Accessibility Strategy

Hull City Council is committed to working with schools and multi academy trusts, through the learning partnership, to continually review key services which are available to safeguard learners and support those with Special Educational Needs and/or Disability (SEND). We aspire that by following a graduated approach, we ensure that learning is accessible and that provision is targeted appropriately to address local needs.

By working together with families and communities, we want all children and young people aged 0 to 25 years old with SEND to be safe, do well in education, make friends and build strong, lasting relationships within their local community. Through high quality provision of support, learners develop their independence, knowing how to keep themselves safe and make healthy lifestyle choices, in preparation to succeed in society. As young adults, we want each young person to have the necessary skills and qualifications that will give them the confidence to be ambitious and to achieve their aspirations.

We want all children and young people in Hull aged 0 to 25 years old with SEND to be safe, do well in education, make friends and build strong, lasting relationships within their local community.

Introduction

This accessibility strategy sets out the approach that Hull City Council is taking to increase access to education for disabled children and young people, so that they can benefit from educational provision to the same extent that children without disabilities can.

All local authorities must have an accessibility strategy for the schools it is responsible for, for example, local authority-maintained schools. This is a requirement of law, the Equality Act 2010.

Accessibility strategies do not apply to academies or free schools. However, all schools, including academies and free schools, must have an accessibility plan which is based upon the same principles as an accessibility strategy.

An accessibility strategy explains how, over time, the local authority will support the schools it is responsible for to -

increase access to the curriculum for disabled pupils
improve the physical environment of schools to increase access for disabled pupils
make written information more accessible to disabled pupils by providing information in a range of different ways

Disability in its broadest sense covers -

physical impairments
learning difficulties
sensory impairments
mental impairments

Under the Equality Act, disability is a protected characteristic. A person has a disability if they have a physical or mental impairment that has a substantial and long-term adverse effect on their ability to carry out normal day to day activities.

“Substantial” means more than trivial
“Adverse” means unfavourable or injurious
“Long term” means if it lasts or is likely to last 12 months or more

Legislation

The council is required to have an accessibility strategy in which it promotes better access for disabled pupils at school and its local community, under the planning duty in the Equality Act 2010, Part 6, Section 88 (Schedule 10) - Equality Act 2010

Unlike the rest of the Equality Act, which has a focus on equal treatment, the sections relating to disability are different and recognise that a person with a disability may have to be treated more favourably than someone who does not, to avoid substantial disadvantage. Substantial is anything more than minor or trivial.

Reasonable adjustments

Taking reasonable steps to avoid substantial disadvantage is often known as the ‘reasonable adjustments’ duty. All providers must adhere to this duty. When deciding if a reasonable adjustment is necessary, schools need to consider potential impact on disabled pupils in terms of time and effort, inconvenience, indignity and discomfort, loss of opportunity and diminished progress.

It means that where a disabled person is at a substantial disadvantage in comparison with people who are not disabled, they should take reasonable steps to remove the disadvantage by -

changing provisions, criteria or practices
altering, removing or providing a reasonable alternative means of avoiding physical features
providing auxiliary aids

Schools do not have to consider physical features as part of their reasonable adjustment duty. Instead, they have an additional duty to plan better access for disabled pupils, generally through their accessibility plan. The law on reasonable adjustments is anticipatory; it requires settings to consider the needs of potential disabled pupils as well as those currently attending the setting.

Some disabled children will require individualised equipment to enable access to the curriculum: smaller items such as pencil grips and writing slopes, and more specialist equipment such as height adjustable furniture, toilet seats and supportive seating. Such equipment will be provided by the settings as part of the reasonable adjustment’s duty (auxiliary aids).

These planning duties therefore do not apply to Further Education, Higher Education or Early Years settings (unless constituted as a school). For them, the requirement to remove physical barriers is contained within the reasonable adjustment’s duty.

Auxiliary aids

In September 2012, the duty to provide auxiliary aids and services (including specialist equipment, which could include laptops and tablets) was extended to include schools. This places schools under a duty to provide aids and services where it is reasonable and where it would prevent a pupil with a disability from being put at a substantial disadvantage when compared to their non-disabled peers.

However, if an auxiliary aid is not provided under the SEN regime, then it should not be assumed that it must be provided as a reasonable adjustment. Similarly, whilst schools and local authorities are under the same reasonable adjustment duty, there should be no assumption that where it is unreasonable for a school to provide an auxiliary aid or service, for example, on cost grounds, it would then be reasonable for the local authority to provide it. All decisions depend on the facts of each case.

Failure to make a reasonable adjustment is a form of discrimination under the Equality Act.

Direct discrimination

Direct discrimination is the act of treating someone less favourably than someone else has been treated (or would be treated) because the person belongs to one of the protected groups.

Indirect discrimination

Indirect discrimination describes situations which occur when an organisation makes a decision, or puts in place a particular policy, practice or procedure, which appears to treat everyone equally, but which in practice leads to people from a particular protected group being treated less favourably than others.

The General Equality Duty

The Equality Act (2010) (the Act) places a general duty on all public sector organisations to have due regard to the need to -

eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Act
advance equality of opportunity between people who share a protected characteristic and those who do not
foster good relations between people who share a protected characteristic and those who do not

The Act explains that having due regard for advancing equality involves -

removing or minimising disadvantages suffered by people due to their protected characteristics
taking steps to meet the needs of people from protected groups, where these are different from the needs of other people
encouraging people from protected groups to participate in public life or in other activities where their participation is disproportionately low

Protected characteristics are qualities shared by everybody. They are age, disability, gender reassignment, marriage or civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation.

The Specific Duty

In addition to the General Duty, there is a Specific Duty for schools to demonstrate how they are meeting the General Duty. The main requirement is for schools to prepare and publish information, and from that information publish equality objectives. In effect, the General Duty sets out what schools do, with the Specific Duty setting out how schools must do it and what they need to record as evidence of what they have done.

Duties of schools

All schools should have due regard to this Accessibility Strategy and use it to inform their Accessibility Plan that shows how, over time, access to education for disabled pupils will be improved. Schools should publish their Accessibility Plans on the school website with a clear link between the Accessibility Plan and the SEND Information Report.

Hard copies of the Accessibility Plan must be provided on request.

Local context

Kingston Upon Hull (often shortened to Hull) is a port city which lies upon the River Hull on the northern bank of the Humber Estuary. Covering an area of approximately 28 square miles, the latest Office for National Statistics (ONS) is 267,100 in 2021.

The city has a total of 97 educational establishments, including 71 primary schools, 13 secondary schools, 6 special schools and 7 Pupil Referral Units (PRU)/Alternative Provision (AP) providers. These establishments provide for a total of 43,200 pupils.
13.7 % of the city’s school population receive SEN Support, and a further 4.6% of pupils have an Education, Health and Care (EHC) plan.

The city supports 2,022 pupils with Education, Health, and Care plans.
The city’s special schools have 746 pupils on roll, all of whom have an Education, Health, and Care plan.
The city’s Pupil Referral Units/Alternative Provision providers have 354 pupils on roll, 228 of which have an Education, Health and Care plan.
7,211 pupils with special educational needs are supported in mainstream provision in the city, 5,935 of which are in receipt of SEN Support and 1,276 of which have an Education, Health and Care plan.

(January 2023 School Census, DfE)

Strategy aims

Through this strategy, Hull City Council will focus on three key aims -

Increase access to the curriculum for disabled learners
Improve the physical environment of schools to increase access for disabled learners
Improve the delivery of information to disabled learners, which is readily accessible to learners who are not disabled

Whilst the accessibility strategy relates to maintained schools, many of the support arrangements made by the local authority will also benefit disabled pupils attending academies and free schools within Hull.

Curriculum accessibility

Aim 1 - Increase access to the curriculum for disabled learners

Ensuring access to the curriculum is vital in providing equal opportunities to children and young people with SEND. Schools need to consider how to improve the accessibility of the curriculum, covering teaching and learning, trips and visits, after school activities and extended school activities.

Schools are responsible for providing a broad and balanced curriculum for all pupils and play a key role in planning to increase access to the curriculum for all pupils. All schools must “use their best endeavours” to provide “high quality teaching that is differentiated and personalised” and which should “meet the individual needs of the majority of children and young people.” (SEN Code of Practice 1.24).

The council and its partners provide a range of services to support schools in making inclusive and accessible provision. Details are available on this website.

Hull City Council, on behalf of schools, commission a mixture of both internal and external providers to deliver services to settings to support learners to access their education. These services are detailed below.

Integrated Physical and Sensory Service (IPaSS) - Supporting learners with physical disabilities, hearing impairments or vision impairments
The Language Unit - Supporting learners with speech, language and communication difficulties
Hull City Psychological Service - Educational Psychologist (EP) Service supporting schools through termly psychological consultation meetings and a wider traded service
Social Communication and Interaction Outreach Service - Supporting learners with autism and neurodiversity (aged 4 to 16 years old)
Early Communication Outreach Service - Supporting learners with early stages of communication and interaction (aged 4 to 7 years old predominantly)
Steps to Success Outreach Service - Supporting learners with social, emotional, mental health difficulties (aged 4 to 12 years old)
Sullivan Centre - Supporting learners with significant health needs (age 5 to 16 years old)

Specific provision within the mainstream is also available through resource bases at -

Bricknell Primary School
Christopher Pickering Primary School
Spring Cottage Primary School
Wansbeck Primary School
Ings Primary School
Broadacre Primary School
Kelvin Hall Secondary School
Sirius West Secondary School

As part of the SEND Sufficiency Strategy, work is being progressed to develop more resource bases and SEN Units attached to mainstream settings to increase access to the curriculum for learners with SEND and disabilities.

Specialist provision is available in the city’s special schools -

Ganton School
Tweendykes School
Frederick Holmes School
Northcott School
Oakfield School
Bridgeview School

In addition to the above, the city also has Euler, which is a hybrid alternative provision (AP) school with a specialist designation.

In some circumstances, National Health Service (NHS) services also support access to the curriculum for individual pupils, including speech and language therapy, occupational therapy (for example, specialist seating assessment), physiotherapy and emotional health and wellbeing.

Where it is thought a child or young person may require additional equipment to enable their access to the curriculum, an assessment of need may be carried out by either IPaSS or the local community therapy service if the case is open to the service.

Any recommended equipment will then be procured and provided through the Education Equipment Panel process. Currently, schools are required to fund equipment up to the cost of £500.

Services are also available from a range of registered AP settings -

Whitehouse
Boulevard Centre
Sullivan Centre
Aspire
Rise Academy
Compass Academy

Advice on sources of other learning support is available on this website.

Environment accessibility

Aim 2 - Improve the physical environment of schools to increase access for disabled learners

Reasonable adjustments may be needed to ensure equality of access to the environment, including the creation of safe spaces, calming areas, and individual workstations.

Support services from health, social care and education services, such as IPaSS, occupational therapy and physiotherapy, are available to advise educational settings about suitable and reasonable adaptations to the inside and outside environment to help include pupils with SEND.

For learner specific environmental adaptations, an assessment of need will be carried out by IPaSS. A report will be provided outlining the adaptations recommended to aid accessibility. This may include information on obstructions, acoustic considerations or lighting matters, dependent on the child or young person’s needs. The provision of recommended adaptations should then be progressed by the setting.

Additionally, for learners who have physical disabilities and who may require support for moving and handling. Settings can make a referral to the IPaSS physical disability team, who are able to assess the individual’s needs, produce a report and make appropriate recommendations.

Where pupil specific moving and handling needs are identified, safe hoisting and safe use of equipment instruction is provided. The moving and handling training course can also be accessed from IPaSS as a traded service. The physical disability team from within IPaSS are also able to provide support to educational settings to write care plans and Personal Emergency Evacuation Plans (PEEPs).

Information accessibility

Aim 3 - Improve the delivery of information to disabled learners, which is readily accessible to learners who are not disabled

This aim focuses on the development of planning to make information (normally provided by the school to its pupils) accessible to disabled pupils. Information which is produced should take into account pupils’ disabilities, pupils' and parents' preferred formats and be made available within a reasonable timeframe.

Hull City Council has a clear corporate writing style which outlines suitable fonts, layout and formatting which are intended to support the accessibility of written information provided by the local authority. Hull City Council also provide documents in alternative formats, including braille.

IPaSS offers specialist advice, training and support to schools to ensure that information is accessible for learners with a sensory impairment.

The Hull SEND Local Offer website has supportive features which allow the formatting of the website to be changed to support accessibility, as well as the support of BrowseAloud, which supports access for those with difficulties such as dyslexia, visual impairments, or English as an additional language.

For parents of SEND pupils, they should be made aware by schools of this website, as well as KIDS - Hull Special Educational Needs and Disabilities Information, Advice and Support Service (SENDIASS), who are available to support parents, carers and young people with SEND. SENDIASS also provide advocacy and encourages partnership working.

Evaluation and review - accessibility consultation

To evaluate the previous accessibility strategy, pupil, parent, and professional views were sought. This enabled the local authority to review the 2020 to 2023 strategy, considering the lived experiences of those involved.

Both questionnaires covered access to -

the curriculum
physical environment
information

Taking their views into account and valuing their expertise, we have been able to update the strategy and outline new measures needed to increase accessibility to curriculum, environment and information.

Pupil views

Pupils were asked to answer questions on a scale of 1 to 4 -

Completely disagree/never
Somewhat disagree/sometimes
Somewhat agree/sometimes
Completely disagree/always

There were also some open-ended questions.

Parent and professional (education/health/social care) views

A questionnaire with open-ended questions was used.

Access to the curriculum

Pupils

What’s working well

72% stated that they felt welcome in their setting
62% felt they were included in all lessons and encouraged to take part

What we need to change

50% felt that they had opportunities to attend additional activities and clubs
42% agreed that they were asked their opinions on the support they needed
43% were confident to ask for help and knew who they could turn to
36% felt they were listened to and respected

You (Parents, carers, and professionals)

What’s working well

“Resource provision classrooms in mainstream schools - more of them and more spaces.”
“Pupil voice- our student council are represented with inclusion and equality at the centre of all decisions.”
“Schools setting up supported pathways and being flexible with their education approach.”
“Enhanced provision classes where adult support does not need to be directed to a specific child because the teaching is all appropriate in delivery speed, content, and approach. This allows children to function at their best and be more independent.”
“Trauma informed awareness.”

What we need to change

“Lack of places in resource provisions.”
“The time frame of the Education Health Care (EHC) plan process has not been within 20 weeks.”
“Staff not trained in SEN; this should be mandatory.”
“We seem to have gone backwards with how we support learners with additional needs. A large majority are stating they cannot meet needs unless they have an additional member of staff. There is no evidence of this being required in the EHC Plan.”
“Sensory processing difficulties/ Social emotional and mental health (SEMH) are not well supported, especially in up-and-coming increased class sizes due to massive budget pressures, lack of spaces within primary and massively reduced levels of support staff to deliver or support intervention.”
“Different approaches from different schools/trusts.”
“There is simply not enough specialist adult support to meet the needs of all pupils.”
“Old school discipline is NOT suitable for pupils with SEND.”
“Listen to parents. Social model, not medical model.”

Local Authority will...

Provide ongoing guidance and training to schools to support them in the effective implementation of the Equality Act 2010 and Children and Families Act 2014 (Special Educational Needs Coordinator (SENCo) training and reminders at key points in relation to processes).
Regularly review the school’s compliance and inclusion (SEND Reviews, Annual Reviews, Education, Health and Care Needs Assessment (EHCNA) Reviews and consultation audits, analysis of suspensions and exclusions).
Support the acquisition of specialist skills and expertise within, across and between mainstream settings and focus support offers to schools on high incidence areas of need, for example, mental health, neurodiversity. (Graduated approach (GA) guidance and outreach service support, including the online platform).
Ensure availability of continued professional development (CPD) opportunities for school staff to support and enhance the understanding of accessibility in the curriculum (through the Outreach Partnership).
Provide opportunities for capacity building in schools through advice and support available (through use of the outreach service, neuro front door consultations, and link EP meetings).
Identify children and young people with SEND at the earliest stage, including through universal health services (promotion of the GA and mapping of services for signposting).
Continue to develop and strengthen the multi-agency working with the neurodiversity service (termly meetings and representation at the SENCO Forums).
Provide opportunities for SENCOs to regularly meet, share good practice and keep up to date with new developments (SENCO Forums and Resource Base and SEND Unit Partnership working group).
Promote and strengthen the understanding of Early Help, ensuring that professionals across services will
recognise emerging needs and take preventative steps.
Encourage liaison between schools to ensure good transition (promotion of the Transition Protocol).
Will value the expertise of children, young people and their families and use feedback from their lived experiences to inform the development of future practices and provisions (through promotion of the coproduction values).
Develop and publish a Local Offer of services and provision that is available to children and young people with SEND, in liaison with families, health and schools.
Ensure the views of the families are sought and used to develop the Hull SEND Local Offer website.
Continue to work with settings to develop resource bases and units to meet the needs of pupils.
Endeavour to work within statutory timeframes with good communication during processes.
Continue to develop strong partnerships across the Learning Partnership for greater consistency across the city.

We hope schools/settings will...

Support all pupils to have positive attitudes towards disability and actively promote disability awareness within their settings.
Develop policies that consider the different needs and disabilities and adjust accordingly to ensure no discrimination. Compliance with the Equality Act 2010 and the Children and Families Act 2014.
Ensure early intervention is a priority and that disabled pupils and those with SEN are not at a disadvantage. This will be done by delivering the curriculum in line with Graduated Approach guidance with a focus on quality first teaching, reasonable adjustments and targeted interventions.
Strong Assess-Plan-Do-Review (APDR) is used to support pupils at the earliest stage.
Ensure equity and inclusion with no pupil at a disadvantage when it comes to school trips and any curriculum enhancing events/ activities. SEND pupil representation is equal.
Provide regular and effective professional development for staff and governors.
Ensure that whole school training and individual staff training reflect the support needs of disabled pupils. Work in partnership with parents and professionals.
Ensure effective support for vulnerable children in transition (complete the SEND/vulnerable forms and follow the Transition Protocol with strong communication and planning).
Apply funding appropriately to ensure that vulnerable groups are not disadvantaged in relation to non-vulnerable groups (use of Element 2 funding).
Listen to the voice of the child and young person and ensure they are appropriately engaged in decisions made about their educational provision.

Access to the environment

Pupils

What’s working well

71% stated that they felt the physical environment was suitable for their needs
“I have a range of people I can speak to if things aren't going well. Places to chill out if I need it."
“I feel better here as I have loads of friends and a teacher helps.”

What we need to change

42% felt that reasonable adjustments were planned in advance.
“Policies that show an understanding of my neurodiversity and sensory needs.”

You (Parents/carers and professionals)

What’s working well

“Working closely with IPaSS has allowed children with hearing impairment full access to the curriculum.”
“Current work with the school nursing team for those children with Individual Health care plans, ensuring inclusive practice and adaptations wherever possible.”
“My son has been offered a lift pass, leaving class a bit earlier to move around at a quieter time. However, he won't take them as he doesn't want to appear different, but I feel the school have been proactive and supportive with the options being available. He was also given laptop/typing time last year.”

What needs to change

“Smaller schools would really help. Busy places are much more overwhelming, which can hinder motor skills. Hand pain should be taken seriously and not just seen as ‘The child trying to avoid having to write'. Pupils should be offered aids such as pencil grips, tablets or laptops with assistive technology if writing is painful. PE should be adapted so that it isn't painful or scary.”
“All schools should have a changing room as there is a significant need with children not being toilet trained going into school.”
“Inclusive provision for all, sensory spaces, calming spaces, adapted classroom practised.”

The following were deemed by parents and professionals as reasonable adjustments or auxiliary aids that they would expect to be available -

Process time
Support/spaces for unstructured times
Range of methods for demonstrating understanding and recording methods
Work adapted and a range of scaffolds/supports
Pre-teaching
Routines and structures are consistent and visually supported
Uniform adjustments where necessary
Writing aids
Sensory equipment and spaces.

All the above (and more) have been included in our Graduated Approach Guidance for schools to outline our expectations in terms of Quality First Teaching (adaptive teaching) and reasonable adjustments.

Local Authority will...

Plan new buildings and significant extensions/ adaptations that comply with accessibility requirements and enable access for individuals with physical and sensory difficulties, and where needed, those with medical conditions.
Commission audits to advise on the required adaptations and additional resources needed to accommodate children/young people with physical or sensory impairments (through IPaSS outreach).
Support schools in reviewing the physical access audit of their premises and ensuring they understand the ‘anticipatory duty’ (IPaSS recommendations).
Work with settings, the SEND Team and other local authority and externally commissioned staff to assist with issues regarding individual placements.
Promote the importance of the graduated approach and direct schools to the guidance documents to outline expectations in terms of Quality First Teaching and reasonable adjustments for the four broad areas of need.

We hope schools/settings will...

Provide auxiliary aids required to support disabled pupils in accessing the curriculum. This includes reviewing whole school and class subject resources are evaluated for their suitability to meet the needs of disabled pupils within the setting (e.g., Information and Communications Technology (ICT) equipment, textbooks, play equipment). This also includes ensuring annual service/maintenance checks are made on auxiliary aids if necessary.
Respond to the expectations set out in local and national guidance on meeting the Equality Act 2010 and Children and Families Act 2014 regarding SEND.
Carry out risk assessments for school trips to ensure they are accessible for pupils with mobility, sensory or medical difficulties.
Ensure all disabled pupils and those with special education needs must have a Personal Emergency Evacuation Plan (PEEP) written and agreed with the parent or carer. Staff will be aware of the plans and appropriately trained.
Use the local authority's graduated approach guidance for the four broad areas of need.

Access to information

Pupils

What’s working well

“Staff who understand me.”

What we need to change

50% felt that the information shared was easy to understand.
“Clear instructions.”

You (Parents/carers and professionals)

What’s working well

“Inclusion and accessibility, I feel, are high on most schools'/colleges’ agendas. This has to be a positive. Sharing this good practice with the wider community may make a difference.”
“At present, things are working well have good communication with the teachers.”
“I also feel that ongoing co-production is very empowering for families.”

What needs to change

“More visual communication around schools - pictures / visual boards.”
“All information should be available as writing, visual information (think 'easy read' format, like the NHS leaflets) and verbal/auditory.”
“Schools should make up their minds and settle on ONE method of communication. Within one school, we currently get some things communicated via an app, some via email, some via text, and some via paper forms. It's confusing and makes it more likely that information will be missed. *If one category of information doesn't apply to a family, for example, bus information for a child who doesn't take the bus, they should be able to opt out. Information overload regarding a topic that doesn't apply to the family makes it more likely they will start to routinely ignore notifications and miss actually important information.”

Local Authority will...

Ensure the Hull SEND Local Offer website is informative, helpful and easily accessible for parents and young people.
Provide information to pupils and their families in accessible formats whenever needed.
Provide advice to schools from its specialist teaching and advice service (IPaSS) about how best to support children and young people in accessing information (IPaSS offer a range of support from signing to Braille).

We hope schools/settings will...

Ensure that information made available to non-disabled pupils is made available in an accessible format for disabled peers.
Involve pupils and their families in decisions and processes regarding the accessibility of information, for example, co-production of the school’s SEN Information Report.

This strategy will cover the period 2023-2027 and will be reviewed yearly by the contributors and revised/updated as required within this period.

The overall responsibility for the evaluation and review rests with Hull City Council, with specific oversight from the SEND Strategic Board.

Whole School SEND Review visits will include a question regarding the school’s accessibility policy or plan and their implementation of the Equality Act 2010.

What we hope will happen -

We hope the Accessibility Strategy will help our children and young people with disabilities to feel welcome and included in their school or setting
We want pupils to access the curriculum and their school and college settings. They should have access to information and have all their needs met
We want them to be involved in discussions about their support, and that they are listened to and respected