Organised by the Equality Commission for Northern Ireland
1) Overall context
The Disability Discrimination Act 1995 (DDA) made it unlawful to discriminate against disabled people. The Act was introduced in stages, with provisions about access to services coming into effect in October 2004, in 2006 the reach of the Act was further extended to cover other categories of people not previously included. For many years the Act was not applied to the provision of transport services, and people could not rely on the DDA if they were refused access to public transport such as buses or trains or it they were provided with inadequate or inferior services because they were disabled.
This changed with the introduction of the Disability Discrimination (Transport Vehicles) Regulations (Northern Ireland) 2009 which came into force on 25 January 2010. These Regulations cover trains, buses and coaches, taxis, rental vehicles and breakdown services. They made it unlawful to treat a disabled person less favourably than someone without a disability, for example by offering them a lower standard of service.
2) Brief description of the campaign
The Equality Commission’s Business Plan 2011-2012 states at objective 1.1 “To continue to build the commission’s profile and image by delivery of three promotional campaigns reflecting corporate priorities”.
A refresher campaign for ‘Access For All’ was developed in support of the launch of the Code of Practice for Disability Discrimination (Transport Vehicles) Regulations (Northern Ireland) in June 2011.
The small weight campaign, capitalised on the existing creative, first seen in January 2010 when the Regulations were introduced.
The campaign had a tighter focus on target audiences with the primary focus on people with disabilities. Consideration of the audience resulted in a further segmentation with older people and carers being identified.
One in five of the population are limited in their daily activities because of some form of disability, with 48% over 55 years of age and around half are in the social grade of DE. Around half of all disabled people are very active users of the internet but the other half are not active at all. Nearly two-thirds watch more than two hours of television per day and over half are readers of the daily press.
A secondary audience type was identified as service providers, professional and representative groups. These groups were not a focus of the advertising elements but rather had a range of activities designed to increase their capacity to comply with the regulations. These activities included meetings, training sessions and engagement events.
A multi-channel mix of television, radio, outdoor and online advertising was developed, supported by extensive media promotion and a series of roadshows in shopping centres and other public spaces.
3) General objectives of the campaign
- To remind disabled and older people of their new and enhanced rights;
- To motivate them to use these rights when needed;
- Provide information to the general public about the new transport regulations and the responsibilities of transport providers.
4) Key messages
- If you have a disability you cannot now be offered an inferior service by a transport provider;
- If you are a transport provider you cannot now discriminate against passengers with a disability by offering them an inadequate or inferior service;
- The Equality Commission for Northern Ireland can provide information and advice about these new
changes to the law.
5) Target audiences (primary and secondary)
[*Primary audiences:*] people with disabilities; elderly people; carers.
[*Secondary audience:*] service providers.
The strategic approach was to develop insight into the different needs and motivations for the segmented audience strands this work was informed by engagement with disabled people, representative groups and commercial companies.
This resulted in the adoption of a range of communication techniques and channels to reach each audience.
6) Resources and budget
- Outdoor W8 Sheet, Bus internals: £ 4,503.00
- Online, SEO, UTV Player: £ 179.11
- Agency, Direct & Indirect: £ 4,755.60
- Press advertorial: £ 1860
TOTAL: £ 33,611.33
7) Detailed description of the communication channels used and messages conveyed. How did the organisers connect with their audiences?
[*Television and Radio Coverage*]
The existing creative of a 20 second high definition television commercial using disabled people fronting the advert and delivering the key message to the audience against a transport themed graphically created background was used.
This advert broadcast from 20 June to 10 July 2011, deploying 250 TVRs across UTV (70%) Ch4 (27%) and Daybreak (3%) reflecting Northern Ireland’s natural share of viewing.
Transmission for daytime programming was weighted to increase exposure of the campaign messages to the elderly and disabled people who would be more likely to watch daytime television.
A 20 second radio advert using both male and female voice overs was broadcast on Downtown, Classic FM, U105 and Talksport. This mix of stations provides optimum opportunity to hear by target audiences across Northern Ireland.
The core audience of disabled and elderly people are heavy consumers of daily press with 1 in 3 adults aged 55+ relying on daily newspaper to keep them informed. Likewise 54% of adults with disabilities read a newspaper every day. Colour adverts featuring the “Access for All – Its the law” logo and accompanying editorial featured in the Belfast Telegraph, Irish News, News Letter, Daily Mirror and Sunday Life.
41% of disabled people regularly use the internet. To this end the campaign utilised the Search Engine Optimisation facility on Google. This works when key words are keyed into Google e.g. Transport Disabled People, Accessible Taxis Disabled People, Disability Rights Transport. These word strings bring internet users directly to the dedicated website.
15 large format 48 sheet outdoor posters were located across Greater Belfast on high volume traffic routes (including Belfast International Airport and Central Station.) 50 Translink Metro buses carried live campaigns ads on a range of being passenger routes. These bus internals were placed behind the driver beside the priority seating for disabled people.
As part of the Disability Transport Campaign the Commission publicised the case of Nicola Nesbitt against Value Cabs. This case was based on the claim
that Ms Nesbitt who is disabled was charged more than a non disabled person for using an accessible taxi. Coverage of this case appeared in 13 newspaper articles.
To help reinforce the campaign message 15 road shows were held at shopping centres across Northern Ireland. See Appendix 1 for location of shopping centres.
Staff attended at the shopping centres where they provided information and advice to members of the public.
The Code of Practice on the Provision and use of Transport Vehicles was launched in Equality House on 21 June 2011. The event was attended by a large number of taxi and coach driver/owners as well as disabled people and disability rights organisations. Presentations were made by the Equality Commission, Translink, North-West Taxi Association and the Automobile Association. The Code itself was delivered to 561 transport providers.
A training session on the content of the Code was delivered on 28 June 2011 to an audience of owner/workers in coach hire, taxi and public transport. Training has also been delivered to 132 Translink managers and inspectors.
[*Website and Digital*]
A new “Access for All” section was designed for the website incorporating two distinct areas for visitors. These were aimed specifically at the two main groups affected by the Disability Transport Regulations: individuals with disabilities and transport service providers. Emphasis was placed on customer journey planning to make the menus and navigation as user friendly as possible.
Considerable effort was made to break down information into concise topics directly relevant to the target audience. This included appropriate content from the Code of Practice and Disability Transport Regulations, details about the DTR road shows and links to additional content and relevant publications available online. The website also used video and audio files to enhance the visitor experience.
An “Access for All” icon was hosted on the homepage of the ECNI website taking visitors directly to a dedicated “Access for All” microsite. This page is also accessible through the “Your rights”, “Employers” and “Campaigns”
section of the website.
8) Explanation of the mechanism put in place to evaluate and monitor the campaign
The IPSOS MORI monthly omnibus survey was used to evaluate the effectiveness of the campaign by asking questions of a sample of disabled people about their awareness of the campaign and change to the law.
The results of the survey show:
[**Spontaneous awareness:*] 28% of respondents were aware of changes to the law with regards to public transport for people with disabilities;
[**Recall of recent changes:*] 41% of people who were aware of recent changes thought that these changes related to “accessibility”. 22% of people who were aware of recent changes thought these changes were in relation to “not being offered inferior service or discrimination against”;
[**Awareness of specific change to the law:*] 44% of respondents when prompted were aware that the changes in the law meant that people with disabilities could not be offered an inferior service by bus, train, coach, taxi or other transport provider. Awareness was higher among older age groups (45-65+) than younger age groups.
[**Advertising awareness:*] 58% of respondents had seen the advertising (when prompted) this awareness was highest among female respondents 63%.
[*Media promotion outcomes*]
The Disability Transport Campaign resulted in 23 press articles and 7 radio broadcast pieces returning 100% Prime Positive tonality and presenting the Commission in extremely favourable light and ensuring the highest possible Media Performance Index of 100/100. The combined PR value of this publicity was £75,482.
The publicity generated by the Nicola Nesbitt settlement resulted in 13 press and 5 broadcast pieces. All exposure was Prime Positive in impact noting the support that Ms Nesbit received from the Commission in making her claim. The majority of articles also noted how Value Cabs had agreed to work alongside the Commission in reviewing its policies and procedures thus boosting the reputation of the Commission as being successful and business friendly.
[*Road show/PR events outcomes*]
Staff who attended at the road shows provided members of the public with advice and information on a range of equality issues, the most common enquires referred to disability. Engagement by the public with staff varied according to venue.
Shopping centres audiences were more likely to engage than those at train or bus stations.
Overall 225 individuals engaged with staff requesting information, describing an experience, seeking advice or commenting positively about the Commissions presence at the venue. The majority of these engagements with staff were about disability related issues.
Over the campaign period the “Access for All” section of the website received 232 visits and 686 pages. 92.5% of these were first time visitors to the site and most were referred from Google and UTV’s website. The Transport Service Provider’s section was visited 35 times with 465 page views and the Disabled People/Your Rights section received 43 visits with 407 page views.
This indicates that those visitors who clicked beyond the introduction pages were very interested in reading further information about the Code of Practice and Disability Transport Regulations, rights and duties, and were most likely therefore to be local transport service providers and people with disabilities – the key target audiences.
A special Disability Transport Regulations edition of the eZine was issued to mark the launch of the Code of Practice. This was sent to over one thousand stakeholders including MLAs, Northern Ireland MPs, MEPs, Peers, NI Political Parties, the local media, individuals and organisations interested or involved in the disability sector.
This edition, which featured information about the launch, the Code of Practice publication, training session and links to the new “Access for All” webpages achieved a readership rate of 30%, and a click-through-rate of 6.5%. This remained consistent with eZines issued in the previous quarters.
It was noted that certain subscribers appeared to act as gatekeepers to their organisations. For example, one subscriber forwarded it onto 90 colleagues in the Assembly’s Committees.
During the five week period following the campaign the enquiry line received 3.4 enquiries from individuals where the individuals state where the source of their awareness of the Commission. 37 individuals indicated that their awareness of the Commission as the organisation which could provide help was due to campaign advertising. 21 people had seen the TV or heard the radio ad. 16 had seen a billboard or newspaper ad. In the five week period preceding the campaign 132 (11.5% of enquiries were disability related. In the five week period following the campaign 155 (18%) of enquiries received were disability related.
[*Engagement with transport providers – disability transport*]
Engagement with transport providers, users and representative groups has been on-going since the Regulations came into force in January 2010. For example, sessions on the implications of the legislation have been delivered to all Translink managers and inspectors; a partnership programme ran with Guide Dogs, IMTAC and the Consumer Council in November 2010; and two transport sessions were included in the disability rights programme which ran during May and June 2011. The Commission is also represented on IMTAC and the Community Transport Association.
A number of actions, in addition to the media campaign and roadshows, were taken to make transport providers aware of their obligations and the Code of Practice. The document itself was sent to 561 transport providers. The launch event was attended by a number of taxi and coach / bus drivers / owners, and included presentations from the North West Taxi Proprietors’ Association, the Automobile Association and on behalf of Translink. Photographs taken at the event were circulated to the presenters for inclusion in their newsletters and magazines, thereby increasing the reach of the event and its messages.
A training session on the content of the Code and how to use it to avoid discrimination ran on 28 June 2011. It was well received and was attended by owners / workers in: coach hire; taxis; public sector transport provision; and a driver training provider.
Around 15 advice enquiries from transport providers have been received through the enquiry line since the campaign was re-run. Over half have been from taxi firms / drivers who have been unsure of their obligations. As a result of work in this area, the Commission is sitting on the taxi stakeholder working group, set up by the Department of the Environment in preparation for forthcoming changes to taxi regulation in Northern Ireland.
9) Impact of the campaign
- Following the release of the Commissions press release about the Nesbitt case and the subsequent publicity it received the Commission was contacted by the Department of the Environment. The Department had been contacted by Minister Attwood who have been asked by Anna Lo MLA what action the DOE had proposed to take in light of the settlement.
- As part of the settlement in the Nesbitt case the respondent taxi company agreed to meet the Commission to review its practices and procedures and in particular its charging structure in relation to disabled passengers. The Commission has met with Value Cabs and these discussions are ongoing.
- The Access for All Section of the Commission’s website was updated to coincide with the start of the campaign. The changes made to the website allowed disabled people and transport service providers to access the information that they required more easily. The development of this section of the website has been subject of an award nomination to the Chartered Institute of Marketing Awards. The website has now been shortlisted for an award.
- In the 16 week period following the beginning of the campaign (20.6.11) 14 disability transport enquires were received by the legal services division out of a total 375 application/enquires received. In the 16 week period prior to the commencement of the campaign no disability transport enquires were received.
- News of the Code of Practice launch was posted on the Commission’s Twitter account. This was subsequently “retweeted” by Disability Action significantly boosting the Commission’s number of Twitter followers. Since the launch of the Code and publicity for the Nesbitt/DTR legal case, the Commission’s number of followers has increased by over one hundred from the launch date. This recent increase included members of the media, the total now stands at 455.