assumptions
• to avoid any discrimination in their language or behaviour
• to avoid any approach which can be seen to be patronising

Staff should be familiar with the good practice and etiquette examples provided throughout this section. Staff training in equalities issues, and the use of this guidance, can help, but the best people to provide advice are the people who are affected by the issues - they are the experts.

Staff may also find that they are "gatekeepers" to consultation processes. This will often be the case in large centralised organisations and in local office networks (which may be the first point of approach). The staff who deal with routine public enquiries should always be aware of any consultation that is taking place. They should be made aware of how, and where, to seek help and should be asked to refer queries to the appropriate contact.

PROVIDING ENOUGH TIME TO RESPOND

The Scottish Executive grassroots consultation events identified that it is time-consuming to respond to a consultation document and there is often not enough time allowed to consider materials properly. This can be an issue for any organisation, but may be particularly important for equalities groups. There are a range of reasons for this, including:

• the need to obtain translated materials
• the need to convene special meetings of wider community members
• the need to avoid specific religious holidays

The best way to make sure that equalities groups will be able to respond is to consult with them about how much time they will need before you set a deadline. They will therefore be aware of your timetable restraints too.

PROVIDING ACCESSIBLE INFORMATION

The ways in which you provide information can have a major impact on whether equalities groups can take part in consultation. Information should always be provided in a way that is easily understood and allows the widest access to it.

There are a number of common problems with information, which were summarised in a report prepared by Reid Howie Associates after the grassroots consultation events ( Equality Unit, Scottish Executive 2001):

"The format of the materials for consultation was identified as a major barrier. The material was seen often to be English-based, written in a dry manner and particularly difficult for some groups to respond to. It was suggested that documents can be off-putting and are regularly too dull and bureaucratic.

There is often a lack of translated information (as well as insufficient interpreters, a lack of understanding of how to use these effectively and a lack of funding for this). Groups stressed, however, that people cannot participate meaningfully if they do not know the language or have access to the appropriate equipment, technology or support.

The lack of imagination in the process was also mentioned, with information often not provided in places seen to be appropriate to the groups. A perceived lack of willingness to consider alternative means of information provision was also mentioned."

The need for plain language

Information should be in plain language, which is jargon-free and straightforward, easy to read and understand. The Plain English Campaign can provide advice about this.

You should not refer to structures or systems which respondents may not be familiar with. The same applies to terms that people will not understand unless they are involved with an organisation.

The need to write clearly applies to all of the written materials that you may use.
This includes not only paper documents, but also PowerPoint presentations and any materials or resources used in meetings. Feedback from meetings (including minutes and action notes) should also be clear.

If you ask written questions, you should make clear exactly what information you are looking for. You should break long documents down into separate, manageable sections, and provide background information where this is needed.

Appropriate language

It is important that the way your materials are written (and the language used by staff) reflect a clear commitment to equality. They should never imply that discrimination or exclusion are acceptable or inevitable. This applies to all parts of the material - the text of documents, the images on covers and the examples used. Graphics and designs of materials should never stereotype or caricature groups. Staff involved in consultations (however peripherally) should be aware that using discriminatory language can make it seem that their participation is less valued. Examples of this include referring to women as "girls" or to disabled people as "the disabled" and can exclude or disempower them.

Practical steps to accessible information

You should provide all of your material in a range of formats. For written materials, a minimum of 12-point type should be used (14 where possible). Addressing the following points will make documents easier for all respondents to access:

• using clear fonts (sans serif is recommended by the Plain English Campaign)
• using medium or bold type
• avoiding the use of italicised fonts
• even type spacing
• avoiding hyphenation
• using appropriate colours to allow contrast

Further considerations include:

• text with poor vertical spacing can be difficult to read, so the space between the lines is as important as the size of the typeface
• paper should be matt, not glossy as unwanted reflections from glossy paper can make even clearly printed text difficult to read
• you should print only on one side of the paper or on paper which is heavy enough to prevent the print bleeding through
• colour and background styles should be used carefully, for example, highlighting text in a colour or using highly stylised backgrounds may make it very hard to read the text

Using clear language is also important if information is to be translated. You should avoid idioms, slang and colloquialisms. You should also avoid using any terms or references that may be offensive to particular cultures or religions. Where you are in any doubt about the languages to use, or other issues relating to translation, it is best to seek specialist advice.

People with learning disabilities may require information in easy-read. Pictures, symbols and graphics can make information more accessible and can make material clearer for anyone who finds formal written consultation problematic.

People with visual impairments may require copies of written documents in Braille or Moon, in large print (at least 16 point) or on audiotape or floppy disk. Some respondents may prefer to receive documents by e-mail.

If you are sending information on disk, the entire document should use one common typeface, such as "Arial", which most people will have. You should completely avoid using symbols from other fonts (even popular fonts such as Wingdings). The respondent may not have these on their computer and it may cause confusion. Disk copies should not contain other layout devices (such as boxes) as these do not necessarily appear on screen or print in the same way on all computers. Where layout is critical, Adobe Acrobat is a good choice, but bear in mind that you may have to let users know how to access this programme. It is freely available from www.adobe.com.

Although Microsoft Word is by far the most popular word processing software in the public sector in Scotland, smaller groups may not use this programme. Many groups use Apple Macintosh, rather than Microsoft Windows-based operating systems. You should always offer alternative versions of material, such as rich text format, or raw (plain) text where you are using disk (or internet) delivery.

Any written documents should let recipients know (in appropriate formats) how to get the material in other formats and what can be supplied. For example, in publications which are produced in English, a number of local authorities now include the title in a range of community languages. There is often a standard panel describing how a copy in another language can be obtained. If you do this, you should make sure that any phone number given can be answered in an appropriate language, and that the document which you have offered is readily available, or ready for translation. Any video materials used should have subtitles and sign language.

This is not an exhaustive list and you should seek advice from specialist organisations. For example, the RNIB can advise on translation to Braille and how to prepare taped information. Local community interpreting services can provide advice on the main community languages in different parts of Scotland. ENABLE can provide advice on easy-read.

Minority ethnic community languages

People from minority ethnic groups may require information translated into languages other than English. There are six languages in Scotland, in addition to English and Gaelic, which are frequently used:

• Arabic
• Bengali
• Chinese
• Hindi
• Punjabi
• Urdu

Other languages will sometimes be required (for example, British Sign Language, or where refugees or asylum seekers may be involved).

Preparation

Preparation of materials in other formats may take a number of weeks, and this needs to be built in to the consultation timetable. Translation and proof reading, for example, take at least six weeks (and may take longer).

You do not always need to have every format available at the start of every consultation. You do need to be ready, however, in every case, to respond quickly to requests for another format. You can then get the material prepared and delivered in enough time for the consultees to respond, or anticipate extending the response deadline.

The main consideration is to make sure that the information is appropriate, relevant and accessible to all groups (including different age groups). This will require a range of complementary approaches.

ORGANISING INCLUSIVE EVENTS

Where meetings and events are held, there are a range of access issues. For larger events, it may be worthwhile having a planning group which includes representatives of all organisations and/or departments involved, along with representatives of equalities groups to consider how appropriate the facilities are.

You should always provide information about the venue and other arrangements, and ask people who want to participate to let you know in advance what their individual requirements are. One means of doing this is to include a space on registration forms inviting people to specify their requirements.

Preparation for staff, speakers and facilitators

An event is more likely to be successful when all of the staff who will participate are well prepared. Every member of staff involved should have had appropriate equality awareness training, and should understand the principles set out in this booklet. They should be aware of how best to provide support, and when it is not appropriate to do so. They should also know how and where to get information or help which they cannot provide.

If staff are facilitating a discussion or other group activity, it is important that they:

• ensure that participants are comfortable
• allow all participants to have a say
• ensure that the activities and timing are appropriate
• explain where the activity fits in the overall consultation process

They also need to be prepared to listen to groups (whether or not they agree with the issues raised) and to seek clarification of any issues that they do not understand.

It is also important to check that invited "experts" (for example speakers) are comfortable with the fact that their contribution may be challenged by participants who have a great deal of personal or practical expertise and experience of the issues.

Physical access

The location of any consultation meeting or event should be accessible to people with a range of impairments. Again, although it is impossible to provide an exhaustive checklist, some examples include that:

• There should be step-free access to and within the venue through the main door.
• The entrance should be wide enough for a wheelchair user (both manual and electric) and should not have heavy doors.
• Ramps should not be steep.
• There should be sufficient parking at the venue and this should be close to the entrance.
• Consideration needs to be given to the surfaces, contrast and obstacles for people with visual impairments.
• Good lighting is important for visually impaired people and for interpreters and lip speakers.
• The height of reception desks, lift buttons, telephones, etc. should be suitable for use by wheelchair users.
• The toilets and lifts should be appropriate for disabled people, and alarms should be provided.
• There should be verbal and Braille indications in the lifts.
• There should be appropriate and sufficient signage and staff should be prepared to provide assistance, if requested.
• The distance between rooms/areas should be short, as distance may be difficult for people with mobility impairments.
• Different types of chair (e.g. with and without arms) should be provided.
• There should be suitable fire alarms for hearing impaired people (or staff available to assist).
• There should be enough stewards to provide information and meet other requests. There will be a particular need at key times, such as the start and end of the event, when groups sub-divide for discussion, over lunch and other breaks.

Undertaking an access audit

One way of checking physical access is by undertaking an access audit before an event. Some disability organisations, such as Centres for Independent Living, or local Access Panels, can advise on this. An access audit is undertaken by a trained and experienced specialist, and generally covers a range of issues at the venue, including, for example:

• physical access
• seating
• signage
• lighting
• amplification
• sight lines
• means of emergency escape

You should avoid buildings that cannot be used by disabled people. If a building has access, but there are some remaining issues, you should let participants know. If you have an access audit carried out for a venue, it is good practice and common sense to provide the results to the venue owner/operator. They can then address any issues, and make it available to other groups using the venue.

Where an access audit has been carried out a long time ago, it is best to re-do it. It is potentially very damaging to assume that nothing will have changed, and it may now be inaccurate. It is always worth checking whether any changes (positive or negative) have been made.

Location and transport

It is also important to consider the geographical location of groups and not to exclude them because of this. If a consultation is Scotland-wide, or region-wide, it is important to use venues in all parts of the area, not only central ones. You should also consider providing transport to events (or reimbursing costs). Both can be a barrier to people on low incomes. There may also be financial barriers for people who have to give up a day at work to participate. Wherever possible, reimburse out-of-pocket expenses on the day of the event.

Some issues particularly affect island areas. In some cases, limited transport means that attendees may not be able to travel to and from an event in one (or even two) days. You will need to consider meeting these additional subsistence costs. For disabled people living in island communities, both air and ferry travel can be at least difficult and often impossible. You may need to hold specific events in island areas or consider other ways of getting their views ( see example).

The physical safety of locations, and the availability of safe transport and parking are also important. You should always provide information on public transport and safety, along with a map of the area.

The timing of events

The timing of events is also important. You should make sure that the day chosen does not coincide with a major event for a particular community (e.g. a religious event or festival).

People who have childcare or other caring responsibilities can be excluded from breakfast or evening meetings. For adults with school-age children, day events should end at a time which allows them to collect their children. Children of school age and people who are working will often not be able to attend daytime events. Participants who are concerned about their personal safety at location or getting to and from the venue, may not be willing to attend evening events. Bear in mind that darkness falls before 5pm during much of December and January, and even earlier in the northern isles.

Choosing a venue suitable to the audience

The venue needs to be a place where people will be comfortable and confident expressing their views. It needs to be safe, accessible, appropriate and familiar to participants. Groups with little experience of formal meetings and consultation may be uncomfortable with "business" meeting methods, or venues such as conference centres. A suitable room should be made available for prayer, if required.

Caring responsibilities

It is important to provide crèche facilities or other forms of childcare support, particularly at events involving women. A number of organisations can provide crèches at events. You should only use registered childcare providers (who can be contacted via local authority social work services) who will also take into account all relevant Child Protection considerations. Crèche provision should be accessible to disabled children and should use materials that reflect a focus on equality. The crèche should also take account of the needs of children from minority ethnic communities (including their language requirements).

Before the event, you should provide information about the crèche to parents so that you can make any changes needed or answer questions that they have. If you intend to separate children by age groups, you should make this clear to parents before they register.

Some parents may prefer not to use a crèche but to make their own childcare arrangements. You should provide the option to do this and to have the costs reimbursed. If your organisation (particularly a local authority) has a policy on this (for example, a maximum cost, or a need for parents to use a registered childminder), make it clear at the start. If the policy is likely to mean that some people cannot take part, you should consider, on a case by case basis, how that can be addressed.

Some participants may have other care responsibilities. You should consider how to provide support with any additional costs (or practical issues) which participants face because of the consultation process.

Communication

You should always consider the best means of communication, both in presentations at events and in discussion groups.

Some people from minority ethnic groups may require an interpreter. These are generally available through local community interpreting services. People with hearing impairments may require a British Sign Language interpreter or a lip speaker. Some participants may need a deafblind guide. You should use only trained interpreters and always contact them in good time to explain your requirements. If you have not worked with interpreters before, you should talk about how the process will work in practice (for example, how you will identify the person who will be using their service).

You should use a microphone and provide a hearing induction loop or infrared sound amplification system. Bear in mind that you should also use a microphone not only for the speakers' contributions, but also to amplify questions asked by the audience. Test all equipment prior to the event.

Notetakers should be provided in groups, as it is very difficult to take notes while concentrating on an interpreter. Copies of the notes can be distributed with the Action Points or Minutes.

You should also bear in mind the need for good practice and etiquette in all your communication. Examples include:

• speaking directly to a participant when they are using an interpreter
• speaking at an appropriate speed
• keeping your hands away from your mouth and avoiding eating when someone is interpreting what you are saying or lip reading
• not shouting at hearing impaired people
• providing assistance only when this is desired
• not patting or feeding a guide dog
• not leaning on a person's wheelchair
• sitting to talk with a wheelchair user

Again, this is not an exhaustive list, it provides some examples of the ways in which you can improve participation.

Refreshments and arrangements for eating

Some groups and individuals may have particular requirements for food or refreshments, for example:

• some will require vegetarian food
• some foods may be forbidden to particular groups
• some people may have specific dietary requirements for health reasons

You should identify any requirements and take these into account - caterers will usually be able to accommodate requests. You should check with the caterer on the day (even where requirements have been properly specified in advance), that the food provided is the food you requested. It is worth reminding caterers that requirements for vegan or vegetarian foods apply not only to sandwiches and quiches, but also to cakes and biscuits. A high proportion of any refreshments should be meat-free. Different foods should be on separate plates and clearly labelled. Make sure that sufficient serving spoons are provided. You should provide water and juice along with tea and coffee and you should not provide alcohol.

Buffet arrangements will be inappropriate for some disabled people (e.g. wheelchair users and others with problems walking or balancing), as it will be impossible to gather food and eat without a seat and a table. Some disabled people have restricted hand movements and may require cups with handles or drinking straws and you should also provide these. People who have guide dogs will almost certainly require refreshments for the dog (e.g. water) and you should provide this. Again, you should check with participants in advance.

Women-only groups

At events involving women (particularly Muslim women) where there is discussion in mixed sex groups, you should offer the option of a women-only group. Do not assume, however, that all women will want to participate in this way.

Specific support

Some participants will bring someone with them to give them particular support or personal assistance. When assessing the number of participants (for refreshments or allocating spaces) you should count these individuals. You should also count others, such as interpreters.

Always bear in mind when you are arranging events that people will have a wide range of individual needs. While you should never make assumptions about these needs, the best way to identify them is to ask participants to specify their requirements in advance ( see above). This will allow you to make the most appropriate arrangements and help to avoid finding on the day that some people cannot take part.

INFORMATION SHARING

It is good practice, in any consultation process, to make the views that have been expressed available to everyone. You can provide for this by either:

• making the responses available at a central location
• providing copies on request

It is important, however, that if you intend to do this, you make it clear to respondents at the start. Some groups or individuals may wish (for a number of reasons) not to be identified. An obvious example is where an individual or group may face victimisation if they were identified. Other examples may include people with medical or mental health problems who do not wish this to be identified, or groups who make suggestions that they do not wish to make public. You must offer the opportunity for responses to remain confidential and respect their confidentiality totally.

Where a summary of responses is prepared, check thoroughly before publication that the report does not identify (directly or indirectly) respondents who wish to remain anonymous.

PROVIDING FEEDBACK

Groups have identified that the lack of feedback from consultation is a major source of frustration. You should feed back the outcome of the consultation to participants and the reasons, as far as possible, for including or not including their views.

The format and dissemination of feedback is just as important as for the initial consultation materials. All of those who took part should be aware of how to get information about the outcome. You should also consider whether, and how, you will involve groups in monitoring and reviewing policy changes that have been implemented as a result of the consultation.

REVIEWING THE PROCESS

After the consultation, it is a good idea to ask those consulted about the process and ways it could be improved in the future. Participants can provide invaluable information for future planning. You should carry out both an internal review of the process and, where possible, discuss it with those consulted. It is also a good idea to review who actually responded to your consultation, to see whether there are any patterns or obvious gaps. This may help to pinpoint any groups which were not reached by the methods you used.

It may also be worth looking at the effect of the methods on the outcomes. If, for example, one method provided a set of views or respondents which varied significantly from others, you should consider whether this is due to differences in the method or actual differences in the views.

CONSULTATION FATIGUE

Many groups now feel that they are being consulted on everything. Equalities groups receive many invitations to participate in consultation on a range of issues, because organisations recognise that it is important to identify their views. They will not, however, always be able to take part. A lack of time and resources may mean that groups have to prioritise and respond only to issues that are centrally relevant to them. This should not, however, stop you inviting them to participate. Groups themselves should be allowed to decide whether they wish to respond. Be flexible - even if your consultation needs a written response, an organisation which does not have the time or resources to do this may be able to provide their views succinctly in a single telephone call.

Establishing partnership working with groups on a longer-term basis is one way of overcoming these problems. That way, their views are collected regularly, rather than only through one-off consultations. Another method is centralising consultation in an organisation, where a number of questions on different issues can be asked at one time, through the same process. This can reduce the number of individual consultations without losing the breadth of the coverage.

LONGER-TERM ISSUES/CAPACITY BUILDING

One-off consultations clearly have a place and can serve a useful purpose. Many local authorities and some Scottish Executive departments are, however, recognising that time, resources and longer-term work with organisations will enable them to become more involved in the consultation process.

The Scottish Executive Equality Unit has established Scotland-wide fora around particular issues affecting groups. Examples of this include the Women in Scotland Consultative Forum and the short-life Race Equality Advisory Forum. The Executive recognised the value of having access to groups of those likely to be affected by policy proposals and decisions. Many local authorities and agencies have also identified the benefits of working with communities of interest to, for example:

• identify priorities
• provide advice
• discuss ideas
• formulate policy proposals
• monitor the impact on communities when policy is implemented

The capacity of groups needs to be built up over time to develop these arrangements. All of the participants (public bodies and groups) need to understand their roles and limitations. Bridges need to be built to reduce the cynicism which can develop from persistent exclusion or which can exist through public authorities assuming that only they have the appropriate expertise.

It may be appropriate to begin to develop networks (or representative groups) with particular sectors of interest (e.g. women, disabled people, LGBT and minority ethnic groups). The format in which material is provided, the timing, accessibility, etc. of meetings should also be considered in this work. These networks (or representative groups) can make it more likely that there will be longer-term, continuing consultation. They also have a place in one-off consultations (as specialist umbrella groups).

Capacity building work with groups can take place over a longer period but can provide a way of keeping up to date with the concerns of specific groups at all stages.

A number of other authorities have also established groups and networks specifically to assist in the consultation process. Clackmannanshire, for example, has a group that considers access to polling stations and buildings.

This type of work is most likely to be co-ordinated centrally within organisations, for example, by an Equality Unit or a central Policy Unit. Individual parts of an organisation can then contact these groups when they want to consult with them, helping to "mainstream" their involvement.

The point made throughout this document, that no single method is ever likely to provide the answer to consultation, should be stressed again. It is vital that consultation with central groups (although useful) is an addition, not an alternative to other methods involving "grassroots" individuals and groups.

In the longer term, including greater numbers of people from equalities groups in the policy process (as decision makers), will make it more likely that the issues which they face are taken into account in policy and practice.

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