The Salvation Army
South Australia Division
39 Florence Street
Fullarton, South Australia 5063.
Phone: (+61) 08 8408 6900
Fax: (+61) 08 8338 3361

South Australia Division Disability Access and Inclusion Plan 2016-2020

This document has been adapted from SA Division ‘Disability Action Plan 2013-17’, which was reviewed in August 2016 and approved by The Salvation Army SA Division Divisional Commander.

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TABLE OF CONTENTS

1.	Forward
2.	Disability Discrimination Act 1992 (DDA)
3.	What is discrimination?
4.	How many people have a disability?
5.	Ageing Population
6.	What is a DAIP Plan and why we prepare one
7.	How we developed this plan
8.	Overview of The Salvation Army
9.	Context of this plan
10.	Objectives of this plan
11.	What we plan to do
12.	How we will monitor, evaluate and update this plan
13.	How we will communicate this plan
14.	Access and Equity Requirements
15.	Summary of Key Issues
16.	TRAINING
17.	INTERNAL/EXTERNAL DOCUMENT REFERENCES
18.	Appendix 1 -  Abbreviations
19.	Appendix 2 - List of Common Terms

1.	Forward

The Salvation Army, South Australia (SA) Division aims to ensure that at all times it delivers its ministry1 in a manner that is based on the principles of access and equity.  It is committed to ensuring that all people in the community, including people with disabilities have equitable and dignified access to its Mission Centres2, services, programs, facilities, information, communication, employment and volunteer opportunities.

In line with our International Mission Statement:

‘The Salvation Army, an international movement, is an evangelical part of the universal Christian Church.  Its message is based on the Bible.  Its ministry is motivated by love for God.  Its mission is to preach the gospel of Jesus Christ and meet human needs in his name without discrimination’.

The Salvation Army, SA Division recognises that people with disabilities and other access challenges comprise a significant part of the community and as such are considered to be an important focus in the provision of access and equity to services.

The development and implementation of this Disability Access & Inclusion Plan 2016 - 2020 (DAIP) will assist The Salvation Army SA Division to continue to move forward in addressing the barriers that people with a wide range of disabilities and other access challenges might experience as they interact with the organisation.

1For the purposes of this document Ministry is defined as any service delivered or activity or event operated by or on behalf of TSA in a Mission Centre.
2For the purposes of this document a Mission Centre is a corps (church), social programme or Headquarters providing governance and related support services.

2.	Disability Discrimination Act 1992 (DDA)
The Salvation Army, SA Division has a responsibility under the Disability Discrimination Act 1992 (DDA), to provide equitable, dignified access to goods and services and premises used by the public. These are broadly defined and would include all aspects of Salvation Army ministry.

The DDA provides uniform protection against unfair and unfavourable treatment for people with a disability in Australia. It also makes it unlawful to discriminate against a person who is an ‘associate’ e.g. a friend, carer or family member. Disability includes:

•	physical
•	intellectual
•	psychiatric
•	neurological
•	cognitive or sensory (a hearing or vision impairment)
•	learning difficulties
•	physical disfigurement and
•	the presence in the body of disease causing organisms

This broad definition means that everyone with a disability is protected. The DDA supports the principle that people with a disability have the same fundamental rights as the rest of the community. Provisions apply to a wide range of life activities including:

•	access to premises used by the public
•	education
•	provision of goods and services
•	employment, and
•	administration of Commonwealth laws and programs

The DDA requires that appropriate changes be made to provide access. Where this does not occur, a person can take legal action through the Human Rights Commission (HRC) or the Federal Court.

3.	What is discrimination?
Discrimination is defined as treating people with a disability less favourably than people without the disability would be treated under the same circumstances (direct discrimination).
Discrimination also exists where there is a condition or requirement imposed which may be the same for everyone, but which unfairly, excludes or disadvantages people with a disability (indirect discrimination).
It is also unlawful to discriminate against a person because their associates (family, carers, partners etc) have a disability.
Different treatment of people with a disability is not unlawful discrimination where it is reasonably intended to ensure that they have equal opportunities or to meet their specific needs.

4.	How many people have a disability?

The 2015 Australian Bureau of Statistics Survey of Disability, Ageing and Carers found that 18.3% of people in Australia had a reported disability. If this percentage is applied to the total population of South Australia which is currently recorded at 1,698,600, (3101.0 - Australian Demographic Statistics, June 2015), it is estimated that about 310,843 people have some form of disability.

Most anecdotal evidence indicates this figure is an under representation, particularly given the tendency for undiagnosed or unrecorded psychological and intellectual disabilities.

5.	Ageing Population
The ageing population is particularly significant to South Australia.  The South Australian Government of Planning and Local Government “Population Projections for South Australia and Statistical Divisions, 2006–36” report highlights: The percentage of people aged 65 to 84 years is expected to almost double to 18.0% of population between 2006 and 2036. For people aged 85 years and older this change is even higher, tripling to 4.4% of population.

As disability is expected to increase with age and the community is generally getting older, it is expected that the impact of an ageing population and the resultant access issues that develop, will also impact on the need to ensure equitable dignified access is provided to all areas of Salvation Army ministry.  

6.	What is a DAIP Plan and why we prepare one

The DAIP provides the framework for The Salvation Army SA Division to address disability access issues across all areas of its ministry and to support it in meeting its obligations under the DDA.  The DAIP is designed to ensure the practices of The Salvation Army SA Division are proactive in relation to meeting the needs of people with disabilities, their carers and associates, and assisting its ministry, facilities and volunteer and employment opportunities being accessible to all. 

 The DAIP document:
•	Identifies access barriers to mission centres, programs and services,
•	Outlines actions to remove barriers,
•	Identifies who has responsibility for ensuring actions are completed; and
•	Outlines how monitoring, reviewing and evaluating of the DAIP will occur.

When the DAIP is registered with the Human Rights Commission, it must be taken into account in any complaints made against The Salvation Army SA Division in relation to disability discrimination 

7.	How we developed this plan

This DAIP was initially developed in 2013 (then called ‘Disability Action Plan’) through a comprehensive consultation process with key stakeholders forming the Divisional Disability Action Plan Working Group (DDAPWG). The development of the original DAP was facilitated by the Divisional Quality Improvement Coordinator who chaired the DDAPWG and the Divisional Risk Management Coordinator as Deputy Chairperson. Commitment from the Divisional Organisational Risk Management Group, management and staff within our Mission Centres has strengthened the development process. External stakeholder consultation has been undertaken with the Disability Advocacy and Complaints Service of SA in our attempt to include input from people with disabilities. The approved plan was registered with the Human Rights Commission and made publicly available on their website. 

In August 2016, a review of the original DAP was initiated, for which purpose key stakeholders were invited to form a new Disability Access & Inclusion Working Group (DAIPWG), facilitated by the Social Programmes Policy & Development Consultant (SPPPDC) and in 2017 the Divisional Social Programme Secretary (DSPS). This review has led to the development of the current plan, now called Disability Access & Inclusion Plan 2016-20.

8.	Overview of The Salvation Army
The Salvation Army began in 1865 when William Booth, a London minister, gave up the comfort of his pulpit and decided to take his message into the street where it would offer the poor, the homeless, the hungry and the destitute a message of hope and faith and practical assistance in breaking out of poverty.

By the 1900’s the Army had spread around the world.  The Salvation Army soon had officers (ministers) and soldiers (church members) in 36 countries, including Australia.  Now it is established in more than 120 countries around the world with The Salvation Army continuing to work where the need is greatest, guided by faith in God and love for all people.

Whatever the difficulty, The Salvation Army is dedicated preaching the good news of the gospel of Jesus Christ and to helping Australians in crisis: men, women and children who are homeless; families torn apart by domestic violence, substance abuse or problem gambling; people who struggle because of unemployment, mental illness, personal crisis or the impact of disaster. 

The Salvation Army Australia Southern Territory, which includes South Australia, operates more than 700 social programmes, activities and centres3. South Australia has more than 50 such Mission Centres with each one tailored to meet the surrounding community needs.  Mission centres and their associated programs are reviewed regularly to ensure both relevance to community needs and delivery of the highest quality support for individuals and families.

The Salvation Army in South Australia focuses on five core areas of social welfare4:
1.	People facing crisis and poverty
2.	Drug, alcohol and gambling addiction
3.	Family and domestic violence
4.	Homelessness
5.	Children and Youth

3 The Salvation Army Australia Southern Territory 2016 Annual Report
4 The Salvation Army SA Division Strategic Direction 2017 - 2019

9.	Context of this plan

SA Division operates under the mission intentions and mission values of The Salvation Army Australia:

Our Mission 
The Salvation Army is a Christian movement dedicated to sharing the love of Jesus.
We share the love of Jesus by:
•	Caring for people
•	Creating faith pathways
•	Building healthy communities
•	Working for justice

Our Values
Recognising that God is already at work in the world, we value:
•	Integrity
•	Compassion
•	Respect
•	Diversity
•	Collaboration
We commit ourselves in prayer and practice to this land of Australia and its people seeking reconciliation, unity and equity
.

The DAIP is based on a ‘whole of organisation’ approach to addressing access and equity issues throughout the SA Division. It reflects the need for all areas of the organisation to collectively work together in a coordinated manner to improve access and equity for all. The Salvation Army in South Australia is required to align its business strategy to the strategic direction of The Salvation Army Australia while ensuring the issues addressed in this DAIP are included going forward.

10.	Objectives of this plan

The objectives of this DAIP are to ensure that all members of the community have equitable and dignified access to all Salvation Army ministry, including services, programs, activities, Mission Centres, information, communication and the employment and volunteer opportunities they are eligible for.

In addition, the objectives aim to ensure that people with disabilities have appropriate access to consultative and feedback processes in order to effectively contribute to and participate in service planning and developments to improve ministry delivery.

Key objectives of the DAIP are:
•	To confirm The Salvation Army’s acknowledgement of people with disabilities as an important and significant part of the community,
•	To confirm The Salvation Army’s commitment to meeting the needs of people with disabilities, their families and carers as members of the community, people receiving care and support, staff and volunteers,
•	To provide a framework for The Salvation Army to work towards provision of accessible and equitable services in all areas of ministry planning and operations,
•	To promote participation and inclusiveness of people with disabilities; and
•	To assist The Salvation Army to meet its legislative requirements under the Disability Discrimination Act and other relevant legislation.

11.	What we plan to do

The following steps form the basis of the DAIP:
•	Document the key elements of an effective Disability Access and Inclusion Plan,
•	Identify the issues and/or barriers that impact on people with disabilities, including routine analysis of complaints received,
•	Document the actions that will be specifically undertaken to address issues or barriers,
•	Prioritise the actions to ensure those with the most beneficial impact on people with disabilities are actioned first; and
•	Identify a responsible person/s for each action

The Salvation Army SA Division Access and Equity Policy states ‘The Salvation Army will at all times adhere to the legislative requirements of the Australian Human Rights and Equal Opportunity Commission Act 1986, Equal opportunity Act 1984, Age Discrimination Act 2001, Sex Discrimination Act 1984 and Racial Discrimination Act 1975’.

Our intent is to ensure our buildings and facilities will allow for ease of access and egress for people with a physical disability or reduced mobility such as the frail, aged or people with children and prams.  In situations where it is not feasible or possible to modify a building to improve accessibility, alternative strategies will be explored to ensure access to ministry.

Where we cannot meet the needs of people with disabilities by using existing resources, we will explore alternative strategies to facilitate access to ministry.

When accessing ministry, the safety of all people will be a priority.  
At all times The Salvation Army will adhere to the legislative requirements of the Work Health & Safety (WHS) Act 2012 (SA) and the Work Health & Safety (WHS) Regulations 2012 (SA).

12.	How we will monitor, evaluate and update this plan
This DAIP will be monitored, reviewed and updated as follows:
•	Bi-monthly  reporting to the Divisional Quality Improvement Group on progress in implementing the actions documented in the plan,
•	Annual consultation with identified stakeholders, including people with disabilities to gain feedback in relation to progress and priorities of the DAIP,
•	Annual report to the Divisional Finance Board in July each year regarding the accomplishments achieved in the previous financial year; and
•	Submission of a revised plan to the Divisional Board in July each year for approval.

The Human Rights Commission notes that a DAIP is not a static document, but changes according to practices, review and evaluation. HRC describes 'reviewing’ as the process of assessing and revising the DAIP.  (HRC Website)

13.	How we will communicate this plan
The DAIP will be communicated using the following strategies:

•	Posting it on The Salvation Army SA Division web page for download,
•	Linking it to the Divisional Information Portal page,
•	Upon request, provision in hard copy and/or electronic format from South Australia Divisional Headquarters; and
•	Registration with the Human Rights Commission and posting on the HRC website.

14.	Access and Equity Requirements
There is a significant range of issues to be considered when addressing the provision of accessible ministry. 

These include:

•	Buildings and facilities
•	Communications
•	Consultations
•	Equipment, technical and adaptive technology
•	Events
•	Format of reading materials
•	Furniture
•	Internet and related materials and supports
•	Presentations
•	Publications
•	Resource sharing
•	Service delivery methods, including the models of support
•	Signage
•	Staff and volunteer employment, training and support

Prioritising the allocation of finite resources or services will be based on a careful assessment of a person’s presenting needs, strengths and any associated risk.

15.	Summary of Key Issues

Key issues to emerge from observation, consultation and analysis are as follows:

1.	Lack of, or limited access to properties or facilities, particularly at older buildings, including:
a.	some buildings 
b.	some toilet facilities 
c.	some furniture
d.	general equipment
e.	technical and adaptive technology

2.	Lack of, or limited access to SA Division information in formats that comply with good practice standards, including:
a.	Information
b.	Promotional materials 
c.	Recruitment materials
d.	The Salvation Army web pages

3.	Lack of, or limited access to employment and volunteer opportunities within SA Division due to:
a.	Lack of an affirmative action employment policy for people with disabilities 
b.	Lack of access to recruitment processes in a variety of formats 
c.	Limitations to adaptive technology for workers with disabilities

Issue or Barrier 1	Lack of, or limited access to SA Division properties and facilities 	
Actions	Sub-Actions	Responsibility	Timeframe	Status/Outcome	
Analyse the SA Division properties and facilities in alignment with DDA compliance
	1.1   Comprehensively audit and assess all SA Division properties and facilities for legislative compliance with the DDA	DAIP & DQIWG members 	By February 2017		
Address the issues of each site in a time-scale that takes account of what is technically and/or financially feasible	1.2   Identify changes that can be completed in the short term eg. signage  	DAIP & DQIWG members	By June 2017		
	1.3   Develop a response plan to address short term changes	DAIP & DQIWG members	By August 2017		
	1.4   Identify changes that will create significant technical problems 	DAIP & DQIWG members	By October 2017		
	1.5   Develop a response plan for changes involving technical problems that prioritises issues to be to be addressed over the next ten years	DAIP & DQIWG members	By February 2018 		
	1.6   Identify technically and/or financially prohibitive changes 	DAIP & DQIWG members	By April 2018 		
	1.7   Develop a response plan to address technically and/or financially prohibitive changes 	DAIP & DQIWG members	By June 2018 		

Issue or Barrier 1 cont.	Lack of, or limited access to SA Division properties and facilities 	
Actions	Sub-Actions	Responsibility	Timeframe	Status/Outcome	
	1.8   Identify capital funding and grant sources to enable property and equipment improvements 	DS & DSPS	ongoing 		

Issue or Barrier 2	Lack of, or limited access to SA Division information in formats that comply with good practice standards	
Actions	Sub-Actions	Responsibility	Timeframe	Status/Outcome	
Update non-compliant information to good practice standards	2.1   Identify information (including web based) currently being provided to the public and clients across Corps and Social programmes that do not comply with good practice standards for provision of information to people with disabilities.
	DAIP members in collaboration with corps officers social programme management	October 2018		

Issue or Barrier 3	Lack of, or limited access to employment and volunteer opportunities within SA Division	
Actions	Sub-Actions	Responsibility	Timeframe	Status/Outcome	
Review recruitment processes	3.1	Review HR practices to assess their support for affirmative action in the recruitment of people with disabilities	DAIP members & HR Dept	By February 2017		
Implement recruitment practices that support workers with disabilities	3.2	Design a generic inclusivity statement to be used in all recruitment advertisements 	DAIP members & HR Dept	By April 2017		
3.1		3.3	Identify generic disability recruitment/employment agencies across SA	DAIP members	By April 2017
		
	3.4	Implement practice of sending TSA recruitment ads to disability recruitment/employment agencies as relevant	HR Dept in collaboration with corps officers and social programme managers	By June 2017		
	3.5   Identify possible disability awareness training providers
	DAIP members	By October 2017		

16.	TRAINING

Worker induction processes will inform new staff about the Disability Access & Inclusion Plan and their obligations under it.
Worker induction processes will provide staff with a copy of ‘Guidelines for Working with Disabled People’.
Workers who are responsible for production of information materials will be familiar with the good practice standards in providing printed information to people with vision impairment. (Eg. pamphlets, posters, web content etc)
Individual staff development plans will consider the need for specialised training in supporting people with disabilities.

17.	INTERNAL/EXTERNAL DOCUMENT REFERENCES

The Disability Access & Inclusion Plan is supported by a number of TSA policies, procedures, plans, strategies and guidelines.   The Disability Access & Inclusion Plan has implications for some of these. Copies of other documents are available by contacting The Salvation Army Divisional Headquarters at 39 Florence Street, Fullarton. South Australia 5063.  Phone: (08) 8408 6900

Internal Documents
•	Mission Statement & Mission Values
•	Social Justice Statement
•	The Salvation Army Australia Southern Territory Annual Report
•	Service User Rights and Responsibilities 
•	Service Charters
•	Complaints Management Policy
•	Critical Incident Management Policy
•	Access and Equity Policy
•	Consumer and Stakeholder Participation Policy
•	Planning, Review and Evaluation Policy
•	Cultural Diversity Strategy
•	Privacy Policy

External document and information
•	Disability Discrimination Act (1992) 
•	Human Rights Commission Website (www.humanrights.gov.au)
•	Disability (Access to Premises – Buildings) Standards 2010

18.	Appendix 1 -  Abbreviations
  ABS		Australian Bureau of Statistics
DAP		Disability Action Plan
DAIP		Disability Access and Inclusion Plan
DDA		Disability Discrimination Act
HRC		Human Rights Commission 
TTY		Telephone Typewriter 
19.	Appendix 2 - List of Common Terms
Access/ Accessible – Means that a person with a disability is, without assistance, able to approach, enter, pass to and from and make use of an area and its facilities.
Advocacy - Support and encouragement for a cause. To make changes to laws, policies and practices to improve life for everyone within the community.
Disability - The loss or reduction of functional ability and activity that is consequent upon impairment. (World Health Organisation) The negative prefix dis is considered to be problematic due to the built-in negative bias. Some of the other terms we use to describe people with disabilities have the same built-in attitudinal bias: infirm, deformed invalid, and impaired.
Discrimination - Differential treatment or practice either intentional or otherwise that can occur through action, policy, procedure or practice.
Impairment - Any disturbance or interference with the normal structure and functioning of the body, including the systems of mental function. (World Health Organisation) This may or may not be a disability, for example high blood pressure is an impairment but not a disability.
Person with a disability - An individual with a physical, visual, hearing, cognitive, mental, emotional, or learning impairment that substantially limits a major life activity.
Physical Disability - A physiological disorder or condition, which deviates from the body norm and may or may not be disabling.
Vision Impairment - Impaired vision, which may be caused by congenital conditions, disease and deterioration from ageing, or accidents. Serious conditions may cause problems with distance vision, vision acuity, blurred vision, tunnel vision or complete blindness.