Care Clarity Support & Advocacy

Accessible Information Standard Policy

Accessible Information Standard (AIS) Policy and Procedure

This policy has been reviewed with a new section on reasonable adjustments which included the NCRS flag. The policy remains appropriate and supports staff to understand and implement the principles of the NHS Accessible Information Standard. Underpinning knowledge and Further Reading links have been reviewed and updated where applicable.

Relevant Legislation

  • The Care Act 2014
  • Equality Act 2010
  • The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014
  • Mental Capacity Act 2005
  • Access to Health Records Act 1990
  • Data Protection Act 2018
  • UK GDPR
  • Public Sector Bodies (Websites and policy documentslications) (No. 2) Accessibility Regulations 2018

Further Reading

Roles Affected

  • All Staff

People Affected

  • Clients
  • Family
  • Visitors

Stakeholders Affected

  • Family
  • Advocates
  • Representatives
  • Commissioners
  • External health professionals
  • Local Authority
  • NHS

To ensure that Care Clarity Support & Advocacy Ltd complies with the NHS Accessible Information Standard, and that staff at Care Clarity Support & Advocacy Ltd consider how they will apply the standard in a clear, consistent, transparent and fair way. For Care Clarity Support & Advocacy Ltd to have a clear, consistent, transparent and fair approach to the provision of accessible, inclusive information and communication support to all. All staff at Care Clarity Support & Advocacy Ltd have a responsibility to make information accessible and inclusive.

Care Clarity Support & Advocacy Ltd will comply fully with the NHS England Accessible Information Standard and will perform the following six implementation steps:

  1. Find out if people have communication and information needs
  2. Record those needs in a clear and standardised way in electronic or paper based systems
  3. Use alert systems to generate specific formats or to clearly indicate needs to others
  4. Include records as part of data sharing and treatment and referral processes
  5. Take steps to ensure people’s information and communications needs are met
  6. Regularly review needs and ensure records are up to date

Staff will have a working knowledge of the NHS England Accessible Information Standard, and Care Clarity Support & Advocacy Ltd will be able to demonstrate compliance through audit and quality assurance processes. In line with UK GDPR, data protection legislation, Care Clarity Support & Advocacy Ltd will enable Clients to access their records when requested, and this includes the right to review and amend their documented communication preferences. Where Clients are unable to provide consent in relation to their wishes with sharing of information, all decisions regarding this area will be made in line with the Mental Capacity Act 2005 and best interests requirements.

Care Clarity Support & Advocacy Ltd will also comply with the Accessibility Regulations that came into force for public sector bodies in 2018 and require reasonable adjustments to be made to websites and mobile apps for those with disabilities to ensure that they remain accessible. The regulations require a service’s website to comply with WCAG2.1 AA by:

  • Ensuring that the website is ‘perceivable, operable, understandable and robust’
  • Having an accessibility statement available on the website

Although some services may be exempt from the regulations (full government guidance can be referred to here), Care Clarity Support & Advocacy Ltd recognises it has an obligation to ensure that reasonable adjustments are in place for disabled people.

There are six basic steps which make up the Accessible Information Standard:

  1. Find out if people have communication and information needs
  2. Record those needs in a clear and standardised way in electronic or paper based systems
  3. Use alert systems to generate specific formats or to clearly indicate needs to others
  4. Include records as part of data sharing and treatment and referral processes
  5. Take steps to ensure people’s information and communications needs are met
  6. Regularly review needs and ensure records are up to date

At the earliest opportunity, e.g. when an enquiry for a Care service is raised, receiving staff must establish any communication needs or wishes in a timely manner. Before commencing any Care, an assessment will be completed that identifies the communication needs and wishes of the Client. This information gathering will include identifying how the Client manages this and what support they will need from staff in order to enable effective communication. Before commencing Care, Linda Akli must determine that Care Clarity Support & Advocacy Ltd can meet the communication needs of the Client.

Staff must avoid making any assumptions about Clients’ communication needs, and must take care to record people’s communication needs specifically and separately from any recording of disability or other protected characteristic status. As part of the Care Plan cycle, assessments will be reviewed in accordance with locally agreed timescales or as a Client’s condition changes. As part of this, staff will revisit and identify any new communication needs and support accordingly.

Linda Akli will consider how to promote enabling all individuals accessing Care Clarity Support & Advocacy Ltd to express their communication needs and wishes. There are a range of resources (e.g. posters and leaflets) that can be accessed via NHS England that can help to raise awareness that Care Clarity Support & Advocacy Ltd will accommodate different communication preferences (refer to the Further Reading section of this policy). Recording of communication needs and preferences will be highly visible and clear on paper formats (i.e. jargon free, in a simple language). Where electronic systems are used, coding must be in accordance with the defined terminology and assurance will be gained that persons receiving this shared information understand it.

Staff at Care Clarity Support & Advocacy Ltd must have systems in place to ensure that records (electronic or paper-based) clearly flag that the Client has a recorded communication need – they will be highly visible and prompt staff to take action. Where facilities are in place for automatically generated correspondence, alerts will pick up the requirement for alternative formats. Staff responsible for overseeing standard print letter releases to Clients must have systems in place to not send these where it would be inappropriate or inaccessible for that person. Care Clarity Support & Advocacy Ltd will investigate and learn from any incidents of this nature.

Consent will be gained from the Client who has identified specific communication preferences and needs in relation to sharing this information. Any limitations to this must also be documented and clarity provided as to what information can be shared, with whom, in what circumstances, and for what purposes. Where consent cannot be obtained due to reduced capacity, staff should refer to the Mental Capacity Act (MCA) 2005 Policy and Procedure of Care Clarity Support & Advocacy Ltd and best interest decisions made in line with the code of practice. Existing internal and external communication systems such as the referral, transfer of Care and handover processes will include reference to communication support required for Clients.

Staff must be aware of how to adapt their own communication styles to meet the needs of a Client, and they must also be competent with the use of any techniques or aids used by Clients. It is acknowledged that it may take time to establish communication needs from Clients that choose to not disclose this information, and they must be encouraged to discuss their needs with staff. Clients who use limited or no English, and those who use British Sign Language (BSL) or the deaf-blind manual alphabet, will have access to a professional interpreter. Staff will support the Client to access this and will work with any advice and support offered by the interpreter. Where staff are required to support Clients to source an interpreter or communication professional, this must be based on the following considerations:

  • Qualifications
  • DBS clearance
  • professional code of conduct
  • Experience
  • Preference of the Client (e.g. in relation to gender)
  • Specialist skills needed

Any concerns in relation to the suitability or practice of the interpreter will be discussed with Linda Akli.

Care Clarity Support & Advocacy Ltd will regularly review Clients’ accessible information and communication needs to ensure they remain accurate and appropriate. This review will occur in line with the Care Plan review cycle at Care Clarity Support & Advocacy Ltd, or sooner if there is a significant change in the Client’s health, communication ability, or care and support setting. Any updates must be clearly documented in the Client’s Care Plan and promptly acted upon to maintain effective and equitable communication.

Although the Accessible Information Standard does not include environmental or facilities matters, some aspects apply to Clients with a disability, impairment or sensory loss, in order to facilitate communication. Staff must always consider whether some rooms are ‘better’ than others for people with communication needs, e.g. less clutter, improved lighting, soundproof. As part of the Care Plan process, the environment must be considered and appropriate locations detailed in the Care Plan where specific rooms might provide better support to facilitate communication. Staff will consider lighting, in particular where lip reading is vital for the Client.

Linda Akli will accommodate communication aids that support individuals with communication, such as loop systems, in agreement and review with Care Clarity Support & Advocacy Ltd. Linda Akli must consider in advance how to facilitate the conversion of key documents, policies and procedures in a timely manner. Linda Akli will identify which communication formats can be used or produced within Care Clarity Support & Advocacy Ltd, for example, email and text message (for people who are deaf as an alternative to telephone, and for people who are blind as an alternative to printed information), and large print.

Staff should also refer to the Recite Me tool within compliance resources, which will support with the conversion of policies and resources into different languages, large print and audio amongst other available functions. A local suite of support services and points of contact will be made available in readiness for accessing specific communication requirements that cannot be met within Care Clarity Support & Advocacy Ltd. Linda Akli will consider how needs can be met by the use of remote, virtual, digital and telecommunications solutions, as well as paper format.

Where Care Clarity Support & Advocacy Ltd has access to the national Care Records Service (NCRS), reasonable adjustments must be recorded using the NHS Reasonable Adjustment Flag in addition to the Client’s Care Plan. This Reasonable Adjustment Flag enables health and social care professionals involved in the Client’s direct care and support to view key information about required adjustments, reducing the need for Clients to repeat their needs and supporting compliance with the Equality Act 2010 and the NHS England Accessible Information Standard (DAPB1605). Staff must consider completion of the flag when:

  • The Client has a disability as defined under the Equality Act 2010
  • The Client has a communication need identified under the Accessible Information Standard
  • The Client requests an adjustment
  • An assessment identifies a barrier to accessing care, support or health and social care services

Where Care Clarity Support & Advocacy Ltd has authorised access to NCRS:

  1. Log into the national Care Records Service
  2. Search for the Client using NHS number and demographic details
  3. Select “Reasonable Adjustment Flag”
  4. Record the type of impairment or need (using natiofinally defined categories) and specific reasonable adjustments required
  5. Save and confirm submission

Adjustments must be reviewed:

  • At formal Client care and support reviews
  • If Clients’ needs change
  • At least annually

Staff can refer to the Supporting Communication and Sensory Needs Policy and Procedure of Care Clarity Support & Advocacy Ltd for practical support and procedures that can extend to any person accessing Care Clarity Support & Advocacy Ltd. Time should be factored into accommodating communication needs, as some Clients may need longer periods of time to process information than others.

New staff joining Care Clarity Support & Advocacy Ltd will receive an induction that includes communication. For new Care Workers, they will also be required to complete the Care Certificate which includes standards around communication. Ongoing, staff will be encouraged to develop their learning further. This will be identified through supervisions and appraisals, and by training needs analysis.

Care Clarity Support & Advocacy Ltd will measure its compliance against the set of performance measures by using the self-assessment framework. There are 8 steps to completing the framework:

  1. Understand the Accessible Information Standard
  2. Assemble a self-assessment team
  3. Review current practices
  4. Conduct staff and user surveys
  5. Undertake gap analysis
  6. Develop an action plan
  7. Implement the plan and monitor
  8. Deliver continuous improvement

NHS England states that organisations should be in a position to annually publish their compliance with the 2025 version by March 2027.

Linda Akli will ensure that processes are in place to make sure that information recorded is current and accurate. Record keeping audit processes will include a review of the communication preferences of Clients. Overarching quality assurance checks of Care Clarity Support & Advocacy Ltd will identify meeting the needs of any Client accessing Care Clarity Support & Advocacy Ltd. Any findings of discrepancy will be immediately acted upon and reflected upon to ensure the risk of reoccurrence is reduced. Clients will be supported to provide feedback about their experiences, with information received by Care Clarity Support & Advocacy Ltd in the most appropriate forum. Information received will be acted upon as part of the continuous improvement cycle.

Key Definitions

  • Accessible information: Information which is able to be read or received and understood by the individual or group for which it is intended
  • Alternative formats: Information provided in an alternative to standard printed or handwritten English, e.g. audio, braille or large print
  • Deafblindness: A combined hearing and sight loss that causes problems with mobility, communication and access to information

Effective information and communication are vital components of a person-centred approach to care and support. The Accessible Information Standard was introduced to standardise how organisations consistently meet communication needs of individuals. There are 6 steps to the Accessible Information Standard; these are Ask, Record, Flag, Share, Act and Review. The standard dovetails alongside equality and diversity and data protection legislation. The standard is mandatory for NHS and social care providers.

Care Clarity Support & Advocacy Ltd recognises that you may have specific communication requirements and will ensure this is accommodated. Care Clarity Support & Advocacy Ltd will ensure information is presented in an accessible way and, where appropriate, in a range of languages and formats that are easily used and understood. Care Clarity Support & Advocacy Ltd will seek your feedback on information sharing as a means of improving its service.

As well as the information in the ‘Underpinning knowledge’ section of the review sheet, we recommend that you add to your understanding in this policy area by considering the following materials:

Forms Included in This Policy

  • How to Create Easy Read Documents
  • Easy Read Template
  • Accessible Information Flag
  • Different formats of key policies such as the Complaints, Suggestions and Compliments Policy and Procedure are readily available for access

Care Clarity Support & Advocacy Ltd actively advertises to any visitors that it can accommodate different communication needs and actively supports a culture that encourages people to disclose their needs.

  • Staff receive additional training in relation to communication skills, such as lipreading, sign language, use of electronic communication aids
  • Records clearly state communication needs and audits demonstrate adherence to the standard
  • Any feedback and suggestions received in relation to communication within Care Clarity Support & Advocacy Ltd is acted on in a timely manner as part of quality assurance processes