Making a Disclosure Procedure
Statement on Language
In this toolkit, the terms “people with disabilities” and “disabled people” are used interchangeably. We recognise and acknowledge that both terms can be the preferred terminology within the disability rights movement in Ireland. We also recognise that some people don’t identify with either term. For more information please refer to the policy.
Introduction
The University is committed to providing an equal, inclusive and diverse environment in which all members of the University community should expect to be able to thrive and be respected and valued for their unique perspectives and contributions.
This procedural document sets out the process for employees seeking to disclose a disability. It accompanies the DCU Disability Policy for Employees which sets out Dublin City University’s (DCU) commitment to the promotion of a university that recognises and respects individual difference and that rejects discrimination in all its forms.
Purpose
The Disability Policy for Employees is presented under the University’s strategic commitment to equality, diversity and inclusion. The purpose of this policy is to provide clear information on what employees can expect from DCU in terms of support for disability in the workplace and what steps and processes should be followed when disclosing a disability (disabilities), seeking support, or requesting reasonable accommodations, as well as the roles and responsibilities of managers, the University and individual employees. This procedural document sets out the process for employees seeking to disclose a disability.
Disclosure of a Disability
Disclosing a Disability
In the context of disability in the workplace, disclosure is the decision of an employee to inform their manager or employer that they have a disability.
Disclosure is viewed in many cases, especially in relation to employment, as one of the most challenging aspects of having a disability. One of the most personal decisions you make as a person with a disability is whether or not to tell someone about your disability.
DCU recognises that this can be a difficult decision on your part.
Disclosure helps to ensure that, if needed, the appropriate supports and accommodations can be put in place to enable a person with a disability to participate fully and equally in the University. In cases where a person’s disability is impacting their job or work environment, disclosure is encouraged to enable any performance or conduct-related issues to be addressed in this context. Where it presents a health and safety risk, disclosure is legally obligated.
Disclosure of personal and medical information is treated with the strictest confidentiality. When an employee discloses a disability to their line manager, the University is considered to be aware of this information and assumes a duty of care to provide appropriate support. Therefore, it is essential that the line manager promptly informs the Disability Liaison Officer (EDI Unit) or their relevant DCU People Partner. The disclosure will be recorded securely and confidentially in the employee’s personnel file. Beyond this, information will not be shared with others without the employee's prior consent, unless there is a concern for the health and safety of the individual or others.
DCU is committed to fostering a safe and inclusive environment where employees feel comfortable disclosing their disabilities. To achieve this, the University implements the following measures:
| Open Communication in Recruitment | Information about DCU's support for employees with disabilities is explicitly mentioned in job advertisements and recruitment materials. This includes details on the disclosure process and available accommodations. |
| Comprehensive Induction Process | New employees will receive information about disability disclosure and support services as part of their orientation. This ensures that all staff members are aware of their options from the start of their employment. |
| Regular Training and Awareness | DCU will offer a range of disability awareness training for all line managers and staff. |
| Confidentiality Assurance | DCU emphasises and upholds strict confidentiality procedures to protect the privacy of employees who disclose disabilities. The University clearly outlines the confidentiality process, specifying who will have access to disclosed information and under what circumstances. |
| Multiple Disclosure Channels | The University offers various ways to disclose to increase comfort levels. |
| Clear Post-Disclosure Process | The University outlines the steps taken after an employee discloses a disability, including confidential meetings, needs assessments, and implementation plans. DCU establishes a process for regular check-ins to ensure the effectiveness of accommodations and address changing needs. |
| Anti-discrimination | DCU explicitly states that discrimination and/or victimisation of employees who disclose disabilities is prohibited and will result in disciplinary action. |
| Accessible Information and Resources | DCU provides information about disability support services in accessible formats. The University ensures all relevant policies and procedures are easily available and understood by all employees. |
By implementing these measures, DCU aims to create an environment where employees feel informed, supported, and empowered to disclose their disabilities when they choose to do so.
Disclosure Process
Why Disclose?
Disclosing your disability can support you in your work in many ways
- Access to reasonable accommodations (e.g: rearranging or sourcing new furniture, additional equipment or assistive technology, flexi working hours, etc.) – these can enable you to perform to the best of your ability and receive the support you need.
- Aids in identifying support structures that are available to you.
- Reduces your stress levels - non-disclosure can be exhausting.
- It provides you with the freedom to examine questions regarding health insurance and other benefits.
- If changes occur in your personal circumstances, it provides you with greater freedom to communicate.
- Helps the University to improve processes regarding the provision of reasonable adjustments/accommodations.
You may disclose your disability either prior to or post-employment or at different stages of the recruitment & selection process such as:
During the Recruitment Process
- On the application form or your CV
- On invitation to interview
- At any time during your interview
- When you receive the job offer
- During induction
Existing or New Employees
- When you are diagnosed with a disability
- When and if additional support is required to carry out your role due to your disability
- When returning to work having acquired a disability
- Anytime of your choosing
You must remember that accommodations in the workplace are only provided when you disclose your disability and request accommodations via the Reasonable Accommodation Request Form.
You may disclose your disability:
- Verbally
- In writing
- Via the Reasonable Accommodation Request Form
If you are disclosing a disability verbally, it is recommended that you set up a meeting with the individual you are disclosing to. This is to make sure that you have enough time, space and privacy for the conversation.
Your disclosure may also be in writing, via email, to your line manager and/or People Partner or Disability Liaison Officer.
If you do require accommodations, it is recommended that you complete the Reasonable Accommodation Request Form. Information on how to request a reasonable accommodation can be found in the Policy’s accompanying documentation.
Disclosing via Core Portal Profile: There is an opportunity to disclose your disability through your personal profile in CoreHR profile under the ‘Diversity Screen’. While we encourage all staff to engage with this function as it provides the University the opportunity to understand our employee community in more detail, please bear in mind that access to this information is limited to the People Data and Systems Team. If you want to disclose a disability in order to avail of reasonable accommodations, the other approaches detailed above will be better suited.
Your line manager should be your first point of contact if you wish to disclose a disability or request reasonable accommodations. Your line manager has a key responsibility for your general well-being and ensuring you have access to the full range of opportunities to undertake your role.
Should you prefer not to disclose your disability to your line manager in the first instance, you may instead speak with your People Partner or the Disability Liaison Officer in the EDI Unit.
When disclosing, you do not need to share the detailed nature of your disability and your line manager does not require this information.
Disability disclosure is only important if it affects (or can potentially affect) your ability to perform the essential functions of the job. The most important and helpful information includes:
- How your disability affects your ability to perform the essential functions of the role
- What supports and/or reasonable accommodations you may require
You may wish to provide the following additional information to your line manager and/or fellow staff:
- General information about your disability
- Why you have chosen to disclose
- The types of accommodations that may have worked for you in the past
- The types of accommodations that you may require in the future
- How your disability and other life experiences can positively impact on your performance
Disclosure of your disability in a face-to-face setting:
- Select a private, confidential and a comfortable place to disclose
- Allow time if you think it is necessary to discuss the impact of your disability
- Allow time for questions, suggestions or concerns that require time for discussion.
In line with the Policy, employees requesting a reasonable accommodation will be asked by DCU People to provide medical evidence on the nature of their disability. This does not have to be shared with their line manager, and will be treated in the strictest confidence by DCU People. Any such information provided as part of a disclosure of a disability, including medical information, will be held securely by the People and Absence Management Officer in DCU People, in line with data protection and GDPR guidelines.
You have no obligation to disclose if:
- There is no impact on your job or the work environment
- You do not require any accommodations to the workplace
- You do not need any changes to the organisation of your work
- You do not wish to, and there are no health & safety implications
You do have a legal obligation to disclose if:
- Your disability presents a health and safety hazard or risk in the workplace; you are obliged to disclose – as you have a duty of care to yourself and others.
If you do not inform the University or your line manager that you have a disability and it is not reasonable for the University/your line manager to know that you have a disability, then they, as your employer, are not deemed to know; therefore, they are not liable if reasonable accommodations are not provided.
If you decide not to make relevant information available to others, this may impact the type and level of accommodations you receive. Again, this will be confirmed to you in writing.