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Out in the open Tackling disability- related harassment A manifesto for change

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Page 1: Out in the_open_dhi_manifesto

Out in the openTackling disability-related harassment

A manifesto forchange

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Tackling disability-related harassment – A manifesto for change

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

Contents

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Foreword

One year on from the report of our originalinquiry – Hidden in plain sight – and thecircuit of speaking events that followed, itwould be easy to imagine that disability-related harassment is finally beingunderstood and tackled.

The responses from government andauthorities discussed in this ‘Manifesto forchange’ show that many are already takingsignificant steps and more are planned, asset out in the detailed reports of what theyintend to do over the next few years, whichare posted on our website alongside thisreport. Together they show progress,individually and collectively, towardsmaking a real difference.

Yet almost every person I talk to who is notpart of the criminal justice or equality sectorstill doesn’t appear to recognise what ishappening to disabled people. If you followthe Disability Hate Crime Network – anonline community of disabled people fromacross Britain sharing their experiences –you will see daily reports of attacks againstdisabled people. Day after day, people arebeing targeted because of their disability.

It has just been reported that the number of disability hate crimes recorded by policeforces in England and Wales for the yearended December 2011 was 1,877.1 This is anincrease of 24.1 per cent on the previousyear, and is the only equality strand to haveseen an increase in the police recording ofhate crimes. This could be a good thing if it

shows that more people feel able to report it,and we need more reporting to demonstratethe true scale of this issue. But it could alsosuggest that the underlying incidence of theproblem has got worse.

I am also concerned about the apparent‘postcode lottery’ in recording patterns,with a variation of 255 cases inLeicestershire down to just four in somepolice force areas, with 12 forces2 recordingless than 10 cases during this period. It isdifficult not to conclude from these figuresthat some police forces are simply not tryinghard enough to encourage disabled peopleto report these incidents or to take themseriously when they do.

Contrast these figures with the CrimeSurvey for England and Wales; they showthe number of people experiencing adisability hate crime in the year to theSpring of 2011 was 65,000. So, just under 3 per cent of hate crimes experienced bydisabled people end up being included inthe official figures. This means that foraround 34 out of every 35 incidents ofdisability hate crime, the victim was eitherunable or unwilling to report the hatecrimes committed against them. This could be because, as the same crime survey consistently shows, victims have lowexpectations about what, if anything,reporting the crime might actually achieve,or it could be that these incidents are notrecognised as being disability-related evenwhen they do. There is a long way to go.

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

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.

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It is important to remember that hate crimeis only the tip of the iceberg. So-called hateincidents – the name-calling, bullying, andother treatment that wears people down –are what the majority of disabled peopleexperience on a much more frequent basisand can escalate to more serious crimes.It is refreshing to see that at least some parts of the media are picking up on thecontradiction between the positivereporting on disability surrounding the2012 Paralympics, and the day-to-dayreality for many disabled people, oftenlabelled as scroungers or benefit cheats or ‘not trying hard enough’.

This ‘Manifesto for change’ sets out ourrevised recommendations for action over the next five years. These have beendeveloped following consultation with alarge number of government, national andlocal bodies who have helped refine andnuance the recommendations to make surethat they work, and to ensure that thoseorganisations own them.

The issue of disability-related harassmentmight be ‘Out in the open’ but it is, mostcertainly, not yet sorted. It is incumbentupon us all to work to overcome this blighton our society.

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IntroductionResearch on the safety and security of disabled people conducted by theCommission in 2009 found that violenceand hostility is a daily experience for somedisabled people.3

These findings led the Commission to launch its largest inquiry to date. Itanalysed over 500 pieces of evidence andheld formal hearings with expert witnesses.

The terms of reference for the inquiry were to investigate the causes of disability-related harassment and the actions ofpublic authorities and public transportoperators to prevent and eliminate it.

The scope of the inquiry covered:

England, Scotland and Wales

disability-related harassment carriedout by individuals or groups of people,including strangers, neighbours,acquaintances, friends, family, relativesand partners

harassment in public places such asstreets, parks, schools, leisure facilities,on public transport and in private placessuch as in the home.

It did not cover harassment in theworkplace, which is covered by a separatelegislative framework.

In September 2011, the Commissionconcluded the formal part of the inquirywhen it published the report Hidden inplain sight.4 This report highlightedsystemic failures by organisations inpreventing disability-related harassmentand in tackling it effectively when ithappens, and gave draft recommendationsfor action.

In this follow-up to Hidden in plain sight,we summarise a wide range of formalresponses from relevant organisations and set out our final recommendations.

The responses are, overall, positive andencouraging. There are some verypromising signs of action and commitmentfrom those with the power andresponsibility to create change. There is lessprogress so far in terms of measureablepractical actions. However, we expectsignificant progress over the next few yearstowards achieving better outcomes for alldisabled people.

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 HumanRights Commission (2011). Available at: www.equalityhumanrights.com

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Following up the Commission’s inquiry Hidden in plain sight proposed seven corerecommendations and a further 79 moredetailed recommendations. TheCommission put these recommendationsout for a six-month consultation period sothat government, organisations andindividuals could comment on howeffective they felt they would be in reducingdisability-related harassment.

We wrote to relevant organisations to ask:

for formal responses to the inquiry’srecommendations

what they were planning to do differentlyas a result of the inquiry.

The approach varied across England,Scotland and Wales to fit with the legal,policy and cultural context in each country.

We received 81 formal responses and thethree national governments publishedtheir commitments. These responses, taken together, show how ourrecommendations are likely to be met incoming years. The responses are publishedon the Commission’s website:www.equalityhumanrights.com. Eachresponse is a public statement by thatorganisation of what they have already doneto make progress and their commitmentson what they will do in the future. Weencourage individuals, disabled people’sorganisations and others to use these tohold each organisation to account.

Based on the responses, and our ownreview, we have produced a final list of 43 strategic recommendations grouped under seven sections in this report.

The Commission will ensure thatconsideration of the findings, and therecommendations from the inquiry, informour own work and, where appropriate, we willmonitor the performance of organisationsthat have a specific responsibility to tackledisability-related harassment.

During the inquiry we heard evidence frompublic authorities about serious incidentswhich had happened in their area. Part 2 ofHidden in plain sight included reports on10 of those cases. Those authorities alsoprovided evidence on the steps they havetaken to improve practice in preventing anddealing with disability-related harassment.We reported on that in Appendix 17 ofHidden in plain sight. Alongside issuingthis report we have asked a number of thoseauthorities to tell us more about theprogress they are making in improvingpractice in their area and to explain howthey have taken the public sector equalityduty into account in doing so. If theevidence shows that inadequate action hasbeen taken to improve, we will considerinvoking our formal enforcement powersunder the Equality Act 2006 to makeauthorities take the issues and theirobligations seriously.

We have already committed to conduct areview in 2015 in our three-year strategicplan, and we expect organisations to havemade significant progress in implementingour recommendations. We also expect thatother inspection and regulatory bodies, anddisabled people’s organisations, willcontinue to work in their sector or local areato support relevant organisations to takeaction and to hold them to account.

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Government responsesThe UK Government and the devolvedadministrations in Scotland and Waleshave responded formally and positively to the Commission’s inquiry. Across thethree countries of Great Britain, there are different starting points in terms oflegislation and policy and consequentlydifferent areas of focus.

The UK Government

The UK Government’s formal response5 toHidden in plain sight was published on 17July 2012. It refers to a number ofsignificant new policy or legislativeapproaches that have been or will beinfluenced by the inquiry’srecommendations.

The Commission considers the UKGovernment’s response to becomprehensive and robust in relation to:

the Government’s clear commitment totackling this issue

commitments to improving datacollection on the application of section146 of the Criminal Justice Act and datasharing

safeguarding measures in health services

tackling antisocial behaviour in socialhousing

a commitment to developing reciprocalreporting arrangements in transport.

The Commission will be continuingdiscussions with government departmentson other areas including:

better understanding of the motivations of perpetrators and societal causes of disability-related harassment

the collection of comprehensive data on disability-related harassment, toimprove decision-making andaccountability

empowering local leadership and otherlocal agents of change to have access tothe right information and support to hold authorities to account and makechange happen

addressing cyber-bullying

the impact of terminology and languagein bringing about cultural change.

Scottish Government

The policy drivers in Scotland

There is a unique range of distinctive policydrivers in Scotland directly relevant to theinquiry:

The Scottish specific equality duties6

require public authorities to set equality outcomes for all protectedcharacteristics by April 2013, gather andact on evidence, involve equality groupsand assess the impact of all new policieson protected groups.

Priorities for the Scottish Governmentand, 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/

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Agreements, local agencies are set withreference to the National Outcomes andPriorities.

Reform of the scrutiny landscape,7 with ashift to a more proportionate, risk-basedand shared scrutiny process.

The response in Scotland

Following the launch of the inquiry reportin September 2011, the Commission inScotland concentrated on the sectorscentral to effective delivery of the inquiryrecommendations. These are:

central government

criminal justice authorities

leadership bodies such as the Associationof Chief Police Officers in Scotland and theAssociation of Directors of Social Work

the audit and scrutiny sector,particularly the Care Inspectorate.

The response from these sectors has beenvery encouraging, with recognition of thescale and seriousness of the challenge.Respondents have also effectively identifiedthe legal and policy levers particularto Scotland.

The Scottish Government’s Health andWell-Being Directorate, Justice Directorateand Finance and Public Reform Directorateall submitted formal and positive responsesto the Commission’s inquiry.

There has been strong action in some localareas, such as that following the case of the‘vulnerable adult’ in Lothian and Borders in

2002.8 The outcome of this case had a wide impact across public authorities inScotland. It became a catalyst for change to the legislative and policy context fortackling disability-related harassmentacross the nation.

Welsh Government

The Commission set out four areas forintervention in Wales:

A determination to eliminateharassment needs to be shown byleaders. Partnerships to prevent andrespond to harassment and shareeffective practice should be encouraged,including piloting Multi-Agency RiskAssessment Conferences (MARACs).

The new equality duties should be usedto prioritise tackling disability-relatedharassment.

A human rights-based approach tosafeguarding should be introduced bythe Welsh Government.

Increased reporting and publicauthorities to put in place measures toensure a positive reporting experienceand effective support.

As a result of our report, in December 2011the National Assembly’s Communities,Equality and Local Government Committeeheld an Inquiry into disability-relatedharassment. In its report,9 the Committeecalls on the Welsh Government to set astrategic direction in tackling disability-related harassment by driving through acollaborative action plan.

7 See http://www.scotland.gov.uk/Topics/Government/PublicServiceReform/IndependentReviewofReg/scrutinyimprovement

8 Hidden in plain sight: Inquiry into disability-related harassment, Equality and HumanRights Commission (2011), pp. 26-9. Available at: www.equalityhumanrights.com

9 Available at: http://www.senedd.assemblywales.org

www.equalityhumanrights.com

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The Commission considers the WelshGovernment’s response to becomprehensive and strong, particularlyin relation to:

work with stakeholders to take forwardan action-focused framework to tacklehate crime across the protectedcharacteristics of race, disability, religionor belief, sexual orientation and genderreassignment

adoption of an objective to reduce theincidence of all forms of violence againstwomen, domestic abuse, ‘honour’-basedviolence, hate crime (includingdisability), bullying and elder abusewithin the Wales Strategic Equality Plan10

commissioning of research Who commitshate crime? (available autumn 2012)

publication of anti-bullying guidanceRespecting others: anti-bullyingoverview.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

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Developing the manifesto for change In reviewing responses to the draftrecommendations within Hidden in plainsight, we saw that a number of sector-specific recommendations were equallyapplicable to all sectors, and removedduplicates.

We have, where relevant, moved from afocus on one sector to wider agencies andpartnerships. We have also recognised theneed to address a range of de-regulatedservice providers by changing our focusfrom ‘public authorities’ to ‘authorities’. We have also amended somerecommendations in the light of very usefulfeedback to our consultation, and groupedthem into the following seven sections:

1. Reporting, recording and recognition

2. Addressing gaps in legislation and policy

3. Ensuring adequate support andadvocacy

4. Improved practice and shared learning

5. Redress and accessing justice

6. Prevention, deterrence andunderstanding motivation

7. Transparency, accountability andinvolvement

We are pleased that the majority ofrespondents have already begun to draft their action plans. We realisethese were based on the original draftrecommendations. Our intent is that theserevised recommendations serve as a guidefor the ongoing development of sectoraction plans.

In each section below, we set out a summaryof the relevant findings and originalrecommendations from Hidden in plainsight and our analysis of responses to these recommendations. Our finalrecommendations are listed at the end of each section.

Details of how we will evaluate how theserecommendations have been implementedcan be found at ‘Evaluating results’ at theend of this report.

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Section 1: Reporting, recording and recognition What we found

Hidden in plain sight found that under-reporting of disability-related harassmentwas widespread; that disabled people oftensaw incidents as so commonplace as to bepart of daily life and not ‘hate crimes’ andthat those receiving reports of harassmentwere failing to ask about disability or see itas a potential motivation. As a result, theprevalence and impact of disability-relatedharassment were greatly underestimated.

Our original recommendations

Hidden in plain sight made a range of draftrecommendations to tackle these issues.These included identifying and recordingwhether a victim is disabled, changes to the use of language on hate crime and onspecial measures, and ensuring robustsafeguarding alerts and accessiblereporting systems for residents livingin institutions.

Response to therecommendations

The Commission received a positiveresponse to these recommendations from most organisations. There wasconsensus that greater reporting, recordingand recognition are required to addressdisability-related harassment. Althoughthere were some questions about thepracticalities of implementation, there were encouraging commitments to action.

Responses received highlighted potentialdifficulties in a number of key areas,including data capture and the sharing of information across authorities and agencies.

Authorities have indicated that establishingwhether a victim is disabled is sometimesdifficult for police forces in England andWales (the legislation to do so already exists in Scotland). Our amendedrecommendation asks for this data to be included in the data already collected on other protected characteristics.

There were mixed views on ourrecommendation about the language of‘hate crime’. The UK Government rejectedthis recommendation on the basis that it didnot fit within a widely internationally andpublically recognised framework for hatecrime. The Commission recognises thisproblem and the associated problem oftackling multiple-identity hate crimes butwe maintain the view, based on the evidencepresented to us, that understanding of andidentification with ‘hate crime’ languageis a barrier for both victims and others inrecognising, reporting and tackling thebreadth of experiences of disability-relatedharassment. On that basis, we haveincorporated the removal of the barrierscreated by terminology into a generalrecommendation on the removal of barriersto reporting.

In relation to our recommendation on useof the term ‘special measures’, the UKGovernment helpfully provided

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clarification. We have removed thisrecommendation and replaced it with ageneral one that requires the removal ofbarriers for disabled people through allstages of the process of accessing justice,and in later sections we explain how this will be realised.

Summary of our findings

There has been some significant progressin recognising and addressing the barriersto reporting. We recognise the problems inlinking up data collection systems andappreciate that this can only be addressedas part of a longer-term strategy. There arealso some very promising developments inthe area of training.

We welcome the Government response on cyber-bullying in education, howevercyber-bullying is a wider problem andGovernment should work with a range of partners to address it.

There has been promising progress by somepolice forces on police call screening forrepeat victims. However, this is yet to beeffective across the majority of forces inEngland and Wales, particularly whererepeat calls rather than repeat incidents are used to trigger action.

Our evidence indicates that incidents maymount up before a first call is made, fora variety of reasons. A move towardsrecording repeat incidents will enablebetter triggers for deploying resourcesfor effective early intervention.

We recognise the challenges that recordingand reporting of incidents presents toorganisations, and note the commitmentand significant progress made by someorganisations on this issue. We believe thisdata should be publicised, with informationon action undertaken to challenge

harassment and the outcomes andconsequences for perpetrators. This couldact as a deterrent to perpetrators and helpbuild the confidence of disabled peopleto report.

It remains a key priority for theCommission to encourage furtherexploration of the problems and solutionsto recording and reporting, particularlyat a local level, in the promising work onpartnerships identified through the formalresponses. The new Police and Crimecommissioners in England could play an important role here.

Final recommendations

Having reviewed the responses, theCommission has agreed the following final recommendations under Section 1:

1. Authorities should remove barriers to all disabled people reporting crime,antisocial behaviour or bullying,including ‘cyber-bullying’. Authoritiesshould also consider how theycommunicate with disabled people and use terminology that service usersidentify with.

2. Staff responding to harassment shouldbe trained in how to better gather andrecord personal information aboutdisability in an appropriate and sensitive manner.

3. Authorities should adopt recordingsystems that record whether the victim was disabled (along with otherprotected characteristics), and whetherhostility/prejudice to disability was amotivation.

4. Authorities should recognise thepotential for escalation and recordincidents leading up to crimes in orderto support the implementation ofpreventative actions.

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5. Health and social care providers shouldput robust and accessible systems in place so that residents living ininstitutions can be confident whenreporting harassment that they will be treated sensitively.

6. Police call screening should focus onacknowledgement, risk of harm and thenumber of incidents rather than thenumber of calls in order to identify and address repeat victimisation.

7. Staff delivering health and social careservices to the public should be trained in safeguarding adults and children,including how to refer to appropriateservices.

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Section 2: Addressing gaps in legislation and policyWhat we found

Hidden in plain sight identified a number ofsignificant gaps in current legislativeframeworks, including a disparity insentencing guidelines for different groupsand an insufficiently robust safeguardingreferral process that means people are putat risk and criminal acts are not promptlyreferred to the police.

Our original recommendations

Hidden in plain sight made a range of draftrecommendations to tackle these issues.These included a review of eligibility criteriato increase social interaction and reducesocial isolation for disabled people,revisions to the ‘No Secrets’ guidance inEngland, statutory recognition of adultsafeguarding boards and parity insentencing guidelines for all types ofidentity-based murders.

Response to therecommendations

There has been substantial progress inimplementing these recommendations,particularly from national governments.We were particularly pleased about theamendment to Schedule 21 of the CriminalJustice Act 2003 to achieve parity insentencing guidelines for identity-basedmurders.

This will amend the Criminal Justice Act2003 to make the starting point for

sentencing in England and Wales formurder motivated by hatred or hostilitytowards disabled (and transgender) victimsequal to sentencing for murder motivatedby hatred or hostility to the other protectedcharacteristics of race, religion and sexualorientation. (This was already covered inScotland under the Offences (Aggravationby Prejudice) (Scotland) Act 2009.)12 Wehave removed this recommendation as ithas now been achieved.

In July 2012, the Government published theCare and Support White Paper and the draftCare and Support Bill. These documents setout the Government’s ambitious plans fortransforming care and support so thateveryone in England can plan and preparefor their care needs, access high quality carewhen they need it, and exercise choice andcontrol over the care they receive.

The Bill contains clauses that putsSafeguarding Adult Boards on a statutoryfooting, better equipped both to preventabuse and to respond when it occurs. Furtherclauses ensure local authorities establish andmaintain a service to provide advice on howto raise concerns about risk andsafeguarding. These reforms will set out aclear framework within which organisationsmust act which resounds significantly withthe inquiry recommendations.

We have retained the recommendations on these important issues in recognition of the fact that at the time of publication ofthis report the amendments are still at the Bill stage.

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

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Government rejected the draftrecommendation to build reports and plansto tackle disability-related harassment intogovernment strategies. The Commissionsupports the Government’s role indevolving decision-making to a local level, but is still of the view that nationalGovernment strategies should addressdisability-related harassment and so have retained this recommendation.

Summary of our findings

We welcome the significant progress andcommitment made to addressing the gapsin legislation and policy that support actionto tackle disability-related harassment:

An amendment to the Health and SocialCare Bill on the application of the HumanRights Act; the UK Government restatedits view that local authority-commissioned care services in Englandand Wales are covered by the HumanRights Act.13

The Welsh Assembly Government’s draftSocial Services (Wales) Bill is based on ahuman rights approach.

The UK Government’s hate crime plan‘Challenge it, Report it, Stop it’14 willconsider whether there is a case forchanging the law on incitement of hatredon grounds of disability, which fallsunder the Public Order Act. The planalso includes a commitment to placingSafeguarding Adult Boards on astatutory basis, and defines the sixprinciples governing the actions of theboards as empowerment, protection,prevention, proportionality, partnershipand accountability. This is in line withour recommendation to all governments

to consider the impact of the publicsector equality duty in tacklingdisability-related harassment withintheir jurisdiction.

Final recommendations

Having reviewed the responses, theCommission has agreed the followingfinal recommendations under Section 2:

1. National governments should:

review the adequacy and effectiveness of the legal framework for offences that are motivated by hostility to disability

review all statutory and common law restrictions on the public participation of disabled people, and other laws which unnecessarily and inappropriately treat disabled peopledifferently to others

ensure government reviews of the public sector equality duties facilitateeliminating disability-related harassment

place adult safeguarding boards on a statutory basis

introduce and develop human rights-based approaches to safeguarding

working with other departments, ensure ownership within and amongst statutory authorities for tackling disability-related harassment

build reports and plans to tackle disability-related harassment into government disability strategies.

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

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2. The Ministry of Justice and the widercriminal justice system should ensurethat section 146 of the Criminal JusticeAct 2003 is appropriately, consistentlyand transparently applied.

3. Authorities should ensure that policydevelopments on social inclusionincorporate the recommendations fromthe inquiry recognising the potential linkbetween propensity for social isolationand segregation, taking a social modelapproach. These should work towardscapacity for decision-making beingsupported, where appropriate, with ahuman rights-based approach.

4. Eligibility criteria for services should notbe focused just on vulnerability or risk of harm, but instead on an individual’scircumstances preventing them fromfully achieving their human rights, andtargeting resources to enable them to do so.

5. If a disabled person moves in order toavoid disability-related harassment,their security of tenure should not beadversely affected.

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Section 3: Ensuringadequate support andadvocacy What we found

Hidden in plain sight found failings in the provision of special measures15 to helpdisabled or intimidated witnesses give their best evidence in court across England,Scotland and Wales. There were alsosignificant gaps in provision of supportservices, not just at the reporting stage butthroughout and beyond the process ofaccessing justice.

Our original recommendations

Hidden in plain sight made a range of draftrecommendations to tackle these issues.These included: changing the procedure forspecial measures, early identification that avictim is disabled and the need for specialmeasures, the availability of good qualityaccessible and independent advocacythroughout a case, and access auditing ofsupport services.

Response to therecommendations

A number of authorities indicated thatresources could impact on the ability toimplement the recommendation toundertake access audits of services.

However, we welcomed governments’support for this recommendation, theirproposed work to review victims’ services,pilots to focus enhanced services to allintimidated and vulnerable witnesses andthe commitment to build in qualityassurance systems to this work. We haveretained a focus on accessibility in our finalrecommendations.

We acknowledge the difficulties of earlyidentification and follow through of specialmeasures but retain this recommendationbecause of its importance to achievingjustice.

Summary of our findings

There have been some very promisingdevelopments in terms of accessibility ofservices with all authorities demonstratinga commitment to meeting the needs ofdisabled people. We recognise that thecurrent economic climate may restrict theavailable resources for addressingaccessibility of support services. We believethat it is only by undertaking an audit thatservice providers will be able to identifyresource requirements and build these intotheir long-term service plans.

15 ‘Special measures’ are a series of provisions that help vulnerable and intimidatedwitnesses give their best evidence in court and help to relieve some of the stressassociated with giving evidence. Special measures apply to prosecution and defensewitnesses, but not to the defendant.

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We are disappointed to note slow progressin improving the application of specialmeasures and believe that for specialmeasures to aid continuous transitionthrough the criminal justice system,authorities and jurisdictions will need towork together.

We realise that the complexity of differentauthorities within the criminal justicesystem means there is work to be done toalign procedures. However, we do feel thisis a critical area for ensuring access tojustice and sending out important messagesto disabled people about their rights toaccess justice. These include that disability-related harassment will be taken seriouslyand that victims and witnesses will receivethe support they require to give evidence.

We welcome the commitment made by theMinistry of Justice and Crown ProsecutionService to tackle the challenges of bringingtogether different systems for the purposeof overall monitoring and recording theapplication of special measures.

Final recommendations

Having reviewed the responses, theCommission has agreed the following final recommendations under Section 3:

1. Requirements for special measuresshould be identified and implemented at the police investigation stage, andappropriate reasonable adjustmentsshould be provided throughoutinvestigation and prosecution. Lack ofprovision of either must not be a barrierto progression of a case nor a rationalefor dropping a case. Authorities shouldrefer disabled victims of harassment,antisocial behaviour and crime tosupport services (specialist services if appropriate).

2. Safeguarding Boards and CommunitySafety Partnerships should ensure thataccessible information and advocacyservices are available to enable disabledpeople to understand and exercise their rights.

3. Where authorities have obligations toprovide or commission local supportservices, they should take into accounttheir own public sector equality duties atthe planning stage, and reflect adequateprovision for access to disabled people.

4. The Ministry of Justice should provide a framework for a review of all barrierswithin the courts system for disabledpeople whether legal, attitudinal orphysical, such as restrictions on juryservice or provision of advocacy orinterpreter services or access to courtbuildings. Disabled people should beinvolved in challenging the barriers.

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Section 4: Improvedpractice and sharedlearning What we found

Hidden in plain sight found barriers to jointworking. These included problems withsharing data, failure to recognise‘incidents’16 and a failure to pick upincidents at an early stage.

Our original recommendations

Hidden in plain sight made a range of draftrecommendations to tackle these issues.These included developing reciprocalreporting arrangements between publictransport providers, reviewing theguidelines for serious case reviews,developing and disseminating proceduresand standards to minimise the risk ofharassment, developing a strongcitizenship and human rights agenda inschools, and ensuring security of tenure fora disabled person forced to move to avoiddisability-related harassment.

Response to therecommendations

We welcome and have adopted theGovernment’s proposed amendment to our draft recommendation on schoolspromoting understanding of disability and sharing good practice, whichrecognises the role of national and local leaders of education.

Good examples of strong partnershipapproaches included the commitment frompolice forces to work with social housingand education providers and transportproviders to develop links with educationproviders for the purposes of preventativework on disability-related harassment.

Some transport providers andintermediaries indicated that was notpractical. However, the British TransportPolice and Department of Transport aretaking a lead on this.

Transport providers identified problemswith referring all allegations of crimescommitted against disabled children andadults to the police and reciprocal reportingarrangements. However, the BritishTransport Police and Department forTransport have committed themselves tosupport reporting of disability-relatedharassment including across deregulatedservices, and we have adopted this as a finalrecommendation.

Summary of our findings

Some responses received indicate asignificant move towards joint andinnovative approaches. The Director ofPublic Prosecutions, Keir Starmer QC, andthe Association of Chief Police Officers’(ACPO) lead officer, Chief Constable Simon

16 Hidden in plain sight defined incidents as those experiences deemed to be low level andnot recorded as a crime or criminal activity e.g. name calling.

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Cole, have taken very public leading roleswithin the criminal justice sector. We are pleased to see this beginning to take shape in other sectors.

A number of responses were silent on ourrecommendation about improved practiceand shared learning. Given how importantwe found effective joined-up working to bein tackling the issue, especially at a locallevel, we call on all authorities to developapproaches for more effective joint working.

The 2012 Her Majesty’s Inspectorateof Constabulary report17 reflected ourconclusion that there is a need for furtherevidence and stronger data on repeatvictims and perpetrators.

For example, while many police forces arenow able to ‘flag’ repeat victims, this canonly be done on a ‘repeat call’ basis. This will not record those callers who haveexperienced repeat victimisation and maketheir first call some way into experiencingharassment. Currently only five policeforces (out of 44 in England and Wales)consistently question the caller to establishwhether repeat victimisation has occurred.

Final recommendations

Having reviewed the responses, theCommission has agreed the following final recommendations under Section 4:

1. Local agencies and partners shouldreview the priority they give toeliminating harassment, and theirinformation sharing systems, using jointintelligence to identify and stop repeatvictimisation or repeat perpetrators andprevent further escalation.

2. Local Authorities should play a lead rolein driving local partnerships to deliver onpreventing and tackling disability-related harassment, and all authoritiesshould develop approaches for effectivejoint working.

3. Regulators, inspectorates andombudsmen, along with seniorrepresentatives of service providers andtheir clients, should work together todevise and disseminate procedures andstandards which seek to minimise therisk of harassment.

4. Adult safeguarding boards should useprofessional networks to ensure:

lessons learnt from local serious case reviews are embedded in training and practice, and shared and evaluated nationally across all authorities

summaries of serious case reviews are publicly available and disseminated

educational establishments share continuous developments and practice in tackling disability-related harassment.

5. Serious case reviews should bemandatory for cases involving adults at risk unless proved unnecessary.

6. Transport providers should developreciprocal reporting arrangements andwork in partnership to addressdisability-related harassment.

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

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Section 5: Redress andaccessing justice What we found

Hidden in plain sight found that very fewcases of disability-related harassment gothrough the courts; and even when they do,sentencing does not always follow. There isvery limited application of section 146 of theCriminal Justice Act 2003,18 a failure toapply special measures properly and casesare often dropped because of perceivedwitness credibility.

Our original recommendations

Hidden in plain sight made a range of draftrecommendations to tackle these issues.These included: ensuring the seriousness of the offence, rather than the capacity ofthe victim, determines the basis for aninvestigation; investigation for potentialaggravated offences throughout theprogression of cases, where disability may be a factor, and ensuring that disabledpeople have equitable access to the court system.

Response to therecommendations

The most promising responses throughoutthe inquiry relate to access to justice. Thereis currently a dearth of knowledge on themotivations of perpetrators of disability-related harassment and we welcome the UKand Wales Governments’ commitments tobegin to address this. This will help policeforces and other agencies begin to developearly intervention measures once profilesand motivations are better understood.

Summary of our findings

We have revised our recommendation onaccess to the court system, and disabledpeople’s experiences, based on thesignificant commitment and progress made by Government.

Responses to the draft recommendationswere promising. They included acommitment to review the recording ofwhether disability is a motivating factor incrimes, to establish whether this is beingoverlooked currently, and the consistencyof application of section 146 of the CriminalJustice Act.

We also welcome the UK Government’sproposal to put quality assurance systemsin place to ensure that these commitmentsare being met.

Final recommendations

Having reviewed the responses, theCommission has agreed the following final recommendations under Section 5:

1. The perceived capacity of the victimshould never form the basis for decisionsabout police investigation.

2. Whenever repeat perpetrators or repeatvictims are identified, the priority givento solving the case should always beincreased to urgent.

3. Crimes motivated in part or in whole byhostility/prejudice to disability need tobe recognised, investigated and

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

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prosecuted as such. Where there isevidence of hostility/prejudice policeshould gather evidence to supportprosecution as an aggravated offenceutilising section 146 of the CriminalJustice Act where appropriate.

4. Government should undertake anextensive review of how disabled peoplecould be better protected within anadversarial justice system, includingconsideration of limiting when thevictim’s impairment can be used asevidence or in questioning in court.

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Section 6: Prevention,deterrence andunderstanding motivationWhat we found

Hidden in plain sight found a lack ofinvestment in research into the motivationand profile of perpetrators. Equallysignificant, there is no statutoryrequirement to conduct a serious casereview for the murder of a disabled person,as there is in England and Wales followingthe death of a child or adult from domesticviolence.

Our original recommendations

Hidden in plain sight made a range of draftrecommendations to tackle these issues.These included: appointment ofharassment co-ordinators; implementinginterventions to prevent occurrences andescalation of harassment; understandingthe characteristics and motivations ofperpetrators; designing out potential forconflict in transport; commissioning ofprimary research on the impact ofsegregated education on attitudes todisabled people, and research to fill theknowledge and data gaps on disability-related harassment.

Response to therecommendations

The UK Government partially agreed withour recommendation that definitive datashould be available to spell out the scale,severity and nature of disability-relatedharassment and that this would enable

better monitoring of the performance ofthose responsible for dealing with it.

We have retained the existingrecommendation but do not define how this should be achieved. We acknowledgethe Government's point that achievementof this recommendation can include usingexisting data sources more effectively.Where a review of existing data highlightsgaps, we expect that Government will fill these.

We were also pleased that the UKGovernment agreed with our draftrecommendation on transport providerstaking steps to ‘design out’ conflict, forexample between wheelchair users andthose with pushchairs utilising sharedspaces on public transport. In reviewing thedraft recommendations, we recognised thisas an issue that extends beyond transportand we have therefore reworded it toaddress the new recommendation to all architects, planners and designers.

The UK Government recognised thebenefits of adopting ‘lesson learnedreviews’ and the sharing of good practice.

The Department for Education did notagree with the recommendation aboutprimary research into the impact of non-inclusive schooling for disabled pupils.

There were also gaps in responses fromgovernment departments on the effective

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dissemination of learning from serious case reviews, other than in the ‘case of the vulnerable adult’ in Scotland. There was also some disagreement with therecommendations from the social care sector.

The Commission would like to see furtherprogress on sharing of lessons learnt fromserious case reviews, across authorities and geographical areas.

We recognise the challenge thisrecommendation represents but have retained it because progress oncommunication and learning will be even more crucial when power is devolved to a local level.

Summary of our findings

A significant issue for the inquiry was thatthe new sentencing guidelines in Englandand Wales should be used to enablemonitoring and evaluation of consistency of sentencing for disability-relatedharassment offences. The response fromthe Ministry of Justice was that this isalready possible. The Commission hasremoved reference to the new sentencingguidelines from the final recommendationbut kept the reference to monitoring and evaluation.

We were very pleased that the UKGovernment agreed with ourrecommendation that authorities andagencies should include provisions againstdisability-related harassment withintenancy agreements and in taking actionagainst breaches.

We have changed the responsibility for the recommendation on investment inresearch from the police to nationalgovernments. This is because governmentshave already taken a lead (for example in

the UK cross-government hate crimeprogramme) and are better placed torespond.

Research will allow authorities to developan in-depth understanding of motivation of perpetrators.

We have had some promising responses to learning more about perpetrationand motivation. We welcome the UKGovernment’s commitment in this area andlook forward to reviewing the outcomes.

We welcome the significant gains the newsentencing powers bring. In order to be an effective deterrent, it is important thecriminal justice authorities make full use of the opportunities these bring totackle disability-related harassment.Consideration is also needed on whetherspecific aggravated/incitement offenceswould act as a further deterrent.

The UK Government has recognised thelink between bullying and harassment andstrengthened teachers’ powers to tacklepoor behaviour and bullying.

However, they have rejected ourrecommendation for the Department forEducation to commission research on the impact of segregated education. TheGovernment made the point that quality ofprovision rather than setting is important.However, the Commission believes thatsetting may also be important and thatseparating disabled children from theirpeers at an early stage may have a long-termimpact. We suspect that this could be interms of social isolation and resilience ofdisabled people, attitudes among non-disabled children and adults, and thecapacity for positive interaction. Wetherefore believe research on this wouldbe beneficial.

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Final recommendations

Having reviewed the responses, theCommission has agreed the following final recommendations under Section 6:

1. National governments should take the leadin developing collective understanding of the motivations of perpetrators ofdisability-related harassment, includingfor the purposes of prevention, profilingand early intervention.

2. The Department for Education anddevolved administrations in Scotlandand Wales should review existingevidence on the extent to whichsegregated education (or inadequatelysupported integrated education) affectsthe ability of disabled children to beincluded within mainstream society.They should also consider evidence onthe extent to which segregation adverselyaffects non-disabled people’s views ofdisability and disabled people. Wheresufficient primary evidence isunavailable, they should considercommissioning new research.

3. Public authorities should use the publicsector equality duty as a framework forhelping promote positive images ofdisabled people and tackle the lowrepresentation of disabled people acrossall areas of public life.

4. All authorities should:

develop, implement and reviewawareness raising campaigns toencourage victims and witnesses ofdisability-related harassment to comeforward

encourage all individuals andorganisations to recognise, report and respond to any incidences ofdisability-related harassment theymay encounter

identify and implement interventionsto prevent harassment occurring inthe first place and develop responsesto prevent escalation. This shouldinclude using legal and non-legalsanctions as deterrents to would-beperpetrators, such as provisionsagainst disability-related harassmentwithin tenancy agreements

ensure that perpetrators ofharassment face consequences andthat these are properly implemented.

5. Authorities should identify andimplement ways to design out potentialfor conflict in use of shared space withinenvironmental infrastructures.

6. Police forces should develop an in-depthunderstanding of the characteristics andmotivations of perpetrators, design localprevention strategies accordingly andevidence their effectiveness.

7. Schools and colleges should developmaterial for helping studentsunderstand disabled people and thesocial model of disability, and theprejudice that disabled people facewithin society. The materials shouldencourage a better understanding andrespect for diversity and difference andhelp students know what to do when they see others perpetrating bullying and harassment, both in school andoutside (on public transport, in publicplaces, etc).

8. Schools and colleges should ensuredisabled pupils and those with specialeducational needs (SEN) are able toparticipate in all school/college andafter-school/college activities on anequal basis with non-disabled pupils(mainstreaming as a prevention).

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Section 7: Transparency,accountability andinvolvementWhat we found

Hidden in plain sight found that theabsence of data is a major problem toidentifying, preventing and tacklingdisability-related harassment. This makesit harder for individuals and organisationsat a local level to hold authorities to account for their performance.

In addition, regulators, inspectorates,ombudsmen and authorities themselvesneed to better understand the nature of the problem in order to address it, and the collation of relevant data will helpidentify where and how to best implementnecessary changes.

There is already promising progress in thecriminal justice sector from inspectorates in starting to identify the nature of theproblem, but as yet little is evident acrossother sectors.

Schools are hugely important in shapingand changing young people’s attitudestowards disabled people. Theirinterpretation and application of thenational curriculum can make a significantimpact on the inclusion of disabled peoplein everyday life.

Our original recommendations

Hidden in plain sight made a range of draftrecommendations to tackle these issues.

These included:

the availability of comprehensive data toenable performance monitoring

the use of the new sentencing guidelinesin England and Wales to monitorconsistency of sentencing

the review of no-criming and ‘motiveless’procedures

the ability to make limiting judgementswhere schools under-perform inequality-related areas e.g. identity-basedbullying

that regulators should includeperformance measures for dealing withdisability-related harassment and otherforms of hate crime

regulators intervening in serious cases of repeat disability-related harassment

the identification of hate ‘crime’ and hate‘incident’ levels within crime figures.

Response to therecommendations

We recognise that it would be difficult toreport on historic data and see the newsentencing guidelines as an opportunity tobegin to collect and evaluate current andfuture data to inform future policy.

We have retained the recommendation thatall authorities should have monitoring

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systems in place to record details aboutvictims, alleged perpetrators, the nature ofincidents and repeated harassment.However, we recognise the significantresource implications of thisrecommendation and welcome the feasibilitystudy proposed by the UK Government.

ACPO and the National PolicingImprovement Agency, in their response,stated that all forces work within theframework of the NCRS (Home OfficeCounting Rules for Recorded Crime) inrelation to recording incidents as crimes andwhen a recorded crime is re-classified ordeleted – ‘no-criming’.19 Forces are auditedfor compliance on this and on the quality oftheir data. The recommendation around no-criming has been retained but re-wordedslightly to help pick up disability-relatedharassment hidden within other crime datasuch as domestic violence, rape and sexualassault in order to help properly understandthe scale of the issue.

Following clarification from regulators andinspectors we have amended therecommendation that regulators shouldalways intervene in serious disability-related incidents leading to death or significant injury. Our newrecommendation refers to the need forregulators and inspectors to be satisfiedthat action is taken by the appropriateagency, and to intervene when it is not.

Summary of our findings

We understand that the progress of thelocalism agenda will ensure that localagencies dictate local priorities and thatnational regulation will play a much-reduced role. Preventative work,understanding perpetrators and

developing more effective deterrents will remain key priorities for tacklingdisability-related harassment.

We recognise the importance of effectivelyusing existing data and research but alsobelieve that an additional investment innew research to address the gaps inintelligence on disability-relatedharassment could potentially realisesimilar benefits to that of work on domesticviolence.

Final recommendations

Having reviewed the responses, theCommission has agreed the following finalrecommendations under Section 7:

1. Leaders of authorities and electedrepresentatives should show strongpersonal commitment, ownership anddetermination to deliver change.

2. Authorities should:

proactively work with disabled peopleand their representative organisationsto identify where risks of disability-related harassment are higher andtake appropriate action to address it

proactively engage with disabledpeople to improve services andpractice on preventing and tacklingdisability-related harassment,ensuring the provision of reasonableadjustments to aid involvement andparticipation.

3. Authorities should collect and share dataabout victim(s), alleged perpetrator(s),nature of incident(s) and repeat offending.

19 ‘No-criming’ is the term used for actions taken when it is established that a crime didnot in fact occur.

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4. Regulators, inspectorates andombudsmen should:

ensure that comprehensive data iscollected and shared which spells out the scale, severity and nature ofdisability-related harassment withinlocalities

ensure that application of section 146of the Criminal Justice Act 2003 ismonitored, evaluated and reported onto ensure appropriate application isconsidered in all cases.

5. Regulators, inspectorates andombudsmen should:

limit judgements of inspection andregulation by performance on equalityobjectives, including measures takento prevent and tackle disability-related harassment. Poor performersshould be identified and sanctioned ifno improvement is apparent within areasonable period of time

ensure their responses to harassmentare joined-up and use commonstandards and criteria for itsidentification

ensure a proportionate interventionwhen a serious or repeat case ofdisability-related harassmentemerges within their sector.

6. Police should review their rates of ‘no-criming’ where the victim is disabled,across all crime types, and address anyissues (i.e. disbelief) that may emergeas a result.

7. Disabled people should be involved inpublic transport policy development and transport providers should workin partnership with criminal justiceauthorities to reduce risk on and aroundtransport provision.

8. Regeneration and social housing designand planning should involve disabledpeople at planning stages in order to help ‘design out crime’ from futuredevelopments.

9. The Ministry of Justice should encouragethe publication of accessible performancestatistics that clearly identify:

the number of reported incidentsrecorded as crimes

the number of reported incidentsresulting in prosecution

harassment crime and harassmentincident levels within crime figures

the performance of local agencies andpartnerships in addressing harassment

service guarantees.

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Evaluating resultsThe Commission acknowledges the difficulteconomic climate in which authorities are working and the policy and structuralchanges that are taking place. These includethe moves towards localism and newcommissioned and locally managed police, health care and other services.

The Commission believes implementationof the final recommendations will deliverthe changes required to ensure disability-related harassment is prevented wherepossible and dealt with effectively when it does occur.

Current data availability does not provide a full picture of disability-relatedharassment. This is addressed within ourrecommendations, and we are committedto following up in a fuller review in 2015how and where those recommendationshave been acted upon to enablemeasurement of authorities’ response todisability-related harassment.

The Commission proposes to evaluate theemerging impact of the inquiry at variouspoints over the five year period followingthe launch of this Manifesto:

Schedule

October 2012 – baseline measuresagreed

September 2013 – at the end of year onewe will review progress against the initialbaseline measures and publish a reviewon the initial response by authorities tothe inquiry’s recommendations

September 2015 – at the end of year threewe will update our review of changesagainst the baseline data and publish afurther review to assess the extent towhich our recommendations have beenimplemented by the relevant authorities

September 2017 – at the end of year fivewe will conduct a final review of changesin the baseline data, assess the ultimateimpact of the inquiry and publish a finalreview of the inquiry.

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Outcome measures

At each stage of the evaluation, theCommission will analyse future waves of Crime Survey for England and Wales(CSEW)20 data to monitor:

the overall incidence of disability-relatedharassment (defined as those incidentswhich the victim felt were motivated byfactors relating to their impairment)21

the report rate of such hate crimes to the police and other authorities 22

the main reasons given by respondentsfor not reporting incidents of hate crimeto the police and other authorities.23

This data will be compared to that compiledand published by ACPO on those hatecrimes which have been recorded by policeforces in England and Wales.

This will be supplemented by CSEW data on:

the overall crime rates experienced bypeople with impairments analysed by theage of the victim

disabled people’s fears about being avictim of crime (including theirperceptions of safety)

victim satisfaction with police actions indealing with incidents which appearedmotivated by a strand characteristic.24

20 The Crime Survey for England and Wales (CSEW) is the new name for the British CrimeSurvey. CSEW is a face-to-face victimisations survey in which people resident inhouseholds in England and Wales, aged 16 and over, are asked about their experiencesof 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 theoffender’s attitude towards any of these factors?

Your religion or religious beliefsYour sexuality or sexual orientationYour ageYour genderAny disability you may haveDon’t knowNone of these’ (respondents can select all that apply)

The responses to this from the CSEW will be grossed up using demographic data toprovide an overall estimate of the incidence of crimes against disabled people whichwere motivated by their disability.

22 Proportion of CSEW hate crime incidents reported to the police (or came to be knownabout 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 smallsample sizes overall, this will be monitored for all strands.

24 This will be measured using CSEW data relating to victim satisfaction with the policehandling of crime incidents for crime in general and for those motivated by the factorslisted in footnote 21. Again, as a result of sample size issues, this monitoring will be forall strands.

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Existing Commission research25 will beused to set the baseline for each of the abovemeasures, and changes in them will bereviewed in 2013, 2015 and 2017. In particular, the Commission will belooking for a reduction in the current gapbetween the underlying incidence ofdisability-related harassment, the numberof such incidents that are being reported byvictims and the number recorded by policeand ultimately prosecuted.

The Commission has chosen to use theCSEW because it believes it to be the bestdata source, at this time, for estimating theunderlying incidence of various forms ofcrime and for tracking trends in these over time.

However it notes that, as is discussed inHome Office (2012, pp. 16-17),26 there arevarious factors which may lead it to eitherunder- or over-record the incidence of hatecrimes. These may include, for example, a lack of understanding of the concept byrespondents or other factors which mayrender an individual to be more likely tobecome a victim of crime that they mayattribute to their personal strandcharacteristics.

As well as the evaluation measures listedabove we will also be using the equalityduties, the Human Rights Act and theUnited Nations Convention on the Rights ofPeople with Disabilities (UNCRPD) tomonitor progress.

Next steps

To measure progress and drive the agendafor the inquiry recommendations theCommission will:

encourage, guide and monitor theprogress of public authorities in meetingtheir equality objectives, including inrelation to their devolved contexts where differentmonitor progress made towardscompliance with the Human Rights Actand the UNCRPD in respect ofsafeguarding and disability-relatedharassmentwork with adult protection professionalsin Scotland and Wales at the local level to capture useful learning.

To measure progress and drive the agenda,we expect governments, public authoritiesand leadership organisations to:

use the Human Rights Act 1998 and thepublic sector equality duties as enablingframeworks for data gathering, sharingand analysis, identifying priorities andinvolving service users from the outset in developing and implementing policydemonstrate that the partially hiddenand under-reported issue of crime andharassment targeting disabled peopleis effectively addressed, anddemonstrate commitment, clarity and transparency in setting clearlyunderstood and shared equalityoutcomes for people and communities at risk of harm.

25 Some of these can be found in two recent Commission Briefing Papers. One, by Noconet 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.pdfThe other, by Botcherby et al. (2011), provides a comparison of the experiences andconcerns 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

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The Commission’s publications are available to download on our website:www.equalityhumanrights.com. If you are an organisation and would like to discussthe option of accessing a publication in an alternative format or language please [email protected]. If you are an individual please contact theEquality 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 RightsCommission Helpline. It gives free advice, information and guidance to individuals onequality, discrimination and human rights issues.

Telephone: 0800 444 205Textphone: 0800 444 206

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

Artwork by Epigramwww.epigram.co.uk

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