Learning Disabilities, Autism and Neurodivergence Bill: Consultation Analysis
The independent analysis by Wellside Research of responses to the consultation on a Learning Disabilities, Autism and Neurodivergence Bill, commissioned by Scottish Government.
Section 7: Access to Technology
Introduction
The need to improve digital access was detailed in the consultation document. Digital inclusion and increasing confidence among people with learning disabilities and neurodivergent people were stated as key aims. Much is already being done to address this and the consultation document identified further ways in which digital access could be improved.
Three proposals were presented for discussion:
- Proposal 1: Consider how to ensure that training is available to people with learning disabilities in digital skills and online safety.
- Proposal 2: Gather clear data on the number of people with learning disabilities and neurodivergent people accessing and using technology.
- Proposal 3: Make more support available to directly help people with learning disabilities and neurodivergent people access and use technology.
Main Findings
In total, 356 respondents provided an answer at this section, with over half agreeing with all three of the proposals. Where respondents did not indicate support for all options, Proposal 3 (providing more support to help people access and use technology) elicited the most support, closely followed by Proposal 1 (to provide training on digital skills and online safety). In addition, most of those who supported Proposal 1 did so in combination with Proposal 3 rather than supporting this as a standalone option. Generally, improvements were welcomed specifically in the online/social use of mobile phones and computers.
Proposal 2 was only supported in isolation by a few respondents, with a general caveat provided by many that data be collected, managed and utilised in a safe and respectful way.
A handful of respondents felt that these proposals would benefit people with learning disabilities and neurodivergent people to find, secure and thrive in employment.
Proposal 1: Training for People with Learning Disabilities
Many respondents championed the idea that access to fit-for-purpose technology and possessing sound digital skills are necessary to live a full and inclusive life. However, the need for individuals to be safe, particularly online, was stressed, with people with learning disabilities (and other neurodivergent conditions) being considered vulnerable in this respect:
“LDAN people can be very vulnerable when using technology and can so easily get themselves into troubling situations of various kinds. They need extra help with the nuances of communication, social behaviour, online safety and even what can get inadvertently get them into criminal behaviour.” (Member of the Public)
Social media was mentioned as a key issue by several respondents. It was felt that people with learning disabilities and neurodivergent people needed training in not only how to use various platforms, but also how to do so in a considered and safe way. A few noted how social media (and access to technology generally) can help to reduce isolation, but they also highlighted the mental health risks that can come from the use of social media, and so it was suggested that training which addressed this would be beneficial. It was also suggested by a few individuals that such training would be highly relevant since some people with learning disabilities and neurodivergent people typically spend more time online.
Several respondents felt there was a need to provide training for children and young people specifically. In particular, it was argued that schools and education settings (including special educational needs (SEN) schools) had a role to play and needed to do more to educate young people on this topic, and to provide inclusion to ensure that children with learning disabilities, autistic and neurodivergent children are suitably informed and skilled in digital technology.
Others (including individuals and a wide range of organisation types) highlighted a need to offer training to family members, carers, and support staff so that they can provide ongoing support around digital skills and online safety. It was felt to be important for them to be able to help identify any safety concerns and know what to do if issues arise.
While supportive of Proposal 1, some public sector organisations and representative bodies raised questions about the implementation and delivery of the training. These respondents were keen to understand more about the mechanics of how this would be delivered, such as which organisations would be responsible for providing the training and support, how staff would be trained in this issue, how this would be resourced and paid for, and what quality controls would be in place to ensure the training was suitably targeted to those most in need and did not reinforce existing inequalities or perpetuate negative stereotypes?
Consistent with comments at many other sections of the consultation document, some respondents suggested that those with lived experience should be involved in designing and delivering training programmes in order to ensure relevance and effectiveness.
A few respondents also suggested that different approaches and training content may be required for different conditions or abilities. It was stressed that different learning disabilities and neurodivergent conditions would present different abilities, vulnerabilities and needs in this respect, and therefore a ‘one size fits all’ approach to this training would not be appropriate.
One of the main concerns, however, and the only common reason given among the handful of respondents who explicitly stated they disagreed with Proposal 1, related to the current wording. Many respondents were concerned that training was only being proposed for people with learning disabilities and called for neurodivergent people to be included. Indeed, much of the feedback provided adopted a broader approach and discussed the need for and provision of training for people with learning disabilities and neurodivergent people more generally, rather than focusing on only people with learning disabilities.
Proposal 2: Data on Numbers Accessing and Using Technology
As noted above, while many respondents agreed with Proposal 2, this was typically in combination with one or all other proposals rather than being supported as a standalone option (only one respondent indicated support for only Proposal 2).
One of the main reason respondents gave for supporting Proposal 2 was the perception that gathering data would inform service delivery, future planning, strategic development and to help direct services, which in turn would improve the lived experiences of many. In particular, a few respondents noted that, as well as improving online/digital services, robust data would help to identify areas where digital and online options are not suitable for individuals/groups of individuals, therefore supporting either maintenance of more traditional methods of information sharing and communication, or the development of other more inclusive mechanisms:
“[Organisation name] strongly agrees that clear data on the number of LDAN people accessing and using technology is needed to inform strategy and interventions. It is acknowledged that one of the most challenging aspects of tackling digital exclusion is the lack of granular data on who is affected.” (LDAN Support/Representative Organisation - Neurodivergent Focus)
It was felt that the collection of such data (including intersectional data) could help to identify the scale and areas of need, help to inform and direct training and support (as offered at Proposals 1 and 3), and identify any gaps, issues or awareness raising that need to be addressed. A few respondents also saw this proposal as a logical starting point or supportive element in designing and implementing Proposals 1 and 3.
Although in favour of Proposal 2, some respondents (often organisations) again sought more information on the implementation and purpose of such data collection, for example, about the type of data to be collected, how this would be gathered, and what it would be used for. Others voiced concern over the collection and collation of data, citing the risk of malicious use and potential discriminatory outcomes:
“…any data collection should be subject to the necessary checks and balances to prevent abuse of such data, particularly if it may identify specific individuals.” (Individual with a learning disability)
Proposal 2 also attracted the highest levels of explicit disagreement at this section. Several respondents felt that collecting data would be futile. They could not “see the point” in collecting more information and they questioned how it would be used to deliver improvements or inform strategic development.
Several respondents said they were unclear of the purpose of the data or how it would be used - they noted that no actions or tangible benefits had been set out for this proposal. Others were concerned that such data collection would be unrealistic and unachievable due to the difficulty of gathering the information and the level of undiagnosed individuals - it was felt that any resulting data would be unreliable, and subject to wide variations. A few also felt that both the money and time that would be needed to establish and conduct this data collection and analysis would be better spent elsewhere, potentially providing technology itself.
Proposal 3: Support to Access and Use Technology
Individuals tended to discuss ‘access’ to technology rather than focusing on the ‘support’ element of Proposal 3. A few indicated that they were not sure what was meant by ‘support’ or what form this would take. Some took this to mean financial support to purchase/rent/access technology, hardware, software, or equipment Others discussed support as being an extension of the training at Proposal 1, suggesting that this should not be a one-off, but should evolve into more ongoing support related to digital skills where required. A few also suggested that support could take the form of specialist services to help people with learning disabilities and neurodivergent people to purchase, set up and maintain technology and equipment.
Having access to technology was considered to help tackle isolation and overcome barriers to information and communication. This was seen as important in most areas of life and when interacting with different organisational sectors. Examples given included: moving away from pen and paper learning in schools/education; being able to access supportive software in the workplace; being able to access supportive methods of communication with GPs and health services; using technology within the prison estate to support communication needs (both internally and for external purposes); and to support independent living.
Many respondents called for increased funding, grants, subsidies or discounts for hardware. It was argued that this would facilitate greater digital access, with respondents noting lower incomes or financial restraints as a key barrier to technology:
“Neurodivergent people face financial inequalities and low employment rates. Therefore, financial support is necessary to purchase technology, such as a laptop, internet package, etc., for those who can't afford it.” (LDAN Support/Representative Organisation - Neurodivergent Focus)
Only a handful of respondents disagreed with Proposal 3. Generally they were concerned about the risks and potential for people with learning disabilities, and neurodivergent people being exploited through online technologies. One individual suggested that some people within scope had difficulties with reading and following instructions and so focusing on digital access was not a priority, while another individual did not understand how Proposal 3 differed from Proposal 1.
Other Comments and Considerations
A number of other considerations were raised by respondents. These are outlined below.
Development of Training, Systems and Technology
In addition to being involved in designing and delivering training, some respondents also emphasised the need for people with learning disabilities and neurodivergent people to be involved in the development of technology and systems themselves to ensure they are appropriate:
“Technology and systems must be co-produced with people with learning disabilities, autistic and neurodivergent people. Due to their lived experiences of barriers to access and use technology, they will be able to identify issues that decision makers may not and ensure that systems work effectively. We believe that systems should be designed first and foremost for people with learning disabilities, autistic and neurodivergent people, as this will enable the rest of the population to access and use technology.” (Health Service)
Funding
Many respondents raised questions and concerns about funding, both in relation to the development and delivery of training programmes and administrative systems, and for increased distribution of hardware and software. As noted above, many interpreted Proposal 3 as offering financial support to access technology, or advocated for this approach. However, some respondents were concerned that, should strategies to improve digital access become legislation, then where would the funding and resources come from?
Retain Traditional Access Options
Some respondents raised concerns about losing access to face-to-face and other more traditional mechanisms as systems move more to online and digital. It was stressed that there remained a need to retain a range of different ways to access services as digital methods were not always accessible or preferable for everyone, and particularly for some people with learning disabilities and neurodivergent people. Others went further, calling for active prevention of the risk of discrimination for those who cannot or do not want to use new technologies:
“We consider it is important that those who are not able to access or use digital technology are not indirectly discriminated against through exclusion from job or learning opportunities, or from opportunities to participate in policy making processes. Consideration ought to be given to requiring non-digital access arrangements to complement digital ones for relevant social goods.” (Justice Organisation)
Some respondents cited a need for proactive opt-in processes to ensure that individuals are not moved to digital, online or paperless services without their consent.
There was also a general feeling among these respondents that some individuals are content to live without unlimited access to technology and that they should not be pressured into learning about and adopting it.
Alternative and Augmentative Communication
Some respondents felt that the proposals did not go far enough and that consideration should also be given to the types of assistive technology available to facilitate digital access. Several mentioned the need for provision and ongoing development of Augmentative Communication Technologies (AAC), and there was concern raised that this had been omitted from the proposals for the LDANBill:
“The proposals do not discuss augmentative communication technologies and are focused on ‘mainstream’ technology access. Just teaching people about accessing IT and providing Easy Read info will never work for all, especially those with multiple and profound LD [learning disabilities]. There is a need to consider how those with more serve LD [learning disabilities] or those with developmental or mental health co-morbidities may benefit from different types of technological support, and how they may be best enabled to access and use these technologies.” (Children's Organisation/Service)
Populations Included Within the Scope
Finally, a few respondents not only stressed the need for training (at Proposal 1) to be extended to autistic people and those with other neurodivergent conditions, but they also noted that autism was not mentioned specifically at Proposals 2 and 3. It was felt that this condition should be included and specified, in keeping with the naming convention of the Bill and to ensure clarity about who is in and out of scope for this support.
Contact
Email: LDAN.Bill@gov.scot
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