Accessibility and Inclusion Policy

1. Purpose

1.1 UTS aims to provide inclusive experiences and an equitable learning and working environment. The Accessibility and Inclusion Policy (the policy) outlines how UTS provides access for students and staff living with a disability. This policy is in addition to the requirements of the Student Rules.

2. Scope

2.1 This policy applies to:

all staff, students and affiliates (collectively the UTS community) (references to staff should be read to include both staff and affiliates)
the provision of services and reasonable adjustments for staff and students with temporary or permanent disabilities and/or access requirements.

2.2 The following are out of scope of this policy:

the cost of personal aids required by staff or students for private purposes
adjustments required as part of rehabilitation from a work-related injury (refer Health Safety and Wellbeing: Injury management and return to work (SharePoint) for guidance on a return to work program)
the cost of medical treatment for a temporary or permanent condition or disability
provisions for staff and students who are carers (refer Staff and Students with Carer Responsibilities Policy)
return to work support following a period of parental or adoption leave (refer Returning to work (Staff Connect)).

3. Principles

3.1 UTS is committed to building a culture where the principles of equity, diversity and inclusion are integrated into everyday activities, processes and practices as outlined in the Equity, Inclusion and Respect Policy.

3.2 At UTS, difference is embraced and is recognised as an asset, something that improves the learning and working experience for everyone. Staff and student leaders embody this in line with the Code of Conduct and the Student Rights and Responsibilities Policy.

3.3 UTS recognises that accessibility support and awareness is a continuously evolving process. Continuously working towards equality of access and experience contributes to a safe, productive, ethical and equitable learning and working environment.

3.4 UTS will seek to ensure that accessibility is an ongoing priority, recognising that improving access for one helps to improve access for all. UTS will take steps to identify and respond to accessibility needs, address access barriers in a timely way and, where possible, work collaboratively in addressing emerging needs (refer also Whole of university approach).

3.5 Every development, improvement, purchase, project, upgrade or provision at UTS will likely have an accessibility component that requires an understanding of accessibility across our management and processes. Accessibility and inclusion requirements will be considered at the planning stage of all physical and digital spaces and reviewed across the lifetime of use.

3.6 Planning, design and review will rely on consultation and user testing to ensure quality. UTS will build awareness and capabilities in its workforce to meet these requirements.

3.7 It is acknowledged that faculty frontline staff can be the first to become aware of individual access barriers and, in collaboration with relevant stakeholders (including students, the Accessibility Service, the Inclusive Practices team, Learning Design and Technology Unit, the Centre for Social Justice and Inclusion, UTS International and the People Unit), are at the forefront of implementing access requirements for students. Faculty frontline staff will be supported in identifying students with accessibility needs, implementing the provisions of this policy and implementing teaching and learning inclusive practices.

4. Policy statements

Diversity and access requirements

4.1 This policy supports and implements processes for making reasonable adjustments in accordance with the Disability Discrimination Act 1992 (Cwlth) (the Act), the Disability Standards for Education 2005 and the Higher Education Standards Framework (Threshold Standards) 2021. The Act requires that reasonable adjustments are made to avoid direct or indirect discrimination and allow students to access and participate in education on the same basis as their peers.

4.2 UTS actively fosters an inclusive culture and environment for people with diverse abilities. Through this policy and the Access and Inclusion Plan (available at Disability access and inclusion), UTS will comply with legislation and standards and commit to:

working to provide accessible learning and employment experiences on the same basis as peers, where possible
consulting with people with lived experience, recognising their expertise
developing access solutions to ensure independence and dignity for the user, and
ensuring that appropriate training and awareness is available for staff.

Support for students with disabilities

4.3 UTS will work to ensure that students with a disability, an illness or an accessibility need or requirement can participate in education on the same basis as other students.

4.4 Diversity and access requirements, and associated reasonable adjustments, are incorporated into UTS teaching and learning processes as outlined in the Student Accessibility Procedure.

4.5 Reasonable adjustments will be provided to students in line with the Student Accessibility Procedure. In acknowledging the diversity of UTS students, where appropriate, guidance from other units (for example, Jumbunna, UTS International and the Centre for Social Justice and Inclusion (CSJI)) may be sought to bridge any language, cultural or social barriers that could impact the identification or provision of reasonable adjustments.

4.6 To gain access to adjustments, or to have an individual access plan developed, students and prospective students:

must register with the Accessibility Service (at Register with the Accessibility Service) to enable UTS to gain a full understanding of specific access requirements via an individual consultation
are encouraged to seek support, advice and any reasonable adjustments (including any assistive technology or physical adjustments) from the Accessibility Service and/or their faculty in a timely way, with consideration for extenuating circumstances, and
are encouraged to seek advice and assistance regarding accessibility provisions and any inherent requirements throughout the application process (refer Prospective students).

4.7 The Director, Student Services and faculty academic liaison officers (ALOs) will work to share knowledge and insights to improve leading practice and provide anonymised data and analytics to Council, Academic Board and the University Leadership Team as appropriate (refer Whole of university approach).

Support for staff with disabilities

4.8 UTS will provide reasonable adjustments to support staff with a disability, an illness or an accessibility need or requirement. Workplace adjustments are available throughout all stages of employment at UTS as outlined in the Workplace Adjustment Procedure.

4.9 Support and guidance, including guidance in making a request, is available for staff from CSJI, the People Unit or from a union representative.

4.10 During the recruitment process, the hiring manager is responsible for managing requests for workplace adjustments. The hiring manager will liaise with the applicant, the People Unit and/or CSJI as appropriate to ensure appropriate adjustments are provided (refer the Recruitment and Appointment Policy and the Workplace Adjustment Procedure).

4.11 A medical assessment (paid for by UTS) and/or documentary evidence may be required to fully assess an application for reasonable adjustments and ensure any insurance and duty of care obligations are met safely and appropriately (refer Workplace Adjustment Procedure). This will only be requested by the supervisor where required to meet a complex accessibility need.

Whole of university approach

4.12 Through the Access and Inclusion Plan, training is available to ensure staff and students understand their responsibilities for peers and colleagues with a disability.

4.13 The Pro Vice-Chancellor (Social Justice and Inclusion) and the Director, Equity, Diversity and Inclusion will coordinate collaboration across UTS to progress inclusive practices and initiatives that address risk, achieve quality and sustainable outcomes for people with a disability, and report on progress in relation to access, retention and success.

4.14 Where required for their role, or relevant to the function and responsibilities of the work unit, staff may need to undertake specific access and inclusion training. Access and inclusion awareness training will be included as part of the induction process.

4.15 The Accessible Environments Access Group (AEAG) and the Vice-Chancellor’s Social Justice and Inclusion Committee (VCSJIC) will work collaboratively and in line with their terms of reference to support the implementation of the Access and Inclusion Plan and this policy.

Resourcing for access

4.16 Access and inclusion requirements must be considered by divisions, faculties and units as part of the corporate planning and budgeting process.

4.17 Resourcing for major accessibility initiatives is prioritised in line with the Access and Inclusion Plan, in consultation with the AEAG and endorsed through the VCSJIC as part of annual budget cycles. Once implemented, ongoing costs of these initiatives are absorbed into relevant business as usual budgets to ensure sustainable continuation.

4.18 Disability research funding support may also be available for research projects. This funding provides support for disability research, with a particular focus on the engagement or inclusion of people with disability to participate in:

the design of research for grant applications
current disability research teams or as research participants, or
research translation and dissemination either as presenter or the intended audience of the material.

4.19 Where unforeseen access costs arise (for example, specialised equipment, software or other resourcing of adjustments) that cannot be met by the faculty or unit budget, a request can be made to the Director, Equity, Diversity and Inclusion and/or the Director, Student Services outlining the resource amount (normally between A$2000 and A$5000), requirement and risk. If endorsed, the request will be submitted to the Provost for funding approval. Any future funding requirements should be addressed through the next budget cycle in the relevant faculty or unit.

Accessible campus and facilities

4.20 UTS will work to include accessibility into the design and upgrade of its facilities. Facilities will be maintained to ensure they are fit for purpose and to enable independence and dignity. This includes:

the design, construction, remediation and maintenance of physical campus facilities
access (entrances and exits) and circulation, continuous accessible pathways and satisfactory links with transport
amenities, such as toilets, furniture and equipment, and
communications, including hearing augmentation, acoustics, lighting and signage.

4.21 Accessibility consultation is undertaken from the design and planning stage and, where possible, throughout the project, with feedback from staff and students with accessibility requirements. Feedback is used to identify gaps and source solutions, before implementation, so that accessibility features can be designed into the physical structure of the campus (for example, access ramps, accessible parking, accessible toilets (identified on the UTS campus map) and hearing supports (refer Hearing assistance facilities)).

4.22 Public and restricted spaces on campus must be kept clear in line with the Campus Policy.

4.23 Accredited assistance animals are recognised as a necessary aid to allow equitable community engagement. Accredited assistance animals are permitted into all campus areas, including teaching and learning facilities, in line with the Disability Discrimination Act 1992 (Cwlth). The only exceptions to this may be:

spaces in which a person’s disability is addressed via other means, or
areas with strict and stated sterility requirements (for example, specific sterile or high-risk laboratories, surgically sterilised areas, industrial food preparation areas or quarantined areas).

4.24 UTS reserves the right to request documentation to prove an animal is accredited or otherwise trained to assist people with a disability.

4.25 UTS accessible parking permits are available to eligible students, staff and visitors in line with the Campus Policy. Accessible parking spaces must be reserved for users with UTS accessible parking permits. Parking in a space without an accessible parking permit will be treated as a breach of this policy and the Campus Policy.

Digital accessibility

4.26 The Information Technology Unit (ITU) will ensure the accessibility of the UTS website and platforms in line with the Publishing on the UTS Website Policy. Input should be sought from the Accessibility Service and the CSJI in relation to the accessibility and inclusivity requirements of UTS web content.

4.27 In line with the Access and Inclusion Plan UTS will aim, where possible, to ensure that:

UTS web content complies with the recommendations of the World Wide Web Consortium's (W3C) Web Content Accessibility Guidelines (WCAG), the accepted worldwide standard (refer Publishing on the UTS Website Policy)
newly acquired digital platforms represent leading practice and existing platforms undertake regular review to comply with the WCAG
universal access is an identified priority in acquiring, developing or procuring new systems and platforms, with solutions that enable independence and dignity
inclusive design is implemented across the digital environment to assist user experience
accessibility checks are undertaken from the design and planning stage and user testing is implemented to identify gaps and solutions.

4.28 UTS has an accessibility statement as part of its web standards (refer Publishing on the UTS Website Policy). The accessibility statement must:

be approved by the Chief Operating Officer (COO) with advice from the Pro Vice-Chancellor (Social Justice and Inclusion) and the General Counsel and Executive Director, Risk and Compliance, and
include an option for staff, students and the community to provide feedback to UTS and a process for access issues to be addressed in a timely way.

Accessibility of events and activities

4.29 UTS will ensure that university events and activities are accessible to people with disabilities. This will be achieved through:

inclusive design and planning
the use of accessible checklists (refer Centre for Inclusive Design: Checklist for inclusive events and meetings or Australian Human Rights Commission: Accessible events)
the inclusion of access requirements in the event registration process
a budget for access requirements
the promotion of the event's or activity’s accessible features, and
the use of consistent inclusive practices such as the use of a microphone for all speakers, repeating questions before responding, testing hearing augmentation (and turning it on) and captions for online events.

4.30 Any person, including visitors to campus, with access requirements should be requested to contact the event planner as soon as possible, ideally 2 weeks before the event, to ensure access requirements can be implemented.

Privacy and records management

4.31 Normally, staff (and future staff) and students are not obliged to disclose a disability, noting that:

in most situations some level of disclosure is necessary to enable UTS to make the appropriate reasonable adjustments
UTS must be notified where the disability or health condition is likely to impact a person's capacity to meet inherent requirements of the role or course, particularly where this could put another person at risk.

4.32 All information provided to UTS about a person's disability or access needs is classified as health information under the Health Records and Information Privacy Act 2002 (NSW) (HRIPA) and is a subset of personal information. All health and personal information must be:

classified as confidential in line with the Records Management Policy, and
managed, collected and accessed in line with the Privacy Policy.

Policy compliance, breaches and complaints

4.33 Where the requirements of this policy are unable to be met, staff responsible for the adjustment or compliance requirement must provide a report to the relevant policy contact for guidance and advice (refer Roles and responsibilities). Final recommendations may be proposed by the policy contact or, where necessary, escalated to the relevant policy owner(s) for decision.

4.34 Reports must:

outline the issue, including a rationale for why the requirement cannot be met (with supporting documentation)
provide possible alternative solutions (temporary or permanent), and
be transparent, well documented and accessible for review as part of future improvements.

4.35 Students who wish to make a complaint in relation to this policy should refer to the Student Complaints Policy. Staff who wish to make a complaint should refer to the Staff Complaints Policy. Systemic issues or significant risks identified as part of the complaints process will be raised with the relevant faculty or unit and/or policy contacts for resolution.

4.36 Non-compliance with this policy will be managed on a case-by-case basis by the relevant supervisor. Appropriate training may be provided to improve awareness and understanding.

4.37 In some cases, breaches of this policy may require management under the applicable Enterprise agreements, the Code of Conduct or section 16, Student Rules, as appropriate.

4.38 Suspected and actual data breaches must be responded to immediately and managed in line with the Data Breach Policy.

5. Roles and responsibilities

5.1 Policy owner: The Provost, the Chief Operating Officer (COO) and the Deputy Vice-Chancellor (Education and Students) are responsible for policy enforcement and compliance, ensuring that its principles and statements are observed. The COO and the Deputy Vice-Chancellor (Education and Students) will work with other members of the University Leadership Team to ensure accessibility and inclusion principles are understood and applied across the university.

5.2 Policy contact: The Director, Equity, Diversity and Inclusion, the Executive Director, People and Culture and the Director, Student Services are responsible for the day-to-day implementation of this policy and act as primary points of contact for advice on fulfilling its provisions.

The Executive Director, People and Culture together with the Director, Equity, Diversity and Inclusion are responsible for approving the Workplace Adjustment Procedure.

The Director, Student Services together with the Director, Equity, Diversity and Inclusion are responsible for approving the Student Accessibility Procedure.

The Director, Equity, Diversity and Inclusion approves exemptions to this policy in consultation with relevant stakeholders.

5.3 Implementation and governance roles:

The Accessibility Service is the central contact point for all students living with disability, medical or mental health conditions. The Accessibility Service also provides guidance for staff in supporting students with additional requirements.

Faculty academic liaison officers (ALOs) are academic staff who work in faculties to assist students with disabilities, ongoing health conditions, carer responsibilities or who are pregnant.

The Centre for Social Justice and Inclusion (CSJI) maintain strategic oversight of inclusion at UTS and work to support a safe and equitable environment for all members of the UTS community. CSJI work collaboratively with the People Unit, the Property Unit, the Inclusive Practices team, Learning Design and Technology Unit, faculties and others in progressing access and diversity needs at UTS. CSJI coordinates the Access and Inclusion Plan (available at Disability access and inclusion).

The Chief Information Officer is responsible for digital accessibility in line with this policy and the Publishing on the UTS Website Policy.

The Inclusive Practices team, Learning Design and Technology Unit is responsible for working with faculties, providing learning and teaching support, and advice and resources (particularly with regard to blended learning and technologies for learning) to enhance the learner experience. The Inclusive Practices team also provides resources and leading practice for accessible content and design (refer Student Accessibility Procedure).

6. Definitions

The following definitions apply for this policy and all associated procedures. These are in addition to the definitions outlined in Schedule 1, Student Rules. Definitions in the singular also include the plural meaning of the word.

Affiliate is defined in the Code of Conduct.

Assessment requirement is defined in the Coursework Assessment Policy.

Assistance animal means trained and accredited dogs or other animals as defined in the Disability Discrimination Act 1992 (Cwlth). Assistance dogs help people with a disability and meet the state standards for public access rights.

Disability is defined in the Disability Discrimination Act 1992 (Cwlth). The definition includes physical, neurological, behavioural, psychiatric, learning, intellectual and sensory disabilities and any symptom or manifestation of the disability. A disability may be either temporary or permanent, visible or invisible and, for the purposes of the provision of support at UTS, includes neurodiversity.

Discrimination, including direct and indirect forms of discrimination, is defined in the Equity, Inclusion and Respect Policy.

Health information is defined in the Privacy Policy.

Inherent requirement means, for students, essential requirements for the course as defined in Schedule 1, Student Rules. For staff, inherent requirement means the core activities, tasks or skills that are essential to specific roles and positions, and to a workplace in general. All students and staff must meet the inherent requirements of their course, role and/or the relevant aligned profession.

Personal information is defined in the Privacy Policy.

Reasonable adjustment (also adjustment and workplace adjustment) means changes that take account of a person’s disability, access requirements, illness or condition (permanent or temporary) to provide greater equality, without causing unjustifiable hardship to UTS. Adjustments are determined on a case-by-case basis to meet the inherent requirements of the role or course. Adjustments are designed to help those living with a disability or access requirement to obtain the same benefits and/or undertake the same requirements of their employment and education as others. Medical treatment or personal aids for private purposes are not considered adjustments for the purposes of this policy.

Staff is defined in the Code of Conduct.

Supervisor is defined in the Code of Conduct.

Temporary disability means a condition that exists for a limited period of time and is not lasting or permanent. In some cases, temporary disability may also be treated as a past disability if adverse treatment was to continue after the disability.

UTS accessible parking permit is defined in the Campus Policy.

Unconscious bias means a type of social stereotype resulting from cultural and social assumptions about certain groups of people formed without conscious awareness. Unconscious bias is often based on erroneous, inaccurate or incomplete information and can have potentially prejudicial expectations about ability and/or capability.

Unjustifiable hardship means a situation where an adjustment would cause undue cost, disruption or difficulty to UTS, or other students or staff, which are out of proportion to the proposed benefits. In determining what constitutes unjustifiable hardship, all relevant circumstances of the particular case must be taken into account before any decision is made.

Approval information

Policy contacts	Director, Equity, Diversity and Inclusion Director, Student Services Executive Director, People and Culture
Approval authority	Vice-Chancellor
Review date	2024 (with Access and Inclusion Plan)
File number	UR22/2244
Superseded documents	None

Version history

Version	Approved by	Approval date	Effective date	Sections modified
1.0	Vice-Chancellor	09/12/2022	15/12/2022	New policy.
1.1	Deputy Director, Corporate Governance (Delegation 3.14.2)	14/12/2023	21/12/2023	Minor changes to reflect accessible parking requirements incorporated in the Campus Policy.
1.2	Deputy Director, Corporate Governance (Delegation 3.14.2)	30/07/2024	01/08/2024	Amendments to reflect new Education Portfolio.