Disability Equality Scheme	

		
Publication date:	30 November 2006	

Contents

Section		Page	
1	Foreword by the Chairman	1
2	Summary	2
3	About Ofcom	4
4	Disabled people and use of electronic communications	7
5	The Disability Duty	8
6	Ofcom's work on disability equality	11
7	Ofcom as an employer	17
8	Involving disabled people	20
9	Ofcom's disability equality priorities	21
10	Action plan	25
11	Gathering and using information	29
12	Impact assessment	30
13	Implementing the Disability Equality Scheme	31
14	How to contact Ofcom	32

	Section 1
1	Foreword by the Chairman
	The ways in which we communicate with each other, both individually and as a society, have never been more diverse. New communications technologies continue to emerge, providing more choice and opportunity for consumers to access entertainment and information and to interact with each other. But full participation for all is not a given; service providers and manufacturers need to take into account the needs of disabled people.
	As the UK's communications regulator, Ofcom has a number of duties designed to ensure disabled people have fair access to electronic communications. These include setting and monitoring targets for television access services (subtitling, audio description and signing) and encouraging the availability of easy to use equipment. In telecommunications we regulate the text relay service, which enables Deaf people and hearing people to communicate with each other. We are also working with telecoms providers to make new and existing telecoms services and technology accessible to disabled people.
	The independent Ofcom Advisory Committee on Older and Disabled People provides advice to the main Ofcom Board to ensure that Ofcom's policies and practices take into consideration views expressed by older and disabled consumers. There are also disabled members on the independent Ofcom Consumer Panel. The Chair of our Community Radio Fund Panel is also disabled.
	For our part, Ofcom is committed to building an inclusive and diverse workforce while recruiting the best talent available. We are also committed to promoting equality of opportunity and good relations between disabled and non-disabled people and do not tolerate unlawful disability discrimination and harassment. Diversity amongst our colleagues is valued.
	The main aim of our first Disability Equality Scheme is to ensure that disability equality is not reliant on the commitment of a few individuals but instead is fully integrated as part of our normal daily business. It is founded on best practice principles and has been shaped with the involvement of disabled people from across the UK.
	David Currie
	Chairman, Ofcom
	Section 2
2	Summary
2.1	This is Ofcom's first Disability Equality Scheme (DES). It sets out what Ofcom has done so far and the next steps to ensure that Ofcom plays its role in promoting equality of opportunity and access for disabled people.
2.2	Ofcom involved disabled stakeholders in the identification of its priorities and the development of this DES through:
·	its Advisory Committee on Older and Disabled People;
·	involving disabled colleagues within the organisation. 
·	advertising in Disability Now magazine and website; and
·	focus groups in England, Scotland, Northern Ireland and Wales;
2.3	In engaging disabled people in the development of the scheme, Ofcom identified seven priorities that it should concentrate on over the next three years to help promote disability equality. These were:
·	Access
·	Media literacy
·	Content and standards
·	Information services and complaints
·	Participation and consultation
·	Employment and training
·	Procurement
2.4	In the action plan, Ofcom outlines the agreed work on equality for disabled people as it relates to its role as the UK's communications regulator and as an employer. The priorities identified during the involvement process are aligned to Ofcom's aims and activities identified in its Annual Plan to ensure that actions to address disability equality are part of its daily activities. These actions include:
·	Clarifying the way in which the communications industry serves the interests of disabled citizens.
·	Encouraging manufacturers to develop communications equipment which is capable of being used with ease, and without modification, by the widest possible range of individuals, including those with disabilities.
·	Ensuring broadcasters meet their obligations with respect to subtitling, signing and audio description.
·	Promoting media literacy through dialogue with disabled stakeholders, particularly those with learning disabilities
·	Ensuring that the generally accepted standards are applied to the contents of TV and radio services to provide adequate protection for members of the public from the inclusion of offensive and harmful material, including the portrayal of disabled people. 
·	Embedding disability equality in Ofcom's approach to impact assessments in order to improve policy decisions.
·	Seeking to recruit more disabled people to Ofcom's decision making boards.
·	Being more creative and pro-active in recruiting and developing disabled colleagues.
·	Seeking to ensure that the companies Ofcom buys goods and services from have equal opportunities policies that include disability equality.
2.5	Progress on the disability action plan will be reviewed annually. New actions might be included depending on developments within the communication industry and any changes in priorities that might be identified further to the publication of the action plan.  Ofcom will undertake to review its operations in three years time, in line with the Disability Discrimination Act.
	Section 3
3	About Ofcom
3.1	Ofcom is the regulator for the UK communications industries, with responsibilities across television, radio, telecommunications and wireless communications services. It is independent of Government but accountable to Parliament.
3.2	Ofcom’s sponsoring Departments of State are the Department of Trade and Industry and the Department for Culture, Media and Sport.
3.3	Ofcom was set up, and its powers and duties are provided for, under the Communications Act 2003. Its principal statutory duty in carrying out its function is to:
a)	further the interests of citizens in relation to electronic communication matters; 
b)	further the interests of consumers in relevant markets, where appropriate by promoting competition.
3.4	Ofcom’s main office is located in London; it has, in addition, National offices in Wales, Scotland and Northern Ireland and a network of field operations colleagues across the UK.
	Ofcom Board 
3.5	The Board provides strategic direction for Ofcom – it is the main statutory instrument of regulation with a fundamental role in the effective implementation of the Communications Act.
	Content Board 
3.6	The Content Board is a committee of the main Ofcom Board. It has delegated and advisory responsibility for a wide range of content issues, predominantly dealing with broadcasting.
	Ofcom Consumer Panel 
3.7	The Consumer Panel is independent of Ofcom. It was established to advise Ofcom on consumer interests in the markets regulated by Ofcom. It has a specific remit to inform Ofcom on consumer issues, specifically those of people with disabilities, older people, rural customers and those on low income or who are otherwise disadvantaged.
	Advisory Committee on Older and Disabled People
3.8	This is one of Ofcom's five statutory advisory committees. The committee has a direct reporting line to Ofcom’s main Board and can advise on issues across Ofcom’s remit as well as Ofcom's internal policies and procedures.
	Ofcom's duties to promote equality of opportunity
Ofcom's general duties
3.9	Under the Communications Act 2003, Ofcom has specific responsibilities for the promotion of disability equality. Under Section 3 (4i) of the Act, in the performance of its duties, Ofcom must have regard to the needs of persons with disabilities, of the elderly and of those on low incomes. 
Employment and training
3.10	Under Sections 27 and 337 of the Act, Ofcom is required to promote equality of opportunity in employment and training for disabled people, and other equality groups, in television and radio.
Fair access to services
3.11	Under Sections 303, 308 and 309 of the Act Ofcom has duties that cover drawing up a code giving guidance to promote enjoyment of television by people who are deaf, visually impaired or both; ensure the inclusion of assistance for the visually impaired with the teletext service; and draw up a code of practice for electronic programme guides.
	Ofcom's Aims and Activities
3.12	Ofcom has many duties, from protecting viewers and listeners against offensive material to ensuring the optimal use of the radio spectrum. Ofcom also has an important role in enforcing consumer law, which means protecting consumers against mis-selling and other harmful conduct. In its role as a competition authority, Ofcom aims to make markets work better by tackling and deterring anti-competitive behaviour. Ofcom has organised its work into eight areas that represent its aims and activities:
·	Addressing citizen and consumer issues - All of Ofcom’s work is ultimately focused on furthering the interests of citizens and consumers. Ofcom will protect consumers and citizens by taking appropriate enforcement action; promoting media literacy; handling complaints via the Contact Centre; and carrying out research to understand better the varying needs of different groups within the UK population.
·	Encouraging innovation - The work Ofcom will be doing to encourage innovation includes three priority areas: spectrum release: auctions and liberalisation; next generation deployment; and content delivery. Ofcom will work to encourage an environment which supports investment and innovation in the future, not just lower prices for existing services now. 
·	Promoting competition - In a rapidly changing world, the benefits for citizens and consumers are potentially largest where markets are open, new entrants can compete against incumbents, investment is encouraged and innovation flourishes. An emphasis on helping markets work better, for example, through the provision of better information to consumers, rather than substituting regulation for the market. 
·	Pursuing better regulation - There is a requirement under the Communications Act for Ofcom to avoid imposing or maintaining regulatory burdens which are unnecessary. Ofcom will continue to explore opportunities to reduce and better target regulation, taking account of the latest regulatory thinking in Europe and throughout the world.
·	Engaging internationally - The framework within which Ofcom regulates is to a significant extent determined at the supra-national level and the need to understand and help inform this legislative agenda. Ofcom will seek to influence the way that regulatory policy evolves, in particular, the new EU directive on TV and other audio-visual content, the revised EU framework for electronic communications and international negotiations on spectrum.
·	Providing key services - Ofcom provides some key services to its stakeholders. They fall into four categories: supporting authorised use of spectrum; licensing access to spectrum; keeping spectrum free of interference; and providing advice via the Contact Centre, responding efficiently to enquiries from stakeholders and informing the policy-making process the issues which are raised.
·	Understanding the sector and our stakeholders - To ensure that there is a strong evidence base to inform thinking and decision making, Ofcom carries out and publishes a comprehensive programme of research.
·	Operating effectively - Ofcom continually seeks to operate more effectively. This includes improving the information technology services within Ofcom; re-organising business processes and systems to achieve the most efficient and integrated use of resources; exploring ways of achieving a more diverse workforce and encouraging diversity in the communications sector more generally; and providing support to Ofcom’s advisory panels and committees.

	
	Section 4
4	Disabled people and use of electronic communications
4.1	National statistics for the UK suggest that people with disabilities make up 18% of the population. Using the definition of disability under the DDA, it is estimated that as many as one in five people of working age have a disability.
4.2	Electronic communications can be of particular importance to those disabled people with visual impairment, hearing impairment and/or mobility issues, as without such skills, disabled people’s ability to participate effectively in the workplace and in society may be greatly diminished.
4.3	Some 82% of disabled people aged under 65 have a mobile phone, 65% have digital TV, 50% have home access to the internet and 46% say they have access to digital radio services. These levels of ownership are similar to all UK adults under 65, with the exception of mobile phones (90% all adults under 65) and the internet (62%).
4.4	Compared to the average for all UK adults under 65, disabled people aged under 65 on average watch more TV and listen to more radio, and use the internet and mobile phones to the same extent.
4.5	Concerns about TV content, particularly the portrayal of disability, are higher amongst disabled people aged under 65 than amongst the equivalent age group across UK adults as a whole, with concerns about radio content, the internet and mobile phones at around the same level. Concerns appear to be slightly greater for those with mobility impairments than those with sensory impairments.
4.6	Nearly three-quarters of tasks related to television (both analogue and digital) were felt to be able to be done with confidence by disabled owners aged under 65, with slightly lower levels for internet, and higher levels for mobile phone tasks.
4.7	Four-fifths of disabled adults aged under 65 are aware of the 9 pm watershed. Just over half of disabled home internet users aged under 65 say they can control content. By contrast, relatively few disabled mobile phone owners aged under 65– 15% - demonstrate knowledge of the content controls available on the most recent mobile phones. These measures are all close to those for UK adults under 65.
4.8	Knowledge of how TV is funded, and whether or not it is regulated, is fairly high, at an index level of 78%. This is very similar to the measure for all UK adults under 65 (80%). Levels of knowledge about industry funding and regulation for radio are not as high. The overall index measure is 55%, very similar to the measure of 58% for all UK adults under 65. Knowledge of internet funding sources is relatively low, with an index measure of 35%.
	
	Section 5
5	The Disability Duty
5.1	The Disability Discrimination Act (DDA) 1995 says that "A person has a disability if he has a physical or mental impairment, which has a substantial and long-term adverse effect on his ability to carry out normal day-to-day activities."
5.2	The Code of Practice for the DDA 2005 moves this issue on by explaining that, "The poverty, disadvantage and social exclusion experienced by many disabled people is not the inevitable result of their impairments or medical conditions, but rather stems from attitudinal and environmental barriers". This is known as 'the social model of disability'.
5.3	True equality of opportunity for disabled people requires more than an approach which seeks to treat disabled people the same as everyone else. This philosophy underpins the requirements to combat discrimination (notably the Act’s requirement to make reasonable adjustments) and to promote equality of opportunity.
	The General Duty
5.4	The DDA amended the 1995 Act to insert a disability equality duty - known as the General Duty - into the Act. The duty is aimed at tackling systemic discrimination, and ensuring that public authorities build disability equality into everything that they do.
5.5	Section 49A of the Act says that public authorities must, when carrying out their functions, have due regard to the need to: 
·	promote equality of opportunity between disabled people and other people 
·	eliminate discrimination that is unlawful under the Act 
·	eliminate harassment of disabled people that is related to their disability 
·	promote positive attitudes towards disabled people 
·	encourage participation by disabled people in public life 
·	take steps to meet disabled people’s needs, even if this requires more favourable treatment.
5.6	Public authorities are expected to have ‘due regard’ to the six parts of the general duty. In all their decisions and functions, authorities should give due weight to the need to promote disability equality in proportion to its relevance. ‘Due regard’ comprises two linked elements: proportionality and relevance. 
5.7	Proportionality requires greater consideration to be given to disability equality in relation to functions or policies that have the most effect on disabled people. Where changing a function or proposed policy would lead to significant benefits to disabled people, the need for such a change will carry added weight when balanced against other considerations. 
5.8	Disability equality will be more relevant to some functions than others. Public authorities will need to take care when assessing relevance, as many areas of their functioning are likely to be of relevance to disabled people.
	Specific duties
5.9	The specific duties require each of those public authorities which are listed to: 
·	publish a DES showing how it intends to fulfil its general duty and its specific duties 
·	involve disabled people in the development of its scheme 
·	review the scheme at least every three years. 
·	The DES should include a statement of: 
·	how disabled people have been involved in developing the scheme 
·	the steps which the authority will take to fulfil its general duty (the action plan) 
·	arrangements for gathering information about performance of the public body on disability equality 
·	arrangements for assessing the impact of the activities of the body on disability equality and improving these when necessary (impact assessments) 
·	arrangements for making use of the information gathered in relation to reviewing the effectiveness of its action plan and preparing subsequent Disability Equality Schemes. 
5.10	A public body must also: 
·	take the steps set out in its action plan 
·	put into effect its arrangements for gathering and making use of information 
·	publish an annual report which includes a summary of the steps it has taken to involve disabled people in the development of the scheme, the result of information gathering and the use it has made of such information.
	Ofcom’s duties under the Disability Discrimination Act 2005
5.11	The DDA places an obligatory General Duty on public bodies, including Ofcom, to promote disability equality. The overarching goal of the General Duty is to ensure equality of opportunity for disabled people. It aims to ensure that the promotion of disability equality is embedded in all of a public authority’s activities in policy, service delivery and employment and Ofcom is fully committed to discharging this duty.
5.12	Ofcom also has a specific legal duty to publish a DES which sets out how it intends to carry out its duties under the General Duty through meeting the specific duties listed above.

5.13	Ofcom's aim is to ensure that it pays due regard to equality for disabled people in developing its policies and strategies, providing services or employing people. Ofcom will make sure that its disability equality priorities and action plan will be part of its business plan. The DES and action plan will be monitored and progress reported on every year in Ofcom's Annual Report.
	Section 6
6	Ofcom's work on disability equality
6.1	There are two parts to Ofcom's work to promote disability and other equalities issues - the internal aspect ensuring that Ofcom manages diversity effectively across the organisation; and the external aspect promoting fair access to communications and encouraging equal opportunities within the sectors it regulates.
	Communications Act
6.2	Under the Communications Act 2003, Ofcom has legal obligations to promote equality of opportunity that explicitly refer to the needs of disabled citizens and consumers. 
Section 	Detail	
Section 3 (4)i	General duties of Ofcom
Ofcom must have a regard, in the performance of its duties, to the needs of people with disabilities, insomuch as they are relevant to the circumstances.	
Section 10	Easily usable equipment
Ofcom should take steps to encourage manufacturers to develop domestic electronic communications equipment which is capable of being used with ease, and without modification, by the widest possible range of individuals (including those with disabilities).	
Section 21	Advisory Committee for Older and Disabled People
Ofcom must establish and maintain a committee to provide advice on the needs of disabled and older citizens.	
Section 27	Employment in broadcasting
Ofcom should take steps as considered appropriate for promoting the equalisation of opportunities in the employment and training for disabled people in television and radio.	
Section 303	Television services for the deaf and visually impaired
Ofcom has a duty to draw up and from time to time revise and review a code giving guidance to promote understanding and enjoyment by:
-	people who are deaf or hard of hearing;
-	people who are blind or partially sighted; and
-	people with a dual sensory impairment	
Section 308	Assistance for the visually impaired with the teletext service
In the public teletext service, Ofcom should consider conditions to ensure the inclusion of particular features of this service, so that people with disabilities affecting their sight are able to make use of the service.	
Section 310	Code of practice for electronic programme guides
Ofcom has a duty to draw up and from time to time review and revise a code giving guidance as to the practices to be followed in the provision of electronic programme guides. The practices required by the code must also include the incorporation of features that will ensure access by people with disabilities affecting their sight or hearing or both.	
Section 337	Equal opportunities and training
Ofcom requires broadcast license holders to make arrangements for the equalisation of opportunity in employment and training for disabled people.	

	Internal activities
Diversity Champion
6.3	Since Ofcom's formation in 2003, it has undertaken work to progress disability equality and raise awareness of issues across the organisation and amongst the industries it regulates.
6.4	In 2006, Ofcom appointed a Diversity Champion at senior management level to lead the agenda within the organisation. The Diversity Champion sits on Ofcom's Executive Committee.
6.5	The Diversity Champion has responsibility for disability equality as well as other diversity issues and leads the agenda within the organisation. They will have responsibility for the operational implementation of this DES and action plan.
Diversity Working Group
6.6	The Diversity Working Group (DWG) was established to steer the diversity agenda within Ofcom and assist in managing the organisation's approach to equality and diversity. The group also monitors the implementation of the Diversity Action Plan, which includes activity to promote disability equality. 
6.7	The DWG consists of colleagues from each Ofcom Group and is chaired by Ofcom's Diversity Champion.
Advisory Committee on Older and Disabled People 
6.8	The Advisory Committee on Older and Disabled People (ACOD) advises Ofcom about the interests and opinions of older and disabled people living in the UK. The remit of the Advisory Committee is to:
·	seek to identify issues affecting the communications sector of interest to disabled  and older people, both collectively as a Committee and individually as Members; 
·	provide advice to Ofcom about general and specific issues concerning the communications sectors relating to disabled and older people; 
·	provide advice and comment as required on matters brought to the Committee by Ofcom; 
·	offer comment, as appropriate, on consultations undertaken by Ofcom; 
·	where requested by the Content Board, to provide specific advice to that Board on matters relating to television, radio and other content on services regulated by Ofcom; 
·	when so requested by the Ofcom Board, to provide advice to the Consumer Panel on matters relating to disabled and older people in the communications sector; 
·	provide Ofcom with advice on matters relating to its responsibilities for the promotion of media literacy affecting disabled and older people; and
·	to contribute to Ofcom's Annual Report to ensure this reflects Ofcom's work on issues relating to disabled and older people.
6.9	ACOD has twelve members who reflect the diversity of disabled and older people and who have a wide range of expertise and interests across all the areas that Ofcom regulates.
Employers' Forum on Disability
6.10	The Employers' Forum on Disability (EFD) is the UK's leading employers' organisation focused on disability as it affects business. It is funded and managed by its members. The aim of the forum is to make it easier to recruit and retain disabled employees and to serve disabled customers. Ofcom has been a member of the forum since 2004. Ofcom uses this forum to keep pace with developments which impact on the recruitment and development of disabled colleagues.
6.11	Ofcom has joined to the EFD's Disability Standard, enabling it to measure its current performance on disability and what needs to be done to make progress. The standard allows Ofcom to compare its performance against organisations within the communications industry and other employers.
	External activities
Equality Scheme for Northern Ireland
6.12	Under section 75 of the Northern Ireland Act 1998 (NIA), Ofcom is required to produce an Equality Scheme in relation to its functions in Northern Ireland. Section 75 of the NIA includes an obligation to promote disability equality. In 2005, Ofcom published its Equality Scheme which sets out how the organisation proposes to fulfil its duty to promote equality of opportunity over the next five years until 2010.
Provision of Television Access Services
6.13	Ofcom commissioned the Provision of Access Services research to provide the first independent and statistically significant data on the numbers of people who could benefit from television access services (subtitling, signing and audio description), and on those actually making use of them. This provided an important input to Ofcom’s review of the Code on Television Access Services, which was published at the end of September 2006.
6.14	The Code on Television Access Services sets out the requirements on subtitling, sign language and audio description that apply to television services licensed in accordance with the Communications Act 2003, the Broadcasting Act 1996, or the Broadcasting Act 1990. Ofcom notes that some broadcasters already provide television access services on a voluntary basis, and encourages broadcasters to do so where possible, even if they are not required to do so by this code.
6.15	Ofcom requires television service providers to promote awareness of the availability of their television access services to potential users of the services by making available accurate and timely information to electronic programme guide (EPG) operators listing their services, and by providing similar information on their website. Ofcom has imposed corresponding obligations on EPG operators through the code to be made under section 310 of the Act. Broadcasters who provide programme synopses for use in EPGs should indicate which programmes are accompanied by television access services by including the standard upper-case acronyms for subtitling, audio description and signing.
6.16	Each year, a review is carried out to determine which channels have an audience share and income that would justify the provision of access services. From 1 January 2007, some 90 channels will be required to provide access services. These channels account for more than 95% of peak-time viewing.
6.17	The research commissioned by Ofcom showed that about 66,000 claimed to have seen a signed programme at least once, and to have a good knowledge of British Sign Language, but indicated that many of these preferred to use subtitling instead. It is likely that on many of the channels with small audiences, signed programmes are being watched by very few people, if any. Following discussion with disability organisations and feedback from access service users, Ofcom believes that the current arrangements for signing on television are not meeting the needs of sign language users, and is discussing with disability organisations and broadcasters whether alternative arrangements would be more appropriate. Ofcom expects to consult on alternative arrangements towards the end of 2006.
European Regulatory Framework Review
6.18	The European Regulatory Framework Review re-examines the five electronic communications directives which are intended to unite and harmonise communication regulation throughout the European Community. During its engagement with this review, Ofcom has identified the need to assess the link between the Communications Directive and the Radio and Telecommunications Terminal Equipment Directive, highlighting the relationship between disabled people's access to communications and the need for easily usable equipment.  
Universal Service Review
6.19	Universal Service Obligations (USO) ensures that basic fixed line services are available at an affordable price to all citizen and customers across the UK.  USO services include: special tariff schemes for low income customers; a connection to the fixed network, which includes functional internet access; reasonable geographic access to public call boxes; and the provision of a text relay service for customers with hearing impairment.
6.20	In 2006, Ofcom reviewed USO to ensure that the obligations continue to meet the needs of consumers as demands and technology change, find the right balance between the needs of vulnerable customers and changing commercial conditions and make sure the benefits of measures reach those who need them by targeting and creating incentives.
6.21	The review has a section specific to the needs of disabled consumers. In this section Ofcom concluded that a Stakeholder Advisory Panel for the relay service should be established and an annual plan and report on the operation of the service published. Ofcom also proposed that other changes to requirements on providers in respect of services for disabled customers should be made. These include extending the scope of customers who can receive bills and contracts in special formats and increasing some accessibility requirements for PCBs. These changes will require changes to the relevant conditions. Ofcom will propose these changes in a separate consultation document shortly. This document will also address legal issues arising from the dispute raised by providers against BT’s increase of the connection charge to BT’s Text Direct service.
Research
Media Literacy Audit: Report on media literacy of disabled people
6.22	In 2006, Ofcom undertook research which looked at how disabled adults and children in the UK access, understand and create electronic communications. In this context, Ofcom's definition of access was much wider than availability or take-up of the platforms. Rather, it focused upon interest, awareness, usage and competence relating to each platform. Understanding relates to how content (such as television and radio programmes, internet websites, or mobile video and text services) is created, funded and regulated.
The Representation and Portrayal of People with Disabilities on Analogue Terrestrial Television
6.23	The research was conducted to evaluate the representation of people with disabilities on analogue terrestrial television in terms of the extent of representation and how people with disabilities have been portrayed. The report is of a content analysis of recorded samples of television programmes broadcast in 2004.
6.24	The research found that, in 2004, only 12% of sampled programmes (on BBC1, BBC2, ITV, Channel 4 and Five) included representations of people with disabilities. However less than 1 person/character in 100 in the sampled programmes overall had a disability.
Universal Service Obligation: Deaf and Hearing Impaired Consumers and Text Phone Services
6.25	This presents the findings from a qualitative study, undertaken in 2004, into the provision of text relay services for deaf and hearing impaired consumers, conducted by MORI Social Research Institute on behalf of Ofcom, the communications regulator.
6.26	A text relay service allows text phone users to call phone users (and vice versa) via a third party operator who translates text to speech. A text phone has a keyboard into which messages can be typed and a display screen to read messages. They are used primarily by deaf and speech impaired users and anyone else who is unable to use a standard telephone.
6.27	Research was commissioned with members of the deaf and hearing impaired communities, in order to develop understanding about the usage of, attitudes towards, and perceived benefits of text phone services. The aim is to assess the operation of text relay services and gather views on their marketing.
Code on Electronic Programme Guides
6.28	This code requires electronic programme guide (EPG) providers to give appropriate prominence for public service channels; provide the features and information needed to enable EPGs to be used by people with disabilities affecting their sight or hearing or both; and secure fair and effective competition. The EPG Code requires EPG providers to:
·	Provide easily accessible information on how to identify programmes broadcast with subtitling, signing and audio description services. 
·	Provide easily accessible information on how to switch on these services. 
·	Give 'appropriate prominence' to public service channels such as the BBC, ITV1, Channel 4, S4C, five and teletext and explain their approach to this. As there are different ways which this can be done Ofcom will intervene only if there are complaints, or if it is not content with the way public service channels are displayed; 
·	Treat channels listed on their EPGs in a fair, reasonable and non-discriminatory way; 
·	Explain their approach to listing other channels on their EPG, and review this approach from time to time.
6.29	Ofcom expects EPG providers to consult disability groups and individuals about the way they meet their obligations under the code, which are set out above.
6.30	Ofcom intends to review the Code at intervals of no more than two years, or more frequently if circumstances warrant it. As part of the review, it will consult stakeholders, including EPG providers, broadcasters, and disability groups.
Equal Opportunities: A Toolkit for Broadcasters
6.31	This toolkit provides broadcasters with practical ways to promote equality of opportunity (including disability equality) in employment and training within their organisations. 

	Section 7
7	Ofcom as an employer
7.1	Under the DDA, Ofcom has a legal duty to promote equality of opportunity for disabled people in employment and training. 
7.2	Ofcom must make arrangements to gather information on the impact of its policies and practices on the recruitment, development and retention of disabled colleagues. Arrangements need to include:
·	a review of applicant numbers, short listed and appointed profiles;
·	types of jobs being undertaken by disabled people, grades/salary levels;
·	training courses attended;
·	career progression;
·	appraisals;
·	disciplinary action;
·	reports of disability harassment (and how resolved);
·	duration of employment;
·	numbers in full or part-time work;
·	numbers leaving giving reasons, including redundancy, dismissal, ill-health, retirement; and
·	analysis of exit interviews for disabled staff (including those taking ill-health retirement).
7.3	Similar assessments need to be made, not just of colleagues, but also of Ofcom's Board, independent Consumer Panel and advisory committee members to seek to ensure the participation of disabled people.
7.4	Although one in five people in the UK is disabled, just over ten per cent of the UK population is disabled and economically active or seeking employment. Currently, 2.2% of Ofcom's colleagues have declared they are disabled. Proportionately, Ofcom's performance in this area is comparable to similar public bodies. For example, the Office of Fair Trading has 2% disability representation, the Cabinet Office 3.6% disabled employees and the Treasury 3%. 
7.5	When looking at the employment of disabled people, it is essential that Ofcom is clear about its definition of disability. Ofcom's recruitment monitoring form asks individuals whether they consider themselves to meet to the DDA definition of disability but also uses a broader self-identification social model definition.

7.6	In considering the workforce profile it is important to note that there may be more disabled people within the organisation who have not declared their status. Non-disclosure may occur for a range of reasons, including where colleagues do not consider themselves to be disabled, do not apply the DDA definition to their circumstances, distance themselves from the label 'disabled', especially for those who may have recently acquired an impairment, and fear of discrimination. Another reason is that many people with impairments or long term health conditions would not describe themselves as ‘disabled’.
7.7	Ofcom will seek to improve the accuracy of the declaration rate for disabled colleagues through raising awareness of what is defined as a disability under the DDA. Ofcom is committed to offering more support for disabled colleagues through the creation of a disabled colleagues' network if a need for such a group is identified. 
	Recruitment
7.8	Ofcom is committed to building a workforce that reflects wider UK society. Whilst improvement is required, Ofcom is seeking ways to be more creative when attracting and recruiting disabled colleagues into the organisation. 
7.9	Certain vacancies within Ofcom require the use of specialist agencies. Ofcom is working with recruitment agencies to ensure that they are aware of Ofcom's commitment to diversity and the desire to attract additional talented disabled candidates.
Graduate Recruitment
7.10	Approximately 6% of first degree graduates have a disability, representing over 11,500 people. Ofcom will seek to reflect this diversity in its Graduate Recruitment Campaign.
	Training
7.11	It is essential that all Ofcom colleagues have a good basic knowledge of the DDA and are given specialist knowledge relevant to their work, so that they can carry out their duties in accordance with the general duty of the DDA.
7.12	In 2005, Ofcom commenced its diversity training programme. Training sessions included details on disability equality, as well as wider diversity issues. Over the next three years Ofcom will organise a training programme to inform colleagues of their duties under the DDA
	Work-Life balance
7.13	Ofcom is expanding its Work Life Balance policy to include staggered hours to assist those colleagues whose disability does not allow them to work in the same patterns as their able bodied colleagues. Subscription to this work method will be subject to the business needs of Ofcom.
	Employment procedures and policies
7.14	Ofcom will review procedures and policies to seek to create an environment which is designed actively to minimise barriers to employment and progression for disabled people. Ofcom strives to ensure that appropriate reasonable adjustments are made and in place and will provide advice and information to disabled colleagues and line managers on the DDA and DES and available support.
	Broadcasters
7.15	Ofcom has a legal duty to encourage the promotion of equality of opportunity for disabled people in employment and training within the broadcasters it regulates.
7.16	In 2005, Ofcom produced an equal opportunities toolkit for broadcasters to provide guidance on how to promote equality of opportunity and enhance their recruitment activity.
7.17	Ofcom also encourages broadcasters to monitor their workforces and access to training by disability, gender and race.  An annual report from all public service broadcasters providing information on the diversity of their organisations is required by Ofcom and will be published on its website.

	Section 8
8	Involving disabled people
8.1	The DDA requires the involvement of disabled people in the development of the DES. To ensure that the scheme is relevant to the needs of disabled people, Ofcom involved of disabled people from the start. 
	Advisory Committee on Older and Disabled People (ACOD)
8.2	The first step was to involve Ofcom's Advisory Committee on Older and Disabled People in the identification of barriers to access and the priorities that Ofcom should be concentrating on over the next three years. 
8.3	ACOD is Ofcom's primary mechanism to involve disabled people in shaping the organisation's disability equality direction. There is ongoing involvement and communication between this group and the Ofcom Board.
	Colleague engagement
8.4	Ofcom invited disabled colleagues to contribute to the development of the DES through the intranet. 
	Advertisement in Disability Now magazine and on the website
8.5	Ofcom placed a full page advertisement in Disability Now magazine and on the publication website for a month inviting readers to contribute to the development of the scheme and help in identifying priorities.
	Consultation with access service users
8.6	Ofcom consults periodically with television access service users (subtitling, signing and audio description) on issues of concern to them, including issues such as proposals to revise the standards applying to the provision of access services, and changes to the Code on Television Access Services. Ofcom is convening a Subtitling Forum with disability groups and broadcasters in November to discuss how subtitling is provided, and the problems that arise with the service. 
	Focus groups
8.7	Ofcom organised four focus groups in England, Scotland, Wales and Northern Ireland to hear the views of disabled people. The meetings were held in Manchester, Glasgow, Cardiff and Belfast.
8.8	Ofcom would like to thank Inclusion Scotland, Disability Wales, Disability Action Belfast and the Greater Manchester Coalition of Disabled People for helping to organise these focus groups.

	Section 9
9	Ofcom's disability equality priorities
9.1	After discussions with, and research amongst disabled people across the UK as well as colleagues at Ofcom, Ofcom has identified seven priorities.
	Access  
9.2	There are issues around access to communications for disabled people, particularly with regard to the universal service review in telecoms and access to television, especially the preparations for digital switchover.
9.3	In the run up to digital switchover, the delivery of access services over digital platforms remains a potential area of concern. Disabled people need to receive timely advice on accessible digital equipment and support during the switchover process.
9.4	Audio description and subtitling are the key ways in which people with visual or hearing impairments can access television. In its Code on Television Access Services, Ofcom has stated that it expects broadcasters to use reasonable endeavours to ensure that the subtitling, signing and audio description accompanying the programmes included in their services is made available to the greatest number of viewers.
9.5	The accessibility of electronic programme guides (EPGS) to blind people and those with visual impairments is an ongoing issue. Ofcom’s work on electronic programme guides will ensure statutory obligations on accessibility features for people with hearing and visual impairments are effectively implemented.
9.6	Access to communications services can be particularly difficult for those on low incomes, which includes a disproportionate number of disabled people. As a consequence, sections of society risk being excluded from accessing certain services based largely on their cost.
9.7	According to the Broadcasting and Creative Industries Disability Network, there is also a growing desire among disabled people to access the media - in studio audiences, in creative roles such as acting, writing and directing, as game show contestants and as programme contributors as well as in corporate positions such as in accounting, legal services, marketing and senior management.
Equipment
9.8	The design of equipment and its ease of use is an issue of particular importance affecting disabled people's access to electronic communications. Equipment can sometimes create barriers to participation by disabled people. For example, many of the latest mobile phones are not compatible with induction loops and do not come with textphone software as standard; some digital television receiver boxes may be harder to set up than others and may not be compatible with disability access services provided by broadcasters. 
9.9	Ofcom has a duty under the Communications Act to encourage the design and development of communications equipment that are easy for the widest range of consumers (including disabled people) to use. Ofcom is already engaged in a wide range of activities including research into the usability of digital television receiver equipment. The report includes good practice design checklists for easy to use and easy to set-up domestic digital television equipment.
	Media literacy  
9.10	Electronic communications networks play a central role in daily life. They underpin all businesses and are central to the workings of a modern democracy. Ofcom’s definition of media literacy, developed after formal consultation with stakeholders, is ‘the ability to access, understand and create communications in a variety of contexts’. Media literacy gives people the confidence and knowledge to get the most out of the many media platforms that now exist.
9.11	When compared to all adults, disabled people have lower levels of competence in using electronic media. The greatest difference in levels of competence relates to the internet, where the measure for adults with a disability is at 68% of the maximum potential, compared to 76% for the wider population.
9.12	Relatively few mobile phone owners with a disability - 15% - demonstrate knowledge of the content controls available on the most recent mobile phones. This measure is at almost the same level all mobile phone owners, with only 17% aware of the availability of these relatively new controls.
9.13	The measures relating to content creation are internet and PC-based. Current levels of content creation amongst disabled people aged under 65 with internet access are low, at 10% of the maximum potential. This measure is lower than that of the equivalent age group of all UK adults with internet access (15%).
9.14	Ofcom will work with stakeholders to help focus on the present and future media literacy needs of all members of society. There are many stakeholders who have a key role to play in the promotion of media literacy skills, knowledge and understanding in both adults and children. These include content producers, broadcasters, platform and network providers, educators, Government departments, parents, children’s charities and other organisations. Ofcom's principal role will be to help provide leadership and leverage in the promotion of media literacy.
	Content and standards
9.15	The way disabled people are portrayed in broadcast media is a significant influencing factor in determining public attitudes towards disabled individuals, how disabled people feel about themselves and whether they feel included in society.
9.16	ACOD has raised concerns about the portrayal (or lack) of disabled people on radio and television. Furthermore, the committee felt that people with learning disabilities and those with mental health issues are particularly subject to negative portrayal in broadcast media when they do appear.
9.17	According to Ofcom's research, perceived hurdles to inclusion include society’s attitudinal bias towards physical attractiveness, leading to the rejection of groups with disabilities. Findings indicate that 46% of those who reported negative attitudes towards disabled people had their view influenced by what they had seen on television. 
9.18	Use of derogatory terms for disabled people can amount to a breach of the Ofcom Broadcasting Code. Ofcom will continue to enforce content regulation rules regarding the portrayal of disabled people on television and radio. It will ensure that that generally accepted standards are applied to the content of TV and radio services so as to provide adequate protection for members of the public from the inclusion of offensive and harmful material. 
	Information services and complaints
9.19	One of the barriers for disabled people accessing Ofcom's services can be a lack of clear and appropriate information. All citizens and consumers have the right to access and understand full, accurate and timely information. The provision of appropriate communication support to users of public services is an issue of equality of opportunity. It helps remove discriminatory barriers to full participation in society. 
9.20	In addition to its spectrum management responsibilities, one of Ofcom's main public roles is the investigation of complaints about television, radio and telecommunications provision. To deliver this service effectively Ofcom needs to ensure that it provides information in a manner which is accessible to the UK public, including disabled citizens.
	Participation and consultation
9.21	Ofcom's statutory committees and boards have relatively limited disability representation when compared to the working population at large. In order to ensure the needs and concerns of disabled consumers fully inform its decision making process, Ofcom is actively seeking to recruit further disabled members to these committees and boards. 
9.22	Ofcom understands that disabled people may have taken a different education path or had career breaks, which represent a career profile different from the norm. Ofcom will take this into account when selecting disabled members to its committees and boards.
9.23	In developing policy that may affect disabled people, Ofcom has a duty to engage and consult with this community. Ofcom carries out periodic wider consultation with disability consumer groups on issues of concern to them.
	Employment and training in the communications industry
9.24	Disabled people continue to face disadvantage and discrimination in employment. In 2005, the employment rate of disabled people was 47%, compared to 75% for wider UK society. Research indicates that disabled people of all ages are significantly under-represented in the media workforce either as part of the programme-making process or in other roles. 
9.25	For disabled people with associated health issues there might be difficulties in accessing employment opportunities because of gaps in their employment history. Many disabled people do not have conventional career paths and this can be detrimental to their efforts to secure employment.
9.26	The Workforce Census conducted by Skillset in 2004 of 2,878 companies in the sector indicated that only 1.3% of people working in broadcasting are disabled (this represents a slight increase from 1% in 2002). The 2005 Skillset Survey of 7,000 individuals working in the audio visual industries (both employees and freelancers) also indicated that employers underestimate the number of disabled people, since 5% of this workforce reported having a disability. Even so, the Disability Rights Commission estimate that 13% of disabled people of working age are in employment, so the broadcasting sector is well below the national average.
	Procurement
9.27	Procurement is a key area where one organisation can influence another's diversity practice and ensure that services delivered equitably. Over the past decade, it has become the norm for companies are to outsource some of their functions to contract other organisations to deliver services. Procurement policy, therefore, provides an opportunity to encourage other companies to adopt policies which promote equality of opportunity. 
9.28	Ofcom shall seek to ensure that all suppliers it uses have an equal opportunities policy or statement that includes disability equality. 
9.29	The EU Public Procurement Directive, implemented in UK law in January 2006, introduced a new provision allowing contracting authorities like Ofcom to reserve contracts for supported factories and businesses (those which have at least 50% disabled employees). This is a further option for Ofcom to promote disability equality through its procurement practice. In addition to reserving contracts, Ofcom can try to ensure that there are no barriers to the participation of supported businesses in procurement exercises more generally, in competition with other suppliers and service providers.
	Section 10
10	Action plan
10.1	This action plan outlines the agreed work on equality for disabled people as it relates to Ofcom's role as the UK's electronic communications regulator and as an employer. The priorities identified during the involvement process are aligned to Ofcom's aims and activities identified in its Annual Plan to ensure that actions to address disability equality are part of its daily activities.
10.2	Progress on the disability action plan will be reviewed and reported annually. Ofcom will monitor the actions that have been identified for each year; what has been achieved and where there has been slippage or no progress has been made, understand the reasons for this and revise timescales. New actions might be included depending on developments within the electronics communication industry and any changes in priorities that might be identified subsequent to the publication of this action plan.

Ofcom Aim/ Activity	DES Priority	Action / Project Description	Owner	Year	
Addressing citizen and consumer 	Information services and complaints	Clarify the way in which the communications industry serves the interests of disabled citizens	Claudio Pollack
(Director of Consumer Policy) 	2007	
issues		As part of the Consumer Complaints Review, assess to what extent disabled consumers are able to access complaint systems and their knowledge of their rights. 	Rosalind Stevens-Strohmann (Competition Policy Manager)	2008	
	Access	Review communications networks and services and assess the barriers to access and inclusion, which will include use of services by disabled consumers.	Alan Pridmore
(Manager, Consumer Policy)	2007	
		Ensure broadcasters meet their obligations with respect to subtitling, signing and audio description.	Peter Bourton
(Senior Policy Executive)	2006-2009	
		Promote greater awareness of audio description amongst potential users.	Peter Bourton
(Senior Policy Executive)		
		Encourage the availability of easily usable apparatus for communications services.	Bradley Brady
(Consumer Policy Manager)	2007	
		Ensure that forthcoming EU Communications Framework Review facilitates specific actions on access including addressing access issues for disabled consumers.	Alex Blowers
(Head of International)	2007-2008	
		Encourage manufacturers to develop domestic electronic communications equipment which is capable of being used with ease, and without modification, by the widest possible range of individuals, including those with disabilities.	David Harrison
(Senior Technologist New Technologies)	2007-2009	
	Media literacy	Promote media literacy through dialogue with disabled stakeholders. 	Peter Davies
(Director of Radio & Multimedia)	2006-2009	
		Seed fund Sky to produce weekly news programme for people with learning disabilities to promote media literacy amongst this group 	Peter Davies
(Director of Radio & Multimedia)	2007	
	Employment and training	Encourage a best-practice approach to equal opportunities in the broadcasting sector. Ensure broadcasters make arrangements for promoting disability equality in employment and training.	Juliette Brown
(Programme Diversity & Training Advisor)	2006-2009	
	Content and standards (portrayal)	Ensure that generally accepted standards are applied to the contents of TV and radio services so as to provide adequate protection for members of the public from the inclusion of offensive and harmful material. These generally accepted standards would include the portrayal of disabled people and other groups in society.  	Christopher Banatvala 
(Director of Standards)	2006-2009	
	Content and standards (Public Service Broadcasting)	Ensure that - among other criteria - Public Service Broadcasting services include what appears to Ofcom to be a sufficient quantity of programmes that reflect the lives and concerns of different communities, cultural interests and traditions (including disabled people) within the UK and locally in different parts of the UK.	Stephanie Peat 
(Programme Executive)	2006 	
Encouraging innovation	Access	Oversee Ofcom’s role in the planning and implementation of digital TV switchover, including monitoring disabled consumer issues relating to switchover (including liaison with ACOD); publishing research on specific switchover-related issues during the course of the year; and ensuring that work is co-ordinated effectively with Digital UK, the Government and other stakeholders.	Jim Egan
(Strategy Director)	2007-2009	
Promoting competition	Access	Evaluate the impact of the BT Undertakings, including the effect this will have on disabled citizens, in particular whether the expected benefits for consumers materialise.	James Thickett
(Acting Head of Research)	2007	
		Ensure Voice Over Internet Protocol services policy takes into account the needs of disabled consumers.	Andrew Heaney
(Director of Competition Policy)	2008	
Pursuing better regulation	Participation and consultation	Embed disability equality into Ofcom's approach to impact assessments in order to improve policy decisions.	Alistair Bridge
(Policy Development Manager)	2007	
Engaging internationally	Content and standards (portrayal)	Ensure that the development of the revised EU Directive on TV and other audio-visual content reflects Ofcom's diversity aspirations and those of its disabled stakeholders	Alex Blowers
(Director of International)	2006-2009	
Providing key services	Access	Make all publications available in alternative formats and languages upon request and free of charge.	Andy Bailey
(Head of Design & Publications)	2006-2009	
	Information services and complaints	Seek to ensure the Ofcom website conforms to best practice accessibility guidelines.	Andy Bailey
(Head of Design & Publications)	2006-2009	
	Information services and complaints	Respond appropriately to requests for alternative formats resulting from enquiries from disabled citizens and consumers (via letter, email and Ofcom's website) in relation to broadcasting, licensing, digital TV switchover, telecoms and spectrum.	Jackie Caspary
(Director, Central Operations)	2006-2009	
Understanding the sector and our stakeholders	Media literacy	Carry out a second survey to identify trends and issues related to disabled citizens and the availability, take-up and consumption of communications services.	Alison Preston
(Senior Research Associate)	2009	
Operate effectively	Access	Modernise the field force teams and improve delivery, governance and quality of service to disabled citizens.
	Robert Thelen-Bartholomew
(Head of Field Operations)	2006-2009	
	Participation and consultation	Undertake disability impact assessment on policies relevant to disability equality	Dougal Scott
(Director of Policy Development)	2007-2009	
		Continue to recruit more disabled people to Ofcom's decision making boards	Graham Howell
(Board Secretary)	2008	
		Support for the Advisory Committee on Older and Disabled People	Graham Howell
(Board Secretary)	2006-2009	
	Employment and training	Be more creative and pro-active in recruiting and developing disabled colleagues	Janet Campbell
(HR Director)	2006-2009	
		Improve the accuracy of the declaration rate for disabled colleagues by raising awareness of what is defined as a disability under the DDA	Janet Campbell
(HR Director)	2007	
		Ensure colleagues receive the appropriate training on their duties under the DDA 	Keeley Addison
(Head of Professional Development)	2007-2008	
	Procurement	Seek to ensure that the companies Ofcom buys its goods and services from have equal opportunities policies that include disability equality.	David Rickard
(Head of Procurement)	2007	
		Section 11
11	Gathering and using information
11.1	Evidence gathering is part of the process of achieving greater equality for disabled people. However, the process of information gathering is not an end in itself, but is a vital mechanism to enable Ofcom to make better decisions about what actions would best improve disability equality. The information will allow Ofcom to:
·	assess its performance;
·	carry out effective impact assessments;
·	identify barriers to good performance and actions for improving;
·	review progress and adjust actions as appropriate;
·	set targets for improving outcomes; and
·	benchmark against other comparable authorities.
11.2	Ofcom collects evidence to meet its responsibilities under Section 3 of the Communications Act 2003, which requires Ofcom to have regard for the needs of disabled people.
11.3	Ofcom undertakes research into disabled citizens' use and participation in electronic communications to help it understand the priorities for action amongst this group. It monitors barriers and differences in outcomes for disabled people in accessing communications technology. Recommendations from these information gathering activities are carried forward into business planning activities and action plans.
11.4	Ofcom monitors its recruitment process and workforce profile to assess its effectiveness in attracting talented disabled candidates into the organisation. It is also able to identify any support, requirements and adjustments that might be needed by disabled colleagues to enable them to perform their roles effectively.
11.5	Ofcom will use information gathered to review its effectiveness in tackling disability equality and the implementation of its action plan.
	Section 12
12	Impact assessment
12.1	Under Section 7 of the Communications Act, Ofcom has a regulatory duty to carry out an Impact Assessment (IA) as part of its regulatory decision-making process. As the decisions which Ofcom makes can impose significant costs on its stakeholders, it is important for Ofcom to think very carefully before adding to the burden of regulation. 
12.2	Impact Assessments form a key part of best practice policy making and help inform different options for regulation. 
12.3	Impact Assessments are also useful in reviewing existing regulation. They provide a framework for weighing up the costs and benefits of removing regulation, as well as analysing other options. Ofcom has decided to incorporate disability and other equality impact assessments into the existing process. 
12.4	Impact Assessments are carried out in relation to the great majority of Ofcom's policy decisions. This is a significant commitment, but in carrying out Impact Assessments, Ofcom will be guided by the principle of proportionality. This means that a decision which is likely to have a wide-ranging impact and/or impose substantial costs on stakeholders will have a more comprehensive Impact Assessment than a decision which will have a less significant impact. 
12.5	Another benefit of carrying out Impact Assessments is that they provide a mechanism for considering the impact of Ofcom's work on the interests of the full range of its stakeholders, including different groups of citizens and consumers. In some cases, for example, Ofcom will need to consider the impact of policy options on the interests of people living in different parts of the country or people who are elderly, disabled or on low incomes. 
12.6	Ofcom's stakeholders play an important part in the Impact Assessment process as often they will hold the information needed to carry out the analysis. Generally, therefore, Ofcom will seek to engage with stakeholders at an early stage.
	
	Section 13
13	Implementing the Disability Equality Scheme
	Who is responsible for the DES?
13.1	All Ofcom colleagues are responsible for implementing this DES. However, the Ofcom Board is ultimately responsible for the delivery of the organisation's statutory responsibilities. Its role is to guide the organisation to ensure that its goals are achieved in the most effective and efficient manner. 
13.2	Members of Ofcom's boards, panels and advisory committees also have a role to play in helping Ofcom to meet its duty to promote equality for disabled people.
13.3	The Diversity Champion will be responsible for the operational implementation of the DES. 
13.4	The Diversity Working Group will work to ensure that effective action is taken to promote disability equality and reduce disadvantage. 
13.5	This DES is a public document and Ofcom will be answerable to the public for delivering the programme set out in the scheme.
	Annual review and reporting
13.6	Ofcom will review progress on the DES and the activities in the action plan annually and provide a summary of work for inclusion in its Annual Report. This will include details of the evidence used to monitor performance on disability equality, and a summary of what this indicates. 
13.7	In line with the DDA, a more formal three year review will take place in 2009, with the involvement of disabled people to evaluate Ofcom's work against the goals set within the action plan. Ofcom will also evaluate the content, structure and priorities of the DES. Particular focus will be placed on whether the priorities are still relevant and appropriate, how successfully disabled people were involved, the way information was gathered and used, and the process for carrying out Impact Assessment.

	Section 14
14	How to contact Ofcom
14.1	If you are a consumer, viewer or listener and you want to complain to Ofcom, you can make contact through the website at www.ofcom.org.uk. 
14.2	You can also contact Ofcom by phone between 9:00am and 5:30pm, Monday to Friday. The number for the Ofcom Contact Centre is 020 7981 3040. 
14.3	If you are deaf or speech-impaired, you can use the Text phone number 020 7981 3043. Please note that this number only works with special equipment used by people who are deaf or hard of hearing. 
14.4	The fax number is 020 7981 3334
14.5	Ofcom handles complaints about the following:
·	Problems with your landline phone 
o	Phone bill, tariff and contract issues 
o	Privacy issues - nuisance and sales calls 
o	Customer service issues 
o	Problems or delays with repairs
·	Problems with your mobile phone 
o	Phone bill, tariff and contract issues 
o	Privacy issues - nuisance and sales calls 
o	Customer service issues
·	Problems with your internet service 
o	Internet service bill & contract issues 
o	Privacy issues - spam emails 
o	Customer service issues 
o	Problems switching between internet service providers 
o	Quality of internet service - e.g speed
·	Programmes on TV/radio 
o	A specific programme 
o	Subtitling, signing or audio description 
o	Scheduling
·	Advertising and sponsorship on TV/radio 
o	A specific advert 
o	Sponsorship and product placement
·	Digital TV/radio availability 
·	TV/radio interference and reception 
o	TV interference or reception problems 
o	Radio interference/reception problems 
o	Interference to Ofcom radio communications licensed services 
o	Digital TV/radio availability
·	Complaints about Ofcom
o	Ofcom does its best to meet the needs of businesses, consumers, viewers and listeners. However, sometimes things can go wrong - or Ofcom can fall short of its own standards. A complaint about Ofcom can be made through the website or by phoning the Contact Centre. 
	Important note about Data Protection
14.6	Ofcom complies with the Data Protection Act. If you are making a complaint Ofcom may pass on your details, as appropriate, for the purposes of dealing with your complaint.