Consultation response: Submission to the Department for Communities’ Consultation on the NI Executive Disability Strategy 2025-2035
The NI Human Rights Commission recommends:
2.4 the NI Executive, working with Department for Communities, commits to reflecting the full human rights framework within the Disability Strategy, including a list of relevant human rights standards and ensures that the obligations flowing from these human rights standards are reflected throughout the Strategy. The Ending Violence Against Women and Girls Strategic Framework 2024-2031 provides an example for how this can be achieved.
2.14 the NI Executive, working with Department for Communities, ensures that views expressed during the public consultation process are meaningfully considered and that the Disability Strategy is amended, as is necessary and reasonable, to ensure that it is effective in practice and human rights compliant.
2.15 the NI Executive, working with the Department for Communities, engages with former members of the Co-Design Group and Expert Advisory Panel on the Disability Strategy to ascertain the nature of their concerns regarding the co-design process and use this as the basis for a formalised policy for future participation processes. This includes taking learning from this process and considering examples of best practice of other processes of effective participation. The principle of effective participation should be at the core of any such policy.
2.18 the NI Executive, working with Department for Communities, expedites the production of its three-year rolling Disability Strategy Action Plan alongside meaningful consultation with d/Deaf and Disabled people’s organisations and relevant representative civil society organisations.
2.20 the NI Executive, working with Department for Communities, sets out which NI Executive Department will assume responsibility for the delivery of Strategic outcomes and actions within the Disability Strategy.
2.27 the NI Executive, working with Department for Communities, ensures that the proposed Regional Disability Forum is as closely representative of all d/Deaf and disabled people living in NI as is possible, including children and young people with disabilities, to ensure pluralism and the capture of a wide range of views and concerns.
2.35 the NI Executive, working with Department for Communities, commits within the Disability Strategy to adopting an intersectional approach. This includes implementing a firm understanding across the NI Executive Departments and wider society on the effects of multiple intersectional discrimination in relation to poverty in NI.
2.36 the NI Executive, working with Department for Communities, ensures that its proposals to strengthen data collection in relation to disability takes account of multiple intersectional discrimination, and that the collection, collation and distribution of data in relation to disability is suitably robust and disaggregated.
2.47 the NI Executive, working with Department for Communities, include within the Disability Strategy a commitment to a full review of all statutory controls that influence the built environment including the public realm and the natural environment and make the necessary amendments to ensure compliance with the UN CRPD. This review should be conducted with the full and meaningful participation of d/Deaf and disabled people, including children and young people, and their representative organisations.
2.53 the NI Executive, working with Department for Communities, commission research to identify barriers to access to justice by d/Deaf and disabled people and thereafter implements measures to remove barriers and close gaps in access to effective remedies.
2.54 the NI Executive, working with Department for Communities, include within the Disability Strategy an action to implement effective training on disability inclusion and accessibility at all levels of the criminal justice system.
2.55 the NI Executive, working with Department for Communities, include actions within the Disability Strategy to ensure that support services for d/Deaf and disabled people exiting situations of abuse, including domestic violence, are fully accessible.
2.68 the NI Executive, working with Department for Communities, ensure that services to facilitate independent living captured under Outcome 5 of the Disability Strategy, including plans for social housing supply, are developed and delivered alongside meaningful participation from d/Deaf and Disabled people and their representative organisations. These services should be distributed across urban and rural areas and gender, age and culturally sensitive.
2.69 the NI Executive, working with Department for Communities, publishes the outcome of the Anti-Poverty Strategy consultation process and identifies the key concerns relating to the proposed Strategy’s ability to alleviate poverty for d/Deaf and disabled people, including children and young people.
2.70 the Department for Communities, alongside the NI Executive, ensures that an independent advocacy service is available on an equal basis across NI and independent of the NI Executive and local health and social care Trusts. This independent advocacy service should be designed and implemented with meaningful participation from d/Deaf and disabled people and their representative organisations.
2.77 the NI Executive, working with Department for Communities, ensures that any provisions to tackle rates of unemployment or improve access to good jobs for d/Deaf and disabled people addresses identified barriers to work and poor working conditions or practices. This should include the commitment to consider and address the specific experiences and needs of d/Deaf and disabled people. Such measures should be developed, implemented and monitored by effective engagement with affected individuals and their representative organisations.
2.82 the NI Executive, working with Department for Communities, commits within the Disability Strategy to sufficient school places in inclusive educational settings for children and young people with special educational needs and disabilities. This commitment should be realised with urgency, with suitable alternative options offered without charge to children and young people who are currently unable to avail of places in educational settings in the meantime.
2.85 the NI Executive, working with Department for Communities, sets out a timeframe within which the legislative review of disability legislation will be conducted. This should include consideration of incorporation of UN CRPD into domestic legislation.
3.5 that a Windsor Framework Article 2 assessment should be undertaken and published at the earliest possible opportunity and that the Draft Strategy and any resulting action plan are reviewed and amended as necessary to ensure Windsor Framework Article 2 compliance.
3.9 the NI Executive, working with Department for Communities, ensure that within the Disability Strategy the legal definition of disability is shaped by EU equality law, including evolving CJEU case-law so that this minimum standard is reflected.
3.15 the NI Executive, working with Department for Communities recognise within the Disability Strategy intersectional discrimination which affects d/Deaf and Disabled people, including the impact of disability when it intersects with protected characteristics in line with evolving EU equality standards.
3.20 the NI Executive, alongside the Department for Communities works to maintain North-South equivalence of disability and accessibility protections on the island of Ireland.
4.6 the NI Executive, alongside the Department for Communities, ensures that the Disability Strategy is effectively funded to the maximum of its available resources and includes an express commitment to the principles of progressive realisation and non-retrogression.

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