Welsh Language Commissioner Standards Investigation: Questionnaire

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1 Welsh Language Commissioner Standards Investigation: Questionnaire

2 Section 1 General 1.1. Full name of the organization: Hywel Dda University Health Board 1.2. Type of organization: University Health Board NHS Wales 1.3. Which geographical area is served by the organization? Carmarthenshire, Ceredigion and Pembrokeshire 1.4. Provide a description of the organization's main duties. Hywel Dda University Health Board is the planner and provider of all NHS healthcare services for the populations of Carmarthenshire, Ceredigion and Pembrokeshire. Established on 1 June 2009, we became fully operational from 1 October 2009 following reorganisation of NHS Wales that included merging Hywel Dda NHS Trust, and Local Health Boards in Carmarthenshire, Ceredigion and Pembrokeshire. We provide primary, community, in-hospital, mental health and learning disabilities services via general and community hospitals, health centres, GPs, dentists, pharmacists and optometrists and other sites for around 375,000 people across Carmarthenshire, Ceredigion, Pembrokeshire and bordering counties. This is possible thanks to the support of 9,931 invaluable staff, helped in partnership by numerous colleagues from the public, private and voluntary sectors and nearly 300 volunteers What is the location of the organization's headquarters and main regional offices? Ystwyth Corporate Building, Hafan Derwen, Carmarthen 1.6. Does the organization have other administrative offices? Yes [ ] No [ ] 1.7. If 'yes', where are the organization's other administrative offices located? 2

3 1.8. Apart from the administrative offices previously noted, list all other public buildings within the organization's boundaries and responsibilities which are open to the public or a section of the public. 4 acute hospitals: Glangwili and Prince Philip Hospitals in Carmarthenshire; Bronglais Hospital in Ceredigion and Withybush Hospital in Pembrokeshire. 7 community hospitals; Amman Valley and Llandovery Hospitals in Carmarthenshire; Tregaron, Aberaeron and Cardigan Hospitals in Ceredigion; and New Tenby and South Pembrokeshire Hospital in Pembrokeshire 11 health centres There are numerous locations and settings across our three counties from which mental health, learning disabilities, and related services are provided. Primary care services are delivered by: 55 GP practices (main sites) 51 dental practices 99 community pharmacies 56 optometric practices 1.9. How many employees work for the organization? Need to take figure on 31 January How many of those employees have Welsh language skills? (note fluency levels if known) Final figure being taken on 31 January 2015 figures available on ESR 3

4 1.11. Please provide information and/or evidence regarding the institutional arrangements the organization has in place to support and lead the work of planning Welsh language services and to comply with the current Welsh language scheme's requirements (if relevant). The UHB employs 1 full time Welsh Language Officer, 1 full time Welsh Language Support Officer and 1 full time equivalent Translator. The UHB has a Welsh Language Steering and Monitoring Group which has sub groups that include Workforce & Organisation Development and Welsh Language and Primary Care and Welsh Language. The UHB has a Bilingual Skills Strategy which staff groups utilise in order to plan their workforce in terms of Welsh Language Skills of staff. The Unit provides advice and support to all staff across the organisation, to include staff within hosted organisations and primary care. Their duties include: Offering advice and information about the Welsh language Promoting and encouraging the use of Welsh within the workplace Encouraging the use of bilingual aids within the workplace such as signage, stationery etc Providing Welsh Language taster lessons for staff and liaising with external bodies for staff training and Welsh Language courses Offering bilingual front-line telephone training Helping to maintain, update and review Welsh Language Schemes and Action Plans Producing annual Welsh language progress reports on behalf of the organisation Attending public meetings to provide a Welsh Language service for Welsh speakers and assisting and with the arrangements for external translation services Assisting staff with various projects and initiatives to enable them to be bilingual Coordinating the organization s Welsh Language Steering and Monitoring Group meetings Translation service Please provide information and/or evidence regarding any facility the organization has to support the use of the Welsh language. 4

5 5 The UHB supports staff to learn Welsh in various ways including an in house e- learning package and community lessons.

6 Section 2 Service delivery standards [1-85] 2.1. Activity 1: Correspondence sent by a body Does the organization carry out the activity in question? Does the organization carry out the activity in question in Welsh? 2.2 Standards specified in the draft regulations for correspondence sent by a body [1-7] If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them. Standard 2: The UHB can guarantee that letters e.g. appointment letters generated by the Myrddin System are bilingual, however the UHB cannot guarantee that letters sent by individual medical secretaries are bilingual and that a record of the patient/service user s language of need is recorded. There is no current system in place for the UHB to monitor how many letters are sent out each day from individual consultants. Standard 1;4;5;6&7: This is generally normal practice across the UHB. However, it does prove to be extremely difficult to keep a record of patient language choice which can be made available across all areas within the organisation. We cannot always monitor and ensure that independent contractors within primary care ask patients for their language choice, nor do they record and transfer this information on to secondary care Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? If No, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization. 6

7 Standard 2: There is no current system in place for the UHB to monitor how many letters are sent out each day from individual consultants. A high number of these individual letters sent out on behalf of consultants by medical secretaries are also extremely time sensitive and the UHB could not guarantee, with current resource, that there would be no delay in translation. Standard 1;4;5;6&7: This is generally normal practice across the UHB. It is monitored within corporate services, however due to the size and complexity of the organisation and its services, it is extremely difficult to monitor compliance and consistency across each department within each directorate. We cannot always monitor and ensure that independent contractors, within primary care, ask patients for their language choice, nor do they record and transfer this information on to secondary care Activity 2: Telephone calls made and received by a body Does the organization carry out the activity in question? Does the organization carry out the activity in question in Welsh? 2.4 Standards specified in the draft regulations for telephone calls made and received by a body [8-22] If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them. Standards 8,10,11,14,17: Guidelines and training are provided to staff who answer the phones at the main switchboard numbers of the acute hospitals and the main headquarters. There are also telephone guidelines available on the staff intranet. Consistency and compliance is difficult to monitor across the whole of the UHB. Standard 9: Details are included in the organisation s Welsh Language Scheme which is available on the website and staff intranet. Standard 14: Existing practice Standard 15: There are currently no KPIs in place to deal with calls in English or Welsh. Standard 16: There is a bilingual answering service with the option to leave a message in Welsh or English on the headquarters main telephone number Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? 7

8 Yes [ ] No [X] If No, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization. Standards 18, 19 & 20: The UHB is compliant in some departments but not all. We would be unable to monitor consistency across the organisation due to the enormity and complexity of the organisation. Standard 21: It is extremely difficult to keep a record of patient language choice which can be made available to all staff across all areas of the UHB, mainly due to the lack of a central patient record system which all staff have access to. All standards: We cannot monitor and ensure that independent contractors, within primary care, ask patients for, and record, their language choice Activity 3: A body holding meetings that aren t open to the general public Does the organization carry out the activity in question? Does the organization carry out the activity in question in Welsh? 2.6. Standards specified in the draft regulations for a body holding meetings that aren t open to the general public [23-29] If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them. Standard If we know that a patient/service user wishes to speak Welsh after being invited to a meeting, every effort is be made to accommodate a person s language preference. However, we could not ensure and monitor consistency across the organisation due to the enormity and complexity of the organisation. We cannot monitor and ensure that independent contractors, within primary care, would be able to comply with these standards Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? If No, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization. 8

9 Standards 23-29: It is not clear from these standards what the difference between a meeting and an appointment is, in terms of health situations. The UHB provides hundreds of planned appointments every day for example between a doctor and a nurse and a patient/service user. It also provides unplanned contact between a doctor and a nurse and a patient service/user. In a number of emergency appointments time will not allow for a translator to be present. We cannot guarantee that every single member of staff across the whole UHB would inquire about a person s language preference and offer to conduct a meeting through the medium of Welsh when inviting a person to a meeting and subsequently make suitable arrangements to accommodate a person s language preference. This is due to the multiple meetings and patient appointments that take place on a daily basis. In relation to 29A it is very rare to find a translator and/or translation company that provides simultaneous translation from English to Welsh. 80% of contact is first made with the NHS within a Primary Care setting. The UHB cannot ensure or monitor that Primary Care contractors would implement these standards Activity 4: Meetings arranged by a body that are open to the public Does the organization carry out the activity in question? Does the organization carry out the activity in question in Welsh? 2.8 Standards specified in the draft regulations for meetings arranged by a body that are open to the public [30-34] If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them. Standards 30-34: All Health Board notices are provided bilingually and clearly states that the public are welcome to correspond with the UHB in either Welsh or English. Simultaneous translation is provided at public meetings organised by the UHB. Please note that UHB Board meetings are meetings that are held in public not public meetings Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? If No, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization. 9

10 Standard 34: It is not possible to guarantee that all third parties and/or contractors display information in Welsh/bilingually. We could not ensure that every individual team and / or member of staff could be compliant with this standard. This could be dependent upon where the materials have been produced, whether individual departments have the financial resources to produce materials bilingually, whether they have staff who can produce materials of equal standard in English and Welsh, etc. There may also be involvement of a partner organisation or 3 rd party organisation which would not be able to produce materials bilingually Activity 5: Public events organised or funded in its entirety by a body Does the organization carry out the activity in question? Does the organization carry out the activity in question in Welsh? 2.10 Standards specified in the draft regulations for public events organised or funded in its entirety by a body [35-36] If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them. The UHB currently carries out these activities in Welsh/Bilingually e.g. Patient Focus Groups. It is however difficult to monitor compliance across the whole UHB Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? If No, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization. 10

11 It will be difficult to monitor compliance across the whole UHB 11

12 2.11. Activity 6: A body s publicity and advertising Does the organization carry out the activity in question? Does the organization carry out the activity in question in Welsh? Standards specified in the draft regulations for a body s publicity and advertising [37] If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standard specified in the draft regulations, if that standard was to be made specifically applicable to them. Standard 37: When publicity or advertising materials are produced, Welsh language versions will be treated no less favourably than the English versions. However, the organisation could not guarantee that all publicity or advertising materials would be produced in accordance with Standard 37. We could not ensure and monitor consistency across the organisation due to the enormity and complexity of the organisation. Ensuring and monitoring that Primary Care contractors and other third party contractors comply with this standard would be extremely difficult Do you consider that making the standard specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [ X ] No [ ] If No, please explain which aspect(s) of the standard appears to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standard specified in the draft regulations specifically applicable to your organization. 12

13 2.13. Activity 7: A body displaying material in public Does the organization carry out the activity in question? Does the organization carry out the activity in question in Welsh? Standards specified in the draft regulations for a body displaying material in public [38-39] If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them. Standards 38 & 39 The organisation could achieve partial compliance with Standards 38 & 39. Due to the sheer volume of material displayed to the public across the organisation and its hosted services, it would be impossible for the organisation to ensure and monitor consistency across the organisation due to the enormity and complexity of the organisation. Ensuring and monitoring that Primary Care contractors and other third party contractors comply with this standard would be extremely difficult Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [ ] No [ X ] If No, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization. Due to the sheer volume of material displayed to the public across the organisation and its hosted services, it would be impossible for the organisation to ensure and monitor consistency across the organisation due to the enormity and complexity of the organisation. Ensuring and monitoring that Primary Care contractors and other third party contractors comply with this standard would be extremely difficult. 13

14 2.15. Activity 8: A body producing and publishing documents Does the organization carry out the activity in question? Does the organization carry out the activity in question in Welsh? Yes [X ] No [ ] 2.16 Standards specified in the draft regulations for a body producing and publishing documents [40-49] If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them. Standards The organisation could achieve partial compliance with Standards with the exception of Standard 47. For some teams and departments, this is existing practice. However, due to the sheer volume of documents published for public use across the organisation and its hosted services, it would be impossible for the organisation to ensure and monitor consistency across the organisation due to the enormity and complexity of the organisation. Standard 42 would not be applicable to the organization, at present, as we do not currently issue any licences or certificates. Standard 46: The communications team has established a priority mechanism to ensure that press releases relating to service change, important public health and improvement messages are always provided in both languages. Any press releases issued in English always contains a message providing contact information should the reporter want the information to be provided through the medium of Welsh. Press releases issued jointly with Local Authorities and partner Universities continue to be issued bilingually. Press statements are responses to specific media queries, and therefore the Health Board s policy is to respond in the language that the request was made i.e. in English to English media and in Welsh to Welsh media. There is currently no capacity/stretch within the Welsh Language Team or the Communications team to change the priority mechanism Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [ ] No [ X ] If No, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization. 14

15 Standard 41: It would be unreasonable and disproportionate for the organisation to produce all of its board papers and minutes bilingually due to the volume of documents that are included in each board meeting, and other relevant public meetings. Documents may also be produced by external bodies and / or 3 rd parties. Standard 43: The organisation also provides service users with many clinical information leaflets which have been published by NHS England and / or other national public health bodies, where Welsh versions do not exist. It would be impossible for the organisation to ensure and monitor consistency across the organisation due to the enormity and complexity of the organisation. It would not be reasonable or practical for the organisation to translate these documents. 15

16 2.17. Activity 9: A body producing and publishing forms Does the organization carry out the activity in question? Does the organization carry out the activity in question in Welsh? Standards specified in the draft regulations for a body producing and publishing forms [50-51] If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them. Where patient and service users forms are concerned, it would be extremely difficult for the organisation to ensure and monitor consistency across the organisation due to the enormity and complexity of the organisation. There is also a clinical risk involved when producing forms bilingually. Even though it can be a linguistic need for a patient / service user to complete a form in their first language, there is also a clinical risk that needs consideration if the member of staff dealing with the patient / service user s forms is non-welsh speaking. For example, this would need to be considered when patient consent forms are requested urgently for surgery, or when a patient is asked to fill out a questionnaire prior to an appointment with a specialised medical doctor / consultant, etc. In relation to Standard 51, it would be difficult for a non-welsh speaker to pre-enter information onto a Welsh form. There would also be a cost / resource implication when using translation services in order to make all of our public forms bilingual Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? If No, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization. Please see response above in

17 2.19. Activity 10: A body s websites and online services Does the organization carry out the activity in question? Does the organization carry out the activity in question in Welsh? Standards specified in the draft regulations for a body s websites and online services [52-57] If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them. Standards It is existing practice for the organisation to have a fully functional website. However, due to the extensive content which is constantly evolving and updating, it is difficult to ensure that the Welsh and English are uploaded simultaneously. There are also ongoing financial implications for translating website content but it is possible that the organisation would be able to comply with Standards Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? If No, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization. Please see above 17

18 2.21. Activity 11: Signs displayed by a body Does the organization carry out the activity in question? Does the organization carry out the activity in question in Welsh? Standards specified in the draft regulations for signs displayed by a body [58-60] If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them. Standards It is current practice for the organisation to produce bilingual signage when erecting a new permanent sign or renewing a permanent sign. Examples of this over recent times include car parking signs, new hospital and building signage, plaques, etc. However, the organisation has no control over the production of permanent signage within primary care establishments, within the locality areas, and could not guarantee that this signage would be produced bilingually where the Welsh is treated no less favourably than the English Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? If No, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization. 18

19 It would be extremely difficult and non-viable for the organisation to ensure that all temporary signage is displayed in bilingual format. Staff produce and display temporary signage on a daily basis across the organisation, e.g. clinic waiting times, polite notices, etc. On occasions, there is an urgent need for staff to display temporary signage for the public s attention and due to lack of Welsh speaking staff, and the time delay in getting signage translated, it would not be possible for all temporary signage to be displayed bilingually. In addition, the organisation has found it difficult in the past to ensure that 3 rd party contractors display public information bilingually, e.g. building contractors who are carrying out building work within a hospital who need to redirect patients to various clinics / wards etc. Therefore Standard 58 would be unreasonable and disproportionate for the organisation due to the fact that we would be unable to ensure and monitor consistency across the organisation due to the enormity and complexity of the organisation. There is a database of temporary signage available to staff on the intranet but it cannot be guaranteed that this is a comprehensive/one size fits all list. 19

20 2.23. Activity 12: A body receiving visitors at its buildings Does the organization carry out the activity in question? Does the organization carry out the activity in question in Welsh? Yes [X] No [] 2.24 Standards specified in the draft regulations for a body receiving visitors at its buildings [61-66] If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them. Standards The organisation s corporate identity is displayed bilingually in reception areas and the public are welcome to speak in Welsh. However, it is not always possible for the organisation to ensure that a Welsh speaking member of staff will be available to greet persons who have requested or expect a face-to-face service in the reception areas. This is due to the lack of existing Welsh speaking staff in some areas and the general lack of funding available for training. Standard 65 It is possible for the organisation to display signage stating that Welsh speakers are welcome to speak Welsh at the reception, however, it would be difficult to ensure and monitor consistency across the organisation due to the enormity and complexity of the organisation. It would also be a fruitless exercise displaying a sign advertising this service if the organisation cannot carry out the service. Standard 66 Existing Welsh speaking staff do wear / display the Iaith Gwaith logo Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? If No, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization. 20

21 Standards Due to the nature of the national health service, it would be disproportionate for the organisation to ask a person(s) if they wish to receive a Welsh language reception service and it would be non-viable for the organisation to provide this service across the UHB. The organisation has very few areas where there is no face-to-face reception service and due to the lack of Welsh speaking staff in some areas it would not be possible for the organisation to arrange for this service to be made available upon demand or in advance upon request. It would also be non-viable for the organisation to monitor this practice within primary care establishments and ensure compliance. 21

22 2.25. Activity 13: Official notices made by a body Does the organization carry out the activity in question? Does the organization carry out the activity in question in Welsh? Standards specified in the draft regulations for official notices made by a body [67-68] If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them. This is existing practice within the UHB. The UHB cannot monitor or guarantee compliance within Primary Care Contractors Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? If No, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization. 22

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24 2.27. Activity 14: A body awarding grants Does the organization carry out the activity in question? Does the organization carry out the activity in question in Welsh? Standards specified in the draft regulations for a body awarding grants [69-73] If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them. Standards The organisation does not currently invite applications for grants and does not issue grants as such. Some funding maybe allocated to a 3 rd party, e.g. a charity working in partnership with us, but this would not be considered as a grant that would need to be paid back to the organisation. Grants are also awarded internally to different teams/departments through the UHB s Charitable Funds committee. It is not current practice for documents relating to grant applications to appear in Welsh and English Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? If No, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization. In light of the fact that the organisation does not currently invite applications for grants it would be disproportionate for Standards to be made applicable to our organisation. Should an occasion occur where the organisation would need to conduct interviews with grant applicants through the medium of Welsh, this could have financial resource implications, due to the need to arrange for simultaneous translation services. 24

25 2.29. Activity 15: A body awarding contracts Does the organization carry out the activity in question? Yes [X No [ ] Does the organization carry out the activity in question in Welsh? Standards specified in the draft regulations for a body awarding contracts [74-78] If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them. **Awaiting All Wales response from Shared Services** ( ) Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? Yes [ ] No [ ] If No, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization. **Awaiting All Wales response from Shared Services** 25

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27 2.31. Activity 16: Raising awareness of Welsh language services provided by a body Does the organization carry out the activity in question? Does the organization carry out the activity in question in Welsh? Standards specified in the draft regulations for raising awareness of Welsh language services provided by a body [79-80] If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them. Standards 79 & 80 The organisation can achieve partial compliance with Standards 79 and 80. Where Welsh speaking staff are available to deliver specific services in Welsh, every effort will be made to publicise this service, however, it would be difficult to ensure and monitor consistency across the organisation due to the enormity and complexity of the organisation. Where it is necessary to use a translation service to provide services in Welsh, it may be more difficult to publicise these services. However, in line with legislation, our website states that all of our services can be provided through the medium of Welsh, even though it is challenging for the organisation to provide all its services bilingually Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? If No, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization. 27

28 It would be unreasonable and disproportionate for the organisation to monitor compliance with Standards 79 & 80 within primary care establishments, who are responsible for publicising their own services. 28

29 2.33. Activity 17: A body s corporate identity Does the organization carry out the activity in question? Does the organization carry out the activity in question in Welsh? Standards specified in the draft regulations for a body s corporate identity [81] If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standard specified in the draft regulations, if that standard was to be made specifically applicable to them. This is current practice within the UHB Do you consider that making the standard specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? If No, please explain which aspect(s) of the standard appears to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standard specified in the draft regulations specifically applicable to your organization. 29

30 2.35. Activity 18: Courses offered by a body Does the organization carry out the activity in question? Yes [] No [X] Does the organization carry out the activity in question in Welsh? Standards specified in the draft regulations for courses offered by a body [82-84] If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standards specified in the draft regulations, if those standards were to be made specifically applicable to them Do you consider that making the standards specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? If No, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization. The UHB doesn t carry out the activity out the activity in question in Welsh. 30

31 2.37. Activity 19: Public address systems used by a body Does the organization carry out the activity in question? Does the organization carry out the activity in question in Welsh? Standards specified in the draft regulations for public address systems used by a body [85] If the organization carries out the activity in question in Welsh, please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the standard specified in the draft regulations, if that standard was to be made specifically applicable to them Do you consider that making the standard specified in the draft regulations relating to this activity specifically applicable to your organization would be reasonable and proportionate? If No, please explain which aspect(s) of the standard appears to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standard specified in the draft regulations specifically applicable to your organization. 31

32 The UHB doesn t currently carry out this activity. 32

33 2.39. Standards specified in the draft regulations which deal with supplementary matters in relation to service delivery standards [ ] Please provide information and/or evidence to demonstrate to what extent the organization would be able to comply with the Standards specified in the draft regulations which deal with supplementary matters in relation to service delivery standards, if those standards were to be made specifically applicable to them. Standard 158 It would be possible for the organisation to produce such a document and partially complies with this standard now in terms of its Welsh Language Scheme. The UHB cannot guarantee that Primary Care contractors will comply with this Standard. Standard 159 The organisation has a complaints procedure and corresponding documents which details the way in which the organisation deals with complaints. This document is published on the website and copies are available to the public. Primary care establishments are independent practitioners and therefore the UHB only has the power to transfer complaints to primary care contractors (when appropriate) but does not have any entitlements to participate in the procedure or record any outcomes. Complaints are responded to directly from each independent contractor. Standard 160 The organisation has a small dedicated team who monitor the organisation s compliance with Welsh language legislation, assist with the promotion of Welsh language service provision, facilitate service delivery in the medium of Welsh, and increase Welsh language awareness amongst our staff. However, due to the enormity and complexity of the organisation, it is difficult for the team to monitor and oversee compliance of each individual team and member of staff with the Service Delivery Standards. Standard The organisation will continue to produce an annual report relating to developments within Welsh language service delivery, however, it has proved difficult in the past to monitor compliance, collate and analyse information across the whole of the organisation, its hosted bodies, and the primary care sector, for inclusion in such reports. The organisation currently complies with Standard 162 and 163 in relation to its Welsh Language Scheme Do you consider that making the standards specified in the draft regulations, concerning the supplementary matters relating to service delivery standards, specifically applicable to your organization would be reasonable and proportionate? If No, please explain which aspect(s) of the standards, or which standard(s) in particular, appear to be unreasonable or disproportionate in your opinion. Provide relevant information and/or evidence on the reasons why, in your opinion, it would be unreasonable or disproportionate to make the standards specified in the draft regulations specifically applicable to your organization. 33

34 Please see response above. 34

35 Section 3 Policy making standards [86-95] 3.1. Please provide information and/or evidence demonstrating to what extent the organization assesses and monitors the effects of a new or reviewed policy, or revising an existing policy, whether positive or adverse, on: a) opportunities for persons to use the Welsh language b) treating the Welsh language no less favourably than the English language. All new and updated policies produced by the organisation are subject to an EQIA before being submitted for approval. Welsh language forms a standard equality strand in this process. In addition, new initiatives also undergo a detailed consultation process which forms part of the organisation s approach to ensuring that equality issues are considered in full before decisions are made about any of the organisation s proposed initiative and projects. This will continue to be the standard process for all new and updated policies and procedures. If a new policy has a possible impact upon Welsh language, then the EQIA will result in a policy needing a Full Impact Assessment. Policies can be referred back to their original authors with recommendations to comply with statutory and legal requirements. The Welsh Language Officer will also advise those who are involved in the monitoring and compliance of such policies Having considered the requirements of standards 89-91specified in the draft regulations, does the organization consult on any policy decisions? 3.3. Please provide information and/or evidence to demonstrate to what extent the organization discusses and asks for opinions on the effect, if any, whether positive or adverse, a policy would have on the following: a) opportunities for persons to use the Welsh language b) treating the Welsh language no less favourably than the English language. A multi-faceted Equality Impact Assessment approach was applied to the Your Health, Your Future reconfiguration of services during 2012/13. This work continued during 2013/14 as the University Health Board progressed to the next stage Your Future Services. Screenings/Assessments continue to be undertaken at each key stage of the development and for small/medium term projects which form intrinsic parts of the complete project. 35

36 3.4. Having considered the requirements of standard 92 specified in the draft regulations, please note whether the organization has a policy on awarding grants? 3.5. Please provide information and/or evidence to demonstrate to what extent the organization assesses the effect, if any, whether positive or adverse, awarding a grant would have on: a) opportunities for persons to use the Welsh language b) treating the Welsh language no less favourably than the English language Please provide information and/or evidence to demonstrate to what extent the organisation, when commissioning or conducting research to assist with the policy decision, considers the effects, if any, (whether positive or adverse) that policy decision would have on: a) opportunities for persons to use the Welsh language b) treating the Welsh language no less favourably than the English language. In relation to commissioning and conducting research to assist with policy decision across such a large and diverse organisation, it would be difficult to ensure that effects on Welsh language and Welsh speakers would be taken into consideration every time. However, the formal EQIA process should assess the positive or negative effects a policy has on the Welsh language and Welsh speakers Please provide information and/or evidence to demonstrate to what extent the organisation, when commissioning or conducting research to assist with the policy decision, considers how that policy decision could be made so that it has positive effects or increased positive effects on: a) opportunities for persons to use the Welsh language b) treating the Welsh language no less favourably than the English language. 36