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Writing a Neuro-Inclusive Reasonable Adjustments Policy (UK): Sample Text + Pitfalls to Avoid


If adjustments in your organisation depend on who someone’s manager is, you don’t have a system—you have luck. A clear reasonable adjustments policy turns legal duties into predictable practice, reduces disputes, and builds trust. Below you’ll find a concise, copy-paste policy you can adapt, followed by implementation notes and common traps to avoid. This guidance tracks the Equality Act 2010 (employer duty to make reasonable adjustments), the EHRC Employment Statutory Code of Practice, and current ACAS advice (including “have a policy” and keep a written record). It also reflects ICO guidance on handling workers’ health information.



Why a written policy matters

  • It operationalises your legal duty: when you know or could reasonably be expected to know about a disability and a related disadvantage, you must take reasonable steps to remove it. A policy clarifies how staff tell you, how you decide, and how you review.

  • It standardises practice for managers (ACAS: define process, meet, decide, record, review; include neurodiversity examples; have a policy).

  • It protects privacy by setting out how health information will be stored and shared lawfully under UK GDPR (ICO).



Copy-paste policy (short, plain English)

Title: Reasonable Adjustments Policy Owner: HR / People Applies to: Employees, workers, applicants and contractors in the UK

1. Our commitment We will remove or reduce disadvantages linked to disability by making reasonable adjustments to jobs, processes, and environments. This duty applies in recruitment, during employment, and on return to work. Managers and HR will act promptly, consult with the individual, and record decisions.

2. What counts as an adjustment Any proportionate change that removes a substantial disadvantage—for example: clearer briefs and meeting formats; changes to hours or location; assistive tech and training; environmental changes; support workers or job coaches; adjusted assessments in recruitment. (Examples are illustrative, not exhaustive.)

3. How to request Tell your line manager or HR in any format (email, form or conversation). You do not need to share medical detail to start the discussion; describe the barrier and what would remove it. We will acknowledge requests quickly and offer a meeting to agree next steps.

4. How we decide We’ll consider: effectiveness, practicality, cost, and impact on service. Where we need expert input, we may seek Occupational Health or ergonomic advice. We aim to decide within a reasonable timeframe and will explain reasons if we cannot agree a requested change. (Legal duty applies once we know or should reasonably know about the disability and disadvantage.)

5. Recording and review Agreed adjustments will be written up in a short record (sometimes called an adjustments passport) owned by the employee and recognised by HR. We will review at sensible triggers (new role/manager, location change) and at least annually.

6. Data protection and confidentiality Health information is special category data. We will limit access to those who need to know, store data securely, and share only with a lawful basis and appropriate condition for processing under UK GDPR. We will document decisions before sharing any health information.

7. Funding and equipment We will fund reasonable adjustments. Where additional tailored support is appropriate (e.g., specialist kit, coaching), we may support an Access to Work application alongside our budget. (Northern Ireland uses a separate scheme.)

8. Recruitment We invite candidates to request adjustments for any stage (job description, application, assessments, interview). We will provide alternative formats and accessible platforms and, where needed, an equivalent route if a third-party tool is not accessible.

9. If you disagree with a decision Raise it with HR. You can request a review and provide additional information. This does not affect any legal rights.

10. Responsibilities Managers: act on requests, meet, decide, record, implement and review. Employees: describe barriers and what helps, participate in reviews, and report changes in need. HR: maintain the policy, support managers, safeguard data, and monitor outcomes.



How to implement (in a fortnight, without drama)

Start by training managers on one conversation model: acknowledge → understand the barrier in the task/environment → co-design low-cost changes → record → set a review date. Use ACAS’s structure (meet, decide, record, review) and publish a single, short form for the adjustment record. Tie reviews to events (new manager, role, location) so support survives change.

Check your recruitment stack: job ads invite adjustments, platforms meet WCAG and allow assistive tech, and you have a fallback when a vendor tool can’t be made accessible. If the test measures the wrong thing or is inaccessible, switch to a work sample—and say so in the policy. (This sits comfortably with wider inclusion standards such as ISO 30415.) 

Finally, hard-wire privacy: managers never keep medical letters in local files; HR/OH control access; sharing relies on a lawful basis and special-category condition, documented up front (ICO).



Common pitfalls (and better patterns)

Gatekeeping support behind diagnosis. The duty is needs-led; ACAS is explicit that you can start adjustments without medical proof. Focus on the barrier and the change that removes it; seek OH input only where it adds value.

Paperwork without practice. An “adjustments passport” helps—but it does not replace live conversations and reviews. Treat it as a living record, not a hurdle.

Inconsistent decisions. Publish decision criteria and examples. Use HR moderation on tricky cases and record the rationale. EHRC’s Code expects reasoned decisions tied to effectiveness and practicability. 

Privacy leaks. Health data in manager inboxes is a breach waiting to happen. Route all documents to HR/OH; restrict access; document lawful basis and condition before sharing.

Recruitment platforms that block assistive tech. If your supplier can’t evidence accessibility, provide an equivalent route and fix the procurement. Your policy should say this out loud.



Quick FAQ (for your intranet page)

Do I need a diagnosis to ask? No. Describe the barrier and what removes it; we will act proportionately and review. (ACAS)

What if my manager changes? Your adjustments record follows you and is reviewed with the new manager. (BDF recommends a living record.)

Who can see my information? Only those who need to implement support. Health information is special category data; access is restricted and logged. (ICO)



References

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