Guidance

Level 3: Disability Confident Leader

Updated 12 July 2024

This guidance explains how to become a Disability Confident Leader at level 3 of the Disability Confident scheme.

Ministerial foreword

Thank you for taking this step on your Disability Confident journey. Disability Confident can help you recruit, retain and develop disabled people who will help your business to succeed. The Disability Confident badge will also show disabled people that you recognise the value they can bring to your business - putting you ahead in the search for talent.

Every business trying to stay ahead of their competitors should aim to take advantage of the huge amount of talent disabled people can bring. I say that as an employer myself, not just as a Minister. Before I became an MP, my own business benefited from the confidence to recruit disabled people, and the confidence, where necessary, to make often small changes to enable them to thrive at work.

Wherever there is a barrier, Government is absolutely committed to removing it. We want a system that works for everyone, including small businesses that are the backbone of our economy. That is why Disability Confident is so important. It was deliberately designed to be easy for small businesses to access at level 1 and 2, whilst being flexible enough to also help the very biggest businesses to improve.

With disabled employment at an all-time high we are heading in the right direction, but we are ambitious to do more. With your help we can ensure that every disabled person has the opportunity to succeed at work and every business has the opportunity to prosper.

Minister of State for Disabled People, Health and Work

Introduction

This pack provides the details on the process, guidance and also provides links to resources to enable your business to progress from a Disability Confident Employer to become a Disability Confident Leader.

It also includes the actions you need to take to renew your Disability Confident Leader status.

What’s in it for my business?

As a Disability Confident Employer you are already benefiting from being able to draw from the widest possible pool of talent, and are securing, retaining and developing disabled staff who are skilled, loyal and hard-working.

By stepping up to being a Disability Confident Leader your business can gain recognition from:

• disabled staff in your business
• disabled people outside your business
• other businesses
• your customers
• the wider community

You will also be acting as a champion for Disability Confident within your local and business communities and encouraging and supporting other businesses in your supply chain(s) and your networks to become Disability Confident. In doing so, you will be showing disabled people that you are leading the way in getting every business to become Disability Confident.

Remploy disability guide for employers.

Mencap Good for Business - The benefits of employing people with a learning disability.

Stepping up to become a Disability Confident Leader

You have already completed the Disability Confident Employer self-assessment and are a Disability Confident Employer (Level 2).

There are now 3 additional steps that you need to take in order to become a Disability Confident Leader these are:

1. Challenge
2. Leadership
3. Reporting on disability, mental health and wellbeing.

Challenge

• that you have had your self-assessment validated, and by whom
• your validator(s) agree with your evidence and assessment, and that you are delivering against all of the core actions as a Disability Confident Employer
• that you are employing disabled people.

Leadership

• providing a narrative of the activities you have or are taking in support of being a Disability Confident Leader

Reporting on disability, mental health and wellbeing

• by referring to the Voluntary Reporting Framework. You are taking action to record and report on disability, mental health and wellbeing in the workplace

You will find further details and guidance in the sections below.

When you have successfully completed the actions and activities to be a Disability Confident Leader, you will need to follow the link in the What happens next? section to confirm.

1. Challenge

Your business will have already successfully completed the Disability Confident Employer self-assessment. The next step to becoming a Disability Confident Leader is to subject your self-assessment to an independent validation. The size and complexity of your business will usually dictate how you go about this.

The process for validation involves the validators looking at each of the criteria and the evidence you have recorded on your Employer evidence template in your Disability Confident Employer self-assessment and being assured that you:

• are delivering against all of the core actions and are employing disabled people
• can provide evidence for each of the activities that you are offering to get the right people for your business and to keep and develop your people

The validation template will help you and your validators with the process. You should copy and paste the information from your Employer self-assessment into this template so your validator can use it for their assessment and add their comments.

Many large businesses already have, or are working towards, a recognised external accreditation that covers all the components of the Disability Confident self-assessment – this type of accreditation may well validate the self-assessment for Disability Confident Leader.

Smaller businesses may want to choose from other options that are available to them, reflecting the size of the business. These can include asking an existing Disability Confident Leader business to undertake the validation, involving an external disabled person’s organisation with the necessary expertise, or involving disabled people inside and outside the business. You may decide to use a mixture of these approaches. The key here is having the self-assessment validated by people or organisations that can provide an appropriate level of challenge based on their own knowledge, skills and expertise.

The level of challenge should be proportionate to the size of the business. Suggestions of people, groups or organisations who can help to validate your application to become a Disability Confident Leader are given below.

Micro employers (1 to 9 employees) and small employers (10 to 49 employees)

Possible validating groups/organisations for micro and small employers are:

• existing Disability Confident Leaders
• disabled employees, customers or people in the local community
• local diversity and inclusion groups
• local disability organisations or network groups
• disabled people’s user led organisations (DPULOs)
• recognised accreditation organisations whose accreditation covers the components of the Disability Confident Employer self- assessment

Validation advice for micro employers

To validate your self-assessment, you may decide to enlist the help and support of disabled people who work for you, local disability organisations or DPULOs that you may have worked with in the past or who are based in your community. For small businesses, or those in remote areas, you might involve local disabled people who you come into contact with as customers in your community – the key is involving people who will challenge your self-assessment.

Validation advice for small employers

As a small employer, your business may be more complex than a micro employer and this will be reflected in the level of validation. The validator will require documentary evidence, examples of recruitment and retention policies and practices, best practice initiatives and evidence that demonstrates how any issues/concerns have been managed effectively. To validate the self- assessment, you may decide to enlist the help and support of a group of disabled customers or disabled people who work for you, disability organisations and/or DPULOs that you may have worked with in the past, or disabled people based in the local community. A list of organisations that can offer support can be found on GOV.UK.

Medium-sized employers (50 to 250 employees)

Possible validating groups/organisations for medium-sized employers are:

• existing Disability Confident Leaders
• disabled employees
• disabled stakeholder groups or forums
• national disability network groups
• local disability organisations, Work and Health Programme providers, network groups
• disabled people’s user led organisations (DPULOs)
• recognised accreditation organisations whose accreditation covers the components of the Disability Confident Employer self- assessment
• national disability organisations

Validation advice for medium-sized employers

As a medium-sized employer you are likely to have a more complex business than a micro/small employer, and this will be reflected

by you providing more detailed evidence to the validators. The validation will require, for example, documentary evidence, examples of recruitment and retention policies and practices, best practice initiatives and evidence of issues/concerns that have been managed effectively.

To validate the self-assessment, you may decide to enlist the help and support of disabled people who work for you, disability network groups, disability specific organisations and/or DPULOs that you may have worked with in the past. You may also be working with an external accreditation organisation – providing the accreditation covers the components of the Disability Confident Employer self-assessment, this would satisfy the validation. A list of organisations that can offer support can be found on GOV.UK.

Large employers (over 250 employees)

Possible validating groups/organisations for large employers are:

• recognised accreditation organisations whose accreditation covers the components of the Disability Confident Employer self-assessment
• existing Disability Confident Leaders
• disabled employees or customers/clients
• internal diversity and inclusions groups/forums
• disabled stakeholder groups or forums
• national disability network groups
• local disability organisations, Work and Health Programme providers, network groups
• disabled people’s user led organisations (DPULOs)
• national disability organisations

Validation advice for large employers

As a large employer, employing over 250, you will collect the various information and data that clearly demonstrates that you are a Disability Confident Employer. The validator will require documentary evidence such as inclusive policies and procedures and may refer to the groups/organisations that you involved in the self-assessment process.

To validate the self-assessment, you may decide to enlist the help and support of disabled people that work for you, disability network groups, disability specific organisations and/or DPULOs that you may have worked with in the past. A list of organisations that can offer support can be found on GOV.UK.

When you go to the link to confirm your application to be a Disability Confident Leader you will need to provide details of your validator including, organisation name, validators contact name, email address, phone number and the date of the validation.

2. Leadership

When you go to the link to confirm your application as a Disability Confident Leader you will be asked to provide a short narrative to say what it is that you are and or will be doing to demonstrate your commitment as a Leader.

You will find it easier to complete this in advance and paste your contribution into the relevant box when asked to do so.

As a Disability Confident Leader you will be encouraging other employers to make the journey to become Disability Confident. How you do this, and at what level, will vary depending on the size and nature of your business.

For all employers, leadership may include:

• encouraging other employers in your supply chain
• using social media to promote and share good practice on Disability Confident, such as LinkedIn, Twitter, Facebook, blogs and business newsletters
• networking with other employers in your industry, through business clubs, local networks, business events and so on
• being a mentor, coach, buddy or providing peer support to others
• engaging with other local employers to share good practice
• celebrating success, for example being nominated for or the winner of a recognised award
• being nominated for and/or winning local, regional and national awards for the employment of disabled people
• sponsoring or hosting Disability Confident inspired events

For medium-sized employers (50 to 250 employees) and large employers (over 250 employees), leadership may also include:

• providing validation of self-assessment(s) to other employers
• using contracting to drive positive change, with supply chain providers encouraged to become Disability Confident

3. Reporting on disability, mental health and wellbeing

From November 2019 Disability Confident Leader (Level 3) employers will now need to refer the Voluntary Reporting Framework published in November 2018 to publicly report on their disability employment. It is expected that most will choose to reflect this in their annual report and accounts or on their website. We have also changed the terms of membership to make explicit the requirement that Level 2 and 3 employers employ disabled people.

The Government believes that transparency and reporting are effective in driving the change required to build a more inclusive society.

What is the Voluntary Reporting Framework?

The Voluntary Reporting Framework has been developed by the Government in partnership with large employers and expert partners (including leading charities) to support organisations to record and voluntarily report information on disability, mental health and wellbeing in the workplace.

The framework itself is a 2-page guide designed to be both voluntary and flexible, so is not prescriptive about what employers should report and aims to support employers to take a first step on the journey towards greater transparency. It is divided into 2 parts: one on disability and one on mental health and wellbeing.

What do you need to do as a Disability Confident Leader?

To become a Disability Confident Leader all businesses regardless of size will need to take action to report using the Voluntary Reporting Framework. The level of reporting should be proportionate to the size of the business. Although the Voluntary Reporting Framework is aimed at large employers over 250 employees we expect all employers seeking to become a Disability Confident Leader to refer to it.

The aim is that using the framework you will report on 2 areas:

• disability
• mental health and wellbeing

For each area there are 2 parts A and B.

When you submit your request to become a Disability Confident Leader you will be asked to confirm you are recording information on (A) Disability and (B) Mental Health and wellbeing and also to confirm whether you are already reporting, or, intend to do so in the next 12 months e.g. in your next Annual Report; on your website or through other medium.

The details of the actions you need to take are outlined below. You’ll find the answers to a number of frequently asked questions.

Reporting on Disability

There are 2 things you will need to do:

A. provide a narrative to explain the activities in your organisation in relation to the recruitment and retention of disabled people

B. where possible report the percentage of individuals within your organisation who consider themselves to be disabled or have a long term physical or mental health condition. You may wish to use the question below to gather this information.

Recommended question

Do you consider yourself to have a disability or long term health condition (mental health and/or physical health)?

Guidance on reporting disability

For Part A, the framework is not prescriptive on the content voluntarily provided, as long as it provides context, is accurate and is complete. Below is a non-exhaustive list of information that may be included.

You should aim to include information about:

• the context to the results of Part B
• organisational policies in relation to the recruitment and retention of disabled people
• support offered to employees with specific disabilities
• the role of networks and support groups
• progression and pay of disabled people
• workplace adjustments
• employee engagement scores

For Part B, guidance on reporting the percentage of individuals who consider themselves as being disabled.

It is suggested that you report the percentage of individuals who consider themselves as being disabled. You should:

• consider whether the data is reliable enough to publish, including looking at non-disclosure rates
• state the question used (if not the wording above)
• explain the collection methodology

Collection of information could be completed through employees updating self-service HR records or anonymous staff surveys. It is recommended that you publish both sources, HR records or anonymous staff surveys if held.

Please explain where data was collected.

It is important to be transparent with employees about data usage, handling and storage.

Reporting on Mental Health and Wellbeing

Again there are 2 things you will need to do:

A. provide a narrative to explain the activities in your organisation in relation to supporting the health and wellbeing of your employees

B. report the output of staff surveys that provide measures of employee wellbeing

Guidance on collection and reporting on mental health and wellbeing

For Part A, the framework is not prescriptive on the content voluntarily provided in the section, as long as it provides context, is accurate and is complete. Below is a non-exhaustive list of information that may be included.

Employers who voluntarily report should aim to include information about:

• employee take up of mental health support offered by the organisation
• the training offered to employees related to mental health
• the percentage of individuals within the organisation that are comfortable disclosing mental health
• whether a public commitment has been made to adhere to both the core and enhanced standards as set out in the Thriving at Work (Stevenson / Farmer) review of mental health, and how you are achieving these

For Part B, the recommended questions below will provide a starting point to measure the wellbeing of your employees. The first four are from the Annual Population Survey conducted by the Office for National Statistics.

Recommended questions:

• overall, how satisfied are you with your life nowadays?
• overall, to what extent do you feel that things you do in your life are worthwhile?
• how happy did you feel yesterday?
• how anxious did you feel yesterday?

And these questions (including ranking of a response to a statement) are based on principles of wellbeing e.g., health, security, environment, relationships and purpose as recommended by the What Works Centre for Wellbeing, including:

• all in all, how satisfied are you with your job?
• I would recommend my organisation as a great place to work
• how would you rate your overall physical health now?
• how would you rate your overall mental health now?
• I feel safe from threats and physical hazards in my work environment
• my line manager helps and supports me
• my colleagues help and support me
• I am satisfied with my physical working environment
• my work gives me the feeling of a job well done

What happens next?

When you have successfully completed the actions and activities to be a Disability Confident Leader, you will need to update your status on the Disability Confident website to request to become a Disability Confident Leader.

You will also need your Disability Confident reference number (this starts DCS00….), this was on the email we sent you or more recently on your certificate. If you can’t find it please email us at [email protected]

Through the form, you’ll confirm:

• you have had your self-assessment validated, and by whom
• your validator(s) agree with your evidence and assessment, and that you are delivering against all of the core actions as a Disability Confident Employer
• you are employing disabled people
• you are recording and
• where you choose to publicly report will intend to do so within the next 12 months
• your including a narrative of the activities you have or are taking in support of being a Disability Confident Leader

Once you have submitted the form

In return, we will confirm your status and send you a Disability Confident Leader badge that you can use in your own business stationery, social media, other communications and more widely for 3 years.

We’ll also send you a Disability Confident Leader certificate in recognition of your achievement and further information on how you can share your experience and provide case studies to help other on their Disability Confident journey.

You will also receive a regular newsletter and access to members only Disability Confident LinkedIn and Facebook sites.

As part of awarding you your Disability Confident Leader status we will include your business name, town, postcode, sector and Disability Confident status on the list of Disability Confident employers that have signed up. You may also be contacted by Jobcentre Plus, DWP and or a DWP Work and Health Programme provider to help you attract, recruit and retain disabled people.

Disability Confident Leader Renewal Process

This section provides details of the process to renew your accreditation as a Disability Confident Leader.

At least 2 months before the expiry of your 3-year accreditation you will receive a reminder email advising you that your accreditation will cease from XX date.

From November 2019 there was a change in the criteria to be a Disability Confident Leader. In addition to undertaking the Challenge and Leadership steps you will also need to confirm you are employing disabled people and take a third step Reporting on disability, mental health and wellbeing in the workplace using the Voluntary Reporting Framework.

You will find the information you need to do this in the Reporting on disability, mental health and wellbeing section of this pack.

What do you need to do?

• Undertake a review of your self-assessment and update your evidence template including your evidence on Voluntary Reporting.
• Arrange for your self-assessment to be re-validated. Details on what is required are contained in the Challenge section.
• Complete the actions in the What happens next section.

Voluntary Reporting Frequently Asked Questions (FAQs)

What is the Voluntary Reporting Framework?

The framework has been developed by the Government in partnership with large employers and expert partners (including leading charities) to support organisations to record and voluntarily report information on disability, mental health and wellbeing in the workplace.

Why use the voluntary reporting framework?

The Government believes that transparency and reporting are effective levers in driving the culture change required to build a more inclusive society.

The independent Thriving at Work Review conducted by Paul Farmer and Lord Dennis Stevenson, published in October 2017, recommended that employers should report more information about their actions on workplace mental health on a voluntary basis.

In November 2017, the Government’s Improving Lives command paper committed to working with partners, including employers, to develop a framework for voluntary reporting on disability and mental health.

The framework itself is a 2-page guide to support employers to take a first step on the journey towards greater transparency. It can be found overleaf.

Does an individual have to tell you about their disability?

Employees vary in their preferences regarding what they tell their employer about their disability or health condition.

Some choose not to say anything because, for example, they are concerned it will jeopardise their future career prospects, or they are simply daunted by the prospect of the discussion.

There is no legal requirement for someone to disclose a disability to their employer.

What are the benefits of voluntarily reporting information on disability, mental health and wellbeing in the workplace?

Positively managing mental health underpins good employee engagement and benefits everyone – employees, employers and the bottom line.

Every employer’s success depends on a healthy and productive workforce, and if employees feel valued and supported they’ll achieve more.

Recording and voluntarily reporting information on disability, mental health and wellbeing may support an employer to:

• improve employee engagement and retention, with consequent gains for performance and productivity; engaged employees are less likely to report workplace stress and take fewer days’ sickness absence
• put effective adjustments can be put in place for that individual, giving them the opportunity to fully utilise their skills and abilities
• better understand the experiences of disabled people and people with mental health conditions in their workforce
• better monitor internal progress in building a more inclusive environment for employees
• access a wider pool of talent and skills through promoting inclusive and disability-friendly recruitment, retention and progression policies
• set an industry example in driving a cultural shift towards increased transparency
• better serve and connect with disabled customers and communities, capitalising on spending power
• engage in open and supportive conversations about disabilities and health conditions to help enable employees to remain in work and achieve their potential

Why should I encourage disclosure?

Actively promoting a positive approach towards health and wellbeing by the organisation, and a clear commitment to disability and inclusion, can encourage your team members to feel more confident about telling you about their disability or long-term health condition.

The discussion doesn’t need to be daunting. The term ‘disclosure’ sounds formal and has negative and/or legal connotations for some people. Using more informal, everyday language might help to break down the barriers around discussing disability. Ask people to “share” or “tell” rather than “disclose” or “declare”.

Someone’s health or disability can be a sensitive issue, but most people would prefer a concerned and genuine enquiry about how they are as opposed to silence.

Often employees will not feel confident in speaking up, so a manager making the first move to open up the conversation can be important. Disability charity Scope’s report ‘Let’s talk: improving conversations about disability at work’ includes tips for employers to encourage employees to share information about their disability or health condition.

In the case of someone who may be stressed or experiencing a mental health issue, the mental health charity Mind has information that may be a useful starting point for these conversations, which could be useful for any type of health issue as well as mental health.

Mind and the CIPD have also developed a good practice guide for managers to help them manage mental health issues at work. If a member of your team wants to discuss their disability or health condition, conversations should be private and in a place where the individual is comfortable. Listen with empathy and respond with openness and common sense. You may also start to discuss possible adjustments and support.

This guide for line managers, published with the CIPD, provides practical advice on increasing employ disclosure.

How to implement the Thriving At Work mental health standards in your workplace

Confidentiality and consent to share information?

If an employee has told you about their disability or health condition, as with any personal information, this should be treated as confidential. You should give all members of your team reassurance of this.

Consent to share information about a disability or health condition must always be sought from the individual concerned. If a person doesn’t give you consent to share their information, this must be respected.

If your team member gives permission for information about their disability to be shared, discuss with them who will be told and by whom, and what they want and don’t want colleagues to know.

Why is the voluntary reporting framework a useful tool for employers?

Collecting relevant data – for instance around levels of disability employment - can pose a significant challenge for employers.

For this reason, the voluntary reporting framework focuses not just on the publication of numbers, but also more broadly on the shaping and sharing of an organisational narrative which captures how an employer is seeking to support their employees to create an open and supportive culture around managing health at work.

The framework includes recommended questions, a series of prompts to shape an employer narrative and guidance on collection and reporting. The framework is a flexible tool to encourage employers to take an important step on their journey towards greater transparency around physical and mental health in the workplace.

What is the timescale for publicly reporting?

When you submit your request to become a Disability Confident Leader you will be asked to confirm you are recording information on (a) Disability and (b) Mental Health and wellbeing and also to confirm whether you are already reporting, or, intend to do so in the next 12 months e.g. in your next Annual Report; on your website or through other medium.

Case Studies

Employee disclosure, Channel 4

Channel 4’s internal ‘Tell Us’ campaign encouraged staff to share their diversity data, particularly around disability. They knew that improving disability employment wasn’t just about attracting, recruiting, and retaining disabled talent, but also creating a culture that enables staff to disclose a disability.

Channel 4 explained to staff why sharing their disability status was important to help them determine how they were doing and how to improve and reassure them about confidentiality and how their data would be used. Channel 4 raised awareness of the range of conditions included under the definition of a disability, and because some find ‘disclosure’ off-putting, the campaign’s language instead talked about ‘sharing’.

Their centrepiece was a series of ‘This Is Me’ videos where disabled staff and their managers shared their stories, many for the first time. The senior leadership team launched these videos alongside the wider strategy, giving important context. The videos were incredibly powerful and helped to create a culture of openness.

Within 2 weeks, 90% of employees had uploaded their diversity data and the percentage sharing a disability increased from 3% to 11.5%. Suddenly, disability data told a more complete story and Channel 4 were in a better position to ensure their staff had the support to excel. This made them happier and more productive not only because they benefitted from more active support, but also because the burden of keeping their disability secret at work was removed.

Our mental health and wellbeing narrative, Thames Water

Over the last 5 years, Thames Water has been on an incredible health and wellbeing journey and are proud to be a Disability Confident Leader.

The introduction of a wave of proactive initiatives year-on-year has led to a more than 80% reduction in workplace illness and several thousand employees being supported by Thames Water for non-work related mental health issues.

Employee Health and Wellbeing has been at the front of business decision making. Here are just a few of the steps Thames Water has taken:

• mental health first aiders introduced across the business
• expansion of the internal clinical occupational health team to support the business in case management, health screening, health surveillance and wellbeing
• an occupational health team which now processes on average 100 referrals per month, 98% of which are for non-work related issues (up to 80% of the cases referred every month are for those still in work)
• Water Wellbeing Week – a dedicated health and wellbeing week every year to act as a catalyst for engagement, openness and transparency

Transparency increases trust and Thames Water believes in being transparent about its health, safety and wellbeing status. Thames Water believes it can serve customers, support colleagues and work better together if it has a diverse, understanding and inclusive workforce with employees who feel pride in working for an organisation that encourages, supports and respects individual differences.

More information is available in the Thames Water annual report for 2018 to 2019.