HMRC Northern Ireland Disability Action Plan 2021 to 2024
Published 27 May 2021
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Foreword
Every day, HM Revenue and Customs (HMRC) does important work to develop and deliver policies and services that affect the lives of people across the country and beyond.
Our vision, values, strategic objectives and Charter describe the type of organisation we want to be – one that treats customers and colleagues fairly, protects society from harm, and makes HMRC a great place to work.
This report sets out what we have achieved to date, and the plan provides practical measures we will deliver over its lifetime to fulfil our legal obligations and help transform lives of disabled people who work for, or interact with, HMRC.
As HMRC’s Disability Champion, I am fully committed to developing a culture where disabled colleagues’ and customers’ needs are at the heart of everything we do. We will continue to take an evidence-based approach to understand how and where we need to improve our organisation for both disabled colleagues and customers.
We are committed to improving customer experience, and the HMRC Charter defines the service and standard of behaviour that customers can expect when interacting with us.
Following a period of public consultation, we refreshed the HMRC Charter in November 2020. For the first time, we also included our principles of support for customers who need extra help, which outline what customers can expect from us if they require additional support.
We expect every colleague to live our values every day, in every decision.
Daljit Rehal, Disability Champion for HMRC.
Introduction
HMRC is committed to ensuring that equality, diversity and inclusion is embedded throughout all our functions. As a non-devolved public authority, our policies and services apply UK-wide.
For Northern Ireland, in compliance with our obligations under Section 49A and Section 49B of the Disability Discrimination Act 1995 as amended by the Disability Discrimination (NI) Order 2006, we have produced a Disability Action Plan to demonstrate how we continue to:
- promote positive attitudes towards disabled people
- encourage participation by disabled people in public life
To ensure our Disability Action Plan is implemented effectively, we will involve and consult stakeholders where proportionate and relevant and continue to commit appropriate resources in terms of people, time and money to achieving our aims. We will ensure that our colleagues and board members are aware of our Northern Ireland Disability Action Plan and understand the commitments and obligations within it.
It will be HMRC’s responsibility to report on the progress of the Disability Action Plan, and HMRC will commit to provide an annual progress report on the implementation of the Disability Action Plan and commits to a full review of the plan in 2024.
Section 75 of the Northern Ireland Act 1998 requires HMRC, in carrying out our functions relating to Northern Ireland, to have due regard to the need to promote equality of opportunity between people of different religious belief, political opinion, racial group, age, marital status or sexual orientation, gender; people with a disability and people without; and people with dependants and people without.
The Act also requires us to have due regard to the desirability of promoting good relations between people of different religious belief, political opinion or racial group. HMRC’s Northern Ireland Equality Scheme sets out how we do this. We report our progress annually to the Equality Commission Northern Ireland.
In England, Scotland and Wales, we publicly set out how we meet our public sector equality duties under the Equality Act 2010 on the gov.uk website and our compliance is monitored by the Equality and Human Rights Commission.
Across the UK we set out what our customers can expect from us – and what we expect from them – as we transform our services and ways of working in HMRC’s Charter. We will continue to embed the Charter across HMRC to ensure that the focus remains on the customer commitments in our day-to-day work and when designing our processes and services.
In our principles of support for customers who need extra help, we commit to signposting the extra support available in our customer guidance, communications and letters.
Our role and functions
HMRC is a non-ministerial department and is responsible and accountable for delivering tax policies and maintaining the tax system.
As the UK’s main tax authority, we:
- are responsible for safeguarding the flow of money to the Exchequer through our collection, compliance and enforcement activities
- make sure that money is available to fund the UK’s public services
- facilitate legitimate international trade, protect the UK’s fiscal, economic, social and physical security before and at the border, and collect UK trade statistics
- administer statutory payments such as Statutory Sick Pay and Statutory Maternity Pay
- help families and individuals with targeted financial support through payment of tax credits
- administer Child Benefit
- are a high-volume business; almost every UK individual and business is a direct customer of HMRC
- aim to administer the tax system in the most simple, customer focused and efficient way
- administer the Government Banking Service
HMRC is responsible for administering:
- Income tax, Corporation Tax, Capital Gains Tax, Inheritance Tax, Insurance Premium Tax, stamp, land and petroleum revenue taxes
- environmental taxes
- Climate Change Levy and Aggregates Levy and Landfill Tax
- Value Added Tax (VAT), including import VAT
- customs duty
- excise duties
- trade statistics
- National Insurance
- tax credits
- Child Benefit
- enforcement of the National Minimum Wage
- recovery of Student Loan repayments
HMRC’s strategic objectives
HMRC has 5 strategic objectives:
- collect the right tax and pay out the right financial support
- make it easy to get tax right and hard to bend or break the rules
- maintain taxpayers’ consent through fair treatment and protect society from harm
- make HMRC a great place to work
- support wider government economic aims through a resilient, agile tax administration system
How HMRC promotes positive attitudes and encourages participation
How HMRC promotes positive attitudes towards disabled people and encourages participation by disabled people in public life
Our strategic approach
The Civil Service and HMRC has a long-standing commitment to equality, diversity and inclusion across the UK, including disabled people in Northern Ireland.
Our strategic approach uses evidence and insight to help us become the type of organisation that we want to be; one that treats all customers and colleagues fairly, including disabled colleagues and customers, protects society from harm, and makes HMRC a great place to work.
Across the UK, HMRC involves and consults disabled colleagues and stakeholders in the decisions that may impact them. We aim to go beyond the legal minimum and work collaboratively to continuously learn and improve our practices.
HMRC’s equality objectives 2020 to 2024
HMRC has equality objectives that apply to our work with our customers and how we interact with our colleagues right across the UK, including disabled people in Northern Ireland. They are reviewed at least every four years and as new priorities emerge.
They are designed to eliminate unfair disparities by being transparent about our challenges and increasing accountability for addressing them throughout the organisation.
They are explicitly linked to Our Commitments and HMRC Charter standards.
We are committed to improving customer experience and the HMRC Charter defines the service and standard of behaviour that customers should expect when interacting with us.
We have 3 equality objectives, outlined below.
Objective 1: inclusive
To be a great place to work for all our colleagues. To have a safe physical and digital environment with a culture where we can be authentic, have a voice and feel that we belong.
To provide products and services that are designed around what customers need to do, are accessible, easy and quick to use.
Objective 2: respectful
For every colleague to treat each other and our customers with respect every day. We will work together to achieve our common goals and have honest conversations with respect when we do not live up to our standards. We will always treat customers fairly, in line with our values of respect, professionalism and integrity.
We will be mindful of customers’ personal situations, and provide extra support where required.
Objective 3: representative
For the diversity of our colleagues to reflect the diversity of our customers. We will improve the health of the tax system by building trust and increasing fairness to improve our customer and colleague experience.
For our colleagues
Public appointments are made at Civil Service level, but at a departmental level we take an evidence-based approach to inclusion. We analyse our diversity data and insight to identify and understand any disparities in the experience for disabled candidates and colleagues throughout the employee lifecycle.
We use that information to tailor and target interventions, to make changes to our policies, culture and behaviours and make HMRC a great place to work for all colleagues.
We address unacceptable behaviour wherever we see it, identifying and supporting the next generation of talent and creating workplaces where everyone feels valued through 4 categories of activity.
Process improvement
To support evidence-based actions and impact measures, we continue to work to increase our diversity declaration rates so that we can accurately identify the scope, size and locations of our challenges.
We audit our data sets to identify aggregate disparities for disabled colleagues in opportunities, usage or outcomes of our policies and processes. We involve disabled colleagues in understanding the barriers faced and designing process improvements.
HMRC created a Workplace Adjustment project which has reviewed and revised end-to-end processes, as well as standardised and streamlined procedures when ordering and placing a reasonable adjustment.
The Task and Finish Group was set up to meet HMRC’s strategic objectives on disability, with particular focus on reviewing the findings from our Disability Disparity Audit to understand the issues and barriers that were indicated. It has also helped shape and develop a disability action plan to improve culture and disabled colleagues’ experience.
Learning and development
We are working to ensure high quality, tailored learning to support the development of talent, knowledge, and to promote inclusive and positive behaviours. HMRC has developed an e-learning package called ‘Just Ask’. The aims are to:
- raise awareness of HMRCs commitment to the social model of disability and believes that people have impairments and are disabled by the barriers operating in organisations that exclude and discriminate against them
- help colleagues be confident and informed when serving disabled customers, allowing colleagues to focus on the needs of the individual rather than their disability
- raise staff awareness of their responsibilities under the Equality Act
As part of HMRC’s strategic commitment to improve the customer experience, all colleagues who have regular contact with external customers are asked to complete this e-learning package.
It helps to raise awareness of our responsibilities under the Disability Discrimination Act and help colleagues feel confident and informed when serving disabled customers in a proactive and appropriate way, focussing on the needs of the individual rather than their disability. We will continue to review our learning offering to ensure it is fit for purpose, effective, delivering value for money and the desired learning outcomes.
Accountability and governance
We continue to strengthen our frameworks to embed consideration of equality throughout all our functions across the department, including disability equality. HMRC is committed to ensuring all of our services & tools are accessibility compliant in line with WCAG 2.1 legislation.
We have developed governance boards which are committed not to launching any new service which have accessibility defects at the point of inception. These boards look at the architecture and design of the service to ensure no internal or customer facing service is launched and not accessible.
We continuously involve disabled colleagues in the design of products, tools and services, taking a user-centred design approach, so users are at the heart of our design principles and we maximise opportunities to promote equality, diversity and inclusion.
Where colleagues are affected by decisions made at senior level, they are actively included in the decision-making process, to ensure we reflect the real day-to-day needs of all staff.
Communicating our inclusive culture
We continue to promote positive attitudes by raising awareness of our vision, where we have areas for improvement and our expectations of all colleagues to contribute positively to making HMRC a great place to work by running regular communication campaigns to build inclusion, raise awareness of our challenges, and celebrate our diversity.
We embed equality consideration into our estates, events and communications. We create opportunities for the department to listen to and understand the personal impact of inequalities on disabled colleagues to reduce barriers and inspire allyship.
For example, we continue to hold meetings with disabled colleagues to test progress and explore what more we can do to improve policies, procedures and behaviours. We regularly post personal stories, blogs, vlogs, and podcasts on various internal platforms, to raise awareness of disabilities, and how our colleagues can be better supported.
Disability equality and inclusion
Much of our work is focused on becoming more inclusive for all colleagues and we integrate disability equality into that where it makes sense to do so. Taking an evidence-based approach means we can identify areas where we need to improve and help inform future actions. We specifically engage and involve disabled people in a number of ways:
- we are actively involved in the development of the cross-government National Strategy for Disabled People
- we work with external organisations, such as Business Disability Forum, when seeking expert and independent advice on disability issues, consultation, equality analysis, or other evidence-gathering exercise
- we engage with Civil Service standards, such as ‘Disability Confident’, a scheme which encourages employers to recruit and retain disabled people and those with health conditions. HMRC holds the highest status, and is known as a Disability Confident Leader
- we support staff disability networks. We have a departmental Disability Network for all colleagues with an interest in disability equality issues and encouraging best practice. The Network provides support and advice for colleagues, and acts as consultant to the business. There are a number of sub-groups that are contained within the Disability Staff Network Group, these include the Deaf & Hearing impairments, SIGHT (Sight Impaired Group for Help and Technology) and the Dyslexia and Dyspraxia Network group
- we have Regional Disability Network Steering Groups and representatives in each of our regional centres who act as first point of contact for colleagues needing support or advice about disability
- the chair of the Disability Network is a member of a departmental-level Equality Diversity and Inclusion steering group, to help HMRC work inclusively for all colleagues. HMRC works collaboratively with cross-government disability networks
- to improve our workplace adjustments processes, we offer training for managers on understanding the needs of disabled colleagues in Northern Ireland in a new working environment in our Belfast regional centre
- we encourage disabled colleagues to participate in the Civil Service DELTA programme, which aims to accelerate development towards senior positions across the Civil Service, to build a more diverse senior pipeline
- we have an active Executive Committee Disability Champion who works with central HR teams, the disability network and subgroups, and cross-government counterparts to provide visible top-level leadership and commitment to disability equality
Our approach has enabled us to develop an award-winning Inclusive Design Guide (IDG) to help deliver phase one of Government Hubs and HMRC’s regionalisation programme. This brings HMRC staff together in one of 13 new or refurbished centres across the UK.
We believe that inclusive design facilitates the transformation of how we function, enabling smarter working for staff by providing inclusive workplaces that attract as diverse a workforce as possible.
Our new regional centres and specialist workplaces will be welcoming, supportive and respectful of the broadest range of people and, by getting the design right now, we will avoid costly changes to buildings further down the line as well as fostering inclusion from the start.
We have also created a working group to support HMRC in making our IT systems more accessible.
This group has helped identify the issues users of Assistive Technology have with internal services and systems. We have already made improvements such as providing captions on Microsoft Teams and making interpretation apps available for iPhone users. Our ambition is that only the most complex of individual needs will lead to specific customisation.
Progress measures
We measure our progress by:
- analysing our engagement and inclusion data around disability from the annual Civil Service People Survey, annual Civil Service Inclusion Survey and ad hoc HMRC Pulse surveys
- quarterly diversity analysis of HR process and policy outcome data, to identify, reduce, eliminate and mitigate any disability disparities, such as casework volume and outcome, recruitment stages, reward nominations and performance management
- monitoring willingness to challenge and report inappropriate behaviour towards disability in annual People Survey
- monitoring reported bullying, harassment, discrimination and victimisation levels towards disability in our annual People Survey
- monthly monitoring of disability diversity declaration rates
- monthly monitoring of our diversity representation and distribution data on disability;
- meeting our various statutory reporting requirements on disability
- receiving feedback from our staff networks, union representatives, leaders and colleagues, normally on a 6-monthly basis
For our customers
Extra Support
Our Extra Support Teams (ESTs) have continued to provide support and guidance to those who need extra help, including customers in vulnerable circumstances. Our service helps people according to their needs, and supported over 70,000 customers in 2020 to 2021. We offer support for customers with a range of difficulties including:
- accessibility
- low personal confidence
- mental health or emotional difficulties
- learning disability
- genuine problems with their ability to interact with HMRC’s tax and benefits system
- imprisonment, which means they are unable to interact with HMRC within required timescales
Types of support include:
- specialist help from our phone or webchat service where advisers can fast track an application or process where appropriate
- advisers who investigate a case and will call customers back over more complex queries
- face-to-face help at a convenient time and location or customer’s home (currently paused due to Covid-19)
- debt management support
- continuing to work in partnership with the Royal Association for Deaf people (RAD) to offer British Sign Language (BSL) translation services, which enable HMRC to hold live conversations with deaf customers who use BSL, and increasing the number of subtitled BSL videos for HMRC’s YouTube channel
- continued partnership with the RAD which ensured that we helped 1018 deaf customers with their tax affairs
- a tailored accessible service suitable for various needs on the Additional Needs page on GOV.UK
- providing alternative formats for customers; converting almost 46,000 documents into alternative formats, which included large print, Braille, audio and plain text on CD
- in January 2020 HMRC introduced a dedicated Compliance Extra Support Team to provide advice to compliance colleagues to help them support customers who require extra help
We have continued to expand the EST to help customers with a broader range of queries – including adding National Insurance contributions (NICs), Employers Helpline including PAYE, Payment Enquiries Line, Self Assessment, VAT, Construction Industry Scheme, Corporation Tax, tax credits, Child Benefit and Inheritance Tax to our remit.
The EST successfully adapted their service model provision to meet the demands of the Covid-19 pandemic. These included:
- developing a telephony outbound booking tool for appointments
- creating webchat portal on GOV.UK
HMRC is implementing processes to support HM Treasury’s Debt Respite Scheme ‘Breathing Space’. From May 2021, identified customers in problem debt will be given a 60-day period where enforcement action from creditors and interest is frozen, allowing customers to seek the support they need. Customers receiving mental health crisis treatment will be given the same protection until their treatment is complete.
Accessibility for our disabled customers
HMRC is committed to ensuring all its customers will have access to its digital services. Our work includes:
- setting out clearly the Web Content Accessibility Guidelines (WCAG) 2.1 AA standards
- asking developers to declare their WCAG 2.1 AA compliance
- asking developers to confirm that they have a support model in place that can support individuals who have accessibility needs or use digital assistive technologies
- ensuring all new HMRC websites and digital services are tested against WCAG 2.1 standards
- publish accessibility statements which detail any known accessibility issues, what support is available if needed, a roadmap to state when any issues will be fixed and who to contact if you have a problem or want to make a complaint
- HMRC has published details of Making Tax Digital software on the ‘Find software that’s compatible with Making Tax Digital for VAT’ GOV.UK webpage
- we are also continuing to collaborate with software developers and accessibility representative groups to ensure the service meets the needs of users with accessibility needs
Disability equality and inclusion
HMRC has undertaken the following actions to build on its commitment to foster positive attitudes towards disabled people and continues to improve its services to encourage the participation of disabled customers in public life:
- improved signposting to further information, which lets people know how customers can find extra support on GOV.UK
- developed training to help customer-facing colleagues identify customers who have additional needs
- delivered training sessions to colleagues across HMRC ensuring they are aware of their equality obligations, including all underpinning legislation
- continued to monitor customer complaints and use the analysis and information to improve customer service for disabled customers
Grant funding
We continue to work with the voluntary and community sector (VCS) to help provide a full and joined-up service to people who need extra support. VCS organisations provide tax and benefit-related support services to a range of individuals, including those with disabilities, mental health or learning difficulties, those on a low income, older people, carers and migrants.
HMRC’s grant funding programme supports VCS organisations to:
- help people use HMRC’s digital services
- explore how we can use data and insights from VCS to help us understand the wider set of barriers customers experience when accessing HMRC services - making sure we don’t exclude any groups of users
- provide advice and support to those customers who, for various reasons, need extra help at some point in their lives when interacting with HMRC, such as the elderly, people with mental health conditions, those in financial hardship, and customers who are digitally excluded, among others
- help HMRC identify and reduce communication barriers for customers, so we can improve the customer experience as well as HMRC’s efficiency and productivity
In 2019 to 2020, we awarded £1.66 million in grant funding to help 14 organisations support those customers who find it difficult interacting with HMRC.
HMRC has also continued to work with a broader network of VCS representatives, including unfunded organisations. Through regular meetings, they provide us with insight into issues that our customers face, test guidance before it is issued and give us an indication of how messages will be received by our customer groups, as well as raising issues from their interactions with customers.
We also know that some people supported by the VCS may lack trust in, or confidence in dealing with, HMRC directly. Others may be in dispute with HMRC, so VCS organisations play a vital part in HMRC’s strategy to support customers, rebuilding their confidence to work directly with us where possible, but also providing ongoing support where necessary.
Forums and working groups
The role of the Individual Stakeholder Forum
The Individual Stakeholder Forum is our main external consultation forum for the VCS and other organisations representing individual customers. It helps us make sure our actions continue to reflect our diverse customer base.
Meetings feature a mix of presentations from HMRC policy and operational representatives and discussions on topical issues, changes in policy or process, or topics raised by members.
The role of the Additional Needs Working Group
The Additional Needs Working Group (ANWG) is a focus group of external representatives. The ANWG provides support and challenge by:
- examining planned changes to ensure that the impact on customers with additional needs has been sufficiently considered
- using their skills and experience to provide practical advice, help and guidance – making recommendations as to how relevant policies, strategies and practices can be improved
- providing HMRC with a forum for the constructive exchange of ideas about the requirements and concerns of customers who need additional support.
- ensuring that HMRC’s Assisted Digital and Digital Exclusion approaches are shaped by the group
- using interaction and feedback to provide an opportunity for the quality assurance of Guidance, HMRC Services and projects
The role of the Customer Experience Committee
This is a subcommittee of the HMRC board with a remit for customer experience.
The Customer Experience Committee provides counsel and scrutiny, as well as challenging HMRC on customer experience-related issues to help the department deliver on its strategic objectives.
The committee’s work programme includes advising on developing a customer-focused culture, introducing customer experience performance measures and addressing the needs of customers who need extra support.
The committee members include a mixture of HMRC’s Executive Committee, HMRC Non-Executive Directors and independent advisers who are customer experience experts drawn from the private sector.
Research
In January 2020 HMRC published an Assisted Digital and Digitally Excluded Support Needs research report.
The aim of the study was to obtain updated information on the prevalence, characteristics and support needs of adults in the UK who are Digitally Excluded or require Assisted Digital support.
The findings will allow HMRC to better understand how to boost usage of its digital services and better provide support to its customers. It includes data on those identifying as having a long-standing illness, health problems and disability.
In addition, we commissioned research in 2019 to improve our understanding of the support needs of customers who use the VCS, and their experience of receiving support. We are using these findings to work as effectively as possible with them and will be publishing the report later in the year.
We continue our work to build a panel of user researchers and testers and now have the biggest panel in government. More than 66,000 people signed up to take part in user research and give us feedback on the services we are building.
For the wider community
We run several community programmes. Our highlights for 2019 to 2020 include:
- 4,497 days funded by HMRC for our people to assist schools, voluntary groups, charities and other good causes
- 3,000 of our people supported around 39,000 young people to take their first steps towards work, through our partnership with the Prince’s Trust that has been growing for more than 25 years
- 4,000 views, on average, for HMRC’s YouTube animations that are part of our ‘Tax Facts’ tax education programme
- continuing to update and promote ‘Tax Facts’ in schools for young people and teachers and have developed our community of volunteers in regional centres
- more than £1 million charity funds raised and donated by our people, including more than £31,000 for our annual BBC Children in Need appeal and more than £585,000 donated by individual colleagues through Payroll Giving to around 880 of their own wide range of charities
- more than £25,000 raised for the Charity for Civil Servants by our people, helping HMRC to become the top-performing government department in the Million Mile Walking Challenge 2019, both for funds raised and colleagues taking part
Proposed measures
HMRC proposed Disability Action Plan 2021 to 2024 is available in Annex A. The plan was subject to consultation and was reviewed in light of any recommendations.
We invited consultation by directly contacting relevant organisations to participate.
We offered the opportunity for consultees to respond by email, letter, survey or participate in a virtual consultation meeting.
The consultation period closed on 30 April 2021.
We have and will continue to consult with the Additional Needs Working Group. The plan is subject to ongoing consultation and is adaptive in nature.
Consultation
We have consulted with people who will be impacted by the proposed measures in Annex A and those who represent, or act for, disabled people. We asked for views on whether the proposed measures promote positive attitudes and encourage participation by disabled people in public life.
Although the plan relates to Northern Ireland, the measures included within the plan will be implemented on a UK-wide basis, therefore we have sought views from relevant organisations across the UK.
Internal arrangements
Within HMRC there are dedicated departments who will consider and monitor the impact of policies, develop strategies and plans to help improve the service HMRC provides to all its customers.
These consist of:
- quantitative and qualitative research
- organisational listening
- customer journey reviews
- equality impacts including Equality Impact Assessments (where appropriate)
Through collaboration with relevant departments, HMRC will monitor the impact and effectiveness of the proposed measures.
Action measures and timeframe
The 2021 to 2024 timeframe is realistic and aligns with HMRC’s wider strategic plans for an inclusive service for all its workforce and customers.
Performance indicators
The progress and effectiveness of each measure proposed as part of the Disability Action Plan will be monitored using the performance indicators. An annual progress report will be submitted to the Equality Commission Northern Ireland.
Publication
Following its submission to the Equality Commission Northern Ireland the Disability Action Plan will be published on the HMRC Equality and Diversity GOV.UK page.
For further information on the Disability Action Plan, please email us or write to us at:
Northern Ireland Equality Policy Adviser,
HR People and Organisation Development,
HM Revenue and Customs,
Ground Floor, Yorke House,
Castle Meadow Road,
Nottingham NG2 1BQ