Chapter 3

Anti-discrimination Legislation
and Disability in Education

Ilektra Spandagou

Principles and practices of inclusive

education and special education

Collaboration
Attitudes

Effective teaching practices to respond to the

diversity of the classroom
Behaviour support
(whole-school and classroom)
Transitions
Linked scenaria: 3 (Owen) and 5 (Sarah)

Keywords Human rights · Disability · Discrimination · Adjustments

Outcomes: After reading this chapter, you will be able to:

• Understand human rights in the area of disability.
• Understand the role of anti-discrimination legislation in the area of disability.
• Discuss the use of adjustments in relation to Australian anti-discrimination
legislation in education.

Introduction

The chapter starts with an exploration of how human rights emerged and the role
of anti-discrimination legislation in protecting these rights. The area of disability
is then explored by answering the questions: Who is covered by disability anti-
discrimination legislation? and What rights does anti-discrimination legislation pro-
vide to people with disability? This discussion looks first at international and then

© Springer Nature Singapore Pte Ltd. 2020 23

I. Spandagou et al., Inclusive Education in Schools and Early Childhood
Settings, https://doi.org/10.1007/978-981-15-2541-4_3
24 3 Anti-discrimination Legislation and Disability in Education

at Australian legislation. Australian disability anti-discrimination legislation is dis-

cussed in terms of its key elements and what steps educational settings and educators
should take to ensure that children and students with disability are not discriminated
against due to their disability. The chapter concludes with a reflection on the potential
and limits of such legislation.

Human Rights and Disability

In Chap. 2 the idea that disability is an evolving concept (United Nations, 2006) was
introduced. We can extend this and say that the concept of our humanity has been
evolving throughout history. Looking at different societies, the relationships of their
members have been governed by systems of beliefs that provided justifications for
the freedoms and rights of particular members, which in turn translated in complex
systems of administration of every aspect of life. For example, different societies
explained differently through systems of entitlements, freedoms and rights; who can
(and cannot) own land and other assets, what occupations and roles are open to
different members of the society, who can have access to knowledge and learning,
what relationships and under what conditions are permitted, and so on.
At different points in history, ideas and beliefs developed about a common human-
ity shared by all humans, which was formalised in a discourse of human rights as
modern societies, which are organised in nation-states, emerged. These philoso-
phies promoted human rights as standards for measuring inequality and fairness.
Our current understanding of human rights cannot be separated from the Universal
Declaration of Human Rights (UDHR) (United Nations, 1948). The UDHR is the
first internationally agreed statement of human rights. As a declaration, the UDHR
doesn’t create legal obligations. A number of international treaties have followed,
which are binding for the states that have adopted them through a process of ratifica-
tion. Some treaties focus on the rights of specific groups such as the United Nations
Convention on the Rights of the Child (CRC) (UN, 1989), which outlines the civil,
political, economic, social, and cultural rights of children.
It is not always easy to identify the influence of an international convention on
the everyday practice of an educational setting. Commonly, there is a long, subtle
process of changes in legislation, policy and practice. Sometimes, we may be aware
of this process, but more often, we are not. Belonging, Being, and Becoming: The
Early Years Learning Framework for Australia (EYLFA) (Australian Government
Department of Education, Employment and Workplace Relations, 2009) is the first
Australian early years learning framework. In its introduction, it is stated that:
Early childhood educators guided by the Framework will reinforce in their daily practice
the principles laid out in the United Nations Convention on the Rights of the Child (the
Convention). The Convention states that all children have the right to an education that lays
a foundation for the rest of their lives, maximises their ability, and respects their family,
cultural and other identities and languages. The Convention also recognises children’s right
to play and be active participants in all matters affecting their lives (p. 5).
Human Rights and Disability 25

This is an example of how a human rights discourse frames our understanding of

what constitutes being a child and the rights involved, and how this is articulated in
the policy that impacts on educators’ practice and the experiences of children. As
educators, we operate within a rights framework.
People with disability are one specific group that struggled to be acknowledged in
the international human rights law. This was due to perceptions of disability during
most of the twentieth century that focused on disability as a personal problem, with
segregation in institutions being very common, making disability invisible. Percep-
tions of disability as an unfortunate event, what is called a personal tragedy model,
distinguished disability from other characteristics like race and gender and resulted
in the United Nations policy on disability to be of a non-binding nature (Spandagou,
2018). This changed with the United Nations’ Convention on the Rights of Persons
with Disabilities (CRPD), which was negotiated with unprecedented participation by
civic society with 12 organisations of people with disability being part of the working
group that developed the draft text. It was adopted on December 13, 2006, and at the
time of publication, 181 countries, including Australia, have ratified it. Ratification
of the convention means that a country agrees to be legally bound by the terms of
the Convention and national laws need to be consistent with the expectations of the
Convention to promote compliance.

Anti-discrimination Legislation

Human rights are centred on equality, the fundamental concept that all human beings
are born free and equal. Discrimination is the denial of rights because of an individ-
ual’s attributes such as gender, race, or disability and, therefore, it is the opposite of
equality. There are two types of discrimination, direct and indirect. Direct discrimi-
nation is treating one person or a group of people less favourably than others because
of one of their attributes in the same or similar circumstances. An example of that is to
deny access to a building or public transport to a person who is blind and has a guide
dog. Another example is to refuse a student’s enrolment to a school because of their
disability. Indirect discrimination sometimes is less obvious. It happens when there
is an expectation that applies equally to everyone, but it disadvantages a person or
group of people because of one of their attributes. Example of that is to expect some-
one with mobility restrictions to negotiate a set of steps at the entrance of a building,
or to expect a student whose disability impacts on their ability to concentrate for long
periods of times, to complete a two-hour exam without breaks.

Compile a list of five–six examples of what you consider discrimination related

to disability. They don’t need to be about education. Consider in addition
to education, for example, access to housing, transport, services, and goods.
26 3 Anti-discrimination Legislation and Disability in Education

Look at your examples and reflect on whether they constitute direct or indirect
discrimination.

Returning to equality, there are different ways of understanding it. Formal equality
refers to treating everyone the same. This type of equality recognises direct discrim-
ination but not indirect discrimination. Substantive equality on the other hand recog-
nises the need for adjustments or affirmative action to compensate for disadvantage.
This is the purpose of anti-discrimination legislation that aims to eliminate discrimi-
nation, referring to both direct and indirect discriminations and the role of reasonable
adjustments in this process. More recent understandings of equality move beyond
this to identifying a positive obligation to take actions to change the structures that
underpin disadvantage. In education, this means that an educational system should
not refuse access due to disability—direct discrimination—and should provide the
necessary changes to allow for equal participation—indirect discrimination—but
also it should intentionally change its structures to become more equitable. There
are two dimensions in equity in education. Fairness ensures that personal circum-
stances should not be an obstacle to academic achievement and inclusion ensures a
basic minimum standard of education for all participants (Field, Kuczera, & Pont,
2007). The CRPD represents all three concepts of equality (Degener, 2016).

Disability Australian Anti-discrimination Legislation

in Education

Why is important to understand discrimination? In Australia, anti-discrimination

legislation is the framework that informs the participation of children and students
with disability in education. The key legislation is the Disability Discrimination Act
1992 (DDA) (Commonwealth, 1992) that aims to eliminate disability discrimination
in a number of areas, including employment, education, services, and housing. The
Disability Standards for Education 2005 (DSE) (Commonwealth, 2005) is a subordi-
nate legislation under the DDA that clarifies the rights of persons with disability and
the obligations of education providers. The DDA applies to all levels of education:
childcare, preschools, schools, post-secondary education, and higher education. The
DSE applies to all the above but not childcare providers. This means that a provider
that offers both childcare and preschool programmes is operating solely under DDA
for the former and under both DDA and DSE for the latter. In addition to federal leg-
islation, all states and territories have anti-discrimination laws that cover education.
Education providers must comply with both federal and state/territory laws. Over-
all, there is overlap between Commonwealth and state/territory laws, but in some
instances, there are some variations in the expression of the protection offered. In
this book, we focus on federal legislation, but it is a worthwhile exercise to compare
it to your state or territory relevant legislation.
Disability Australian Anti-discrimination … 27

The language of such legislation does not translate intuitively to educational lan-
guage. This may make educators reluctant to engage with the legislation, understand
it, and be confident that their practice complies with it. The extent that this is essen-
tial is recognised in the Australian professional standards for teachers (Australian
Institute for Teaching and School Leadership (AITSL), 2011). One of the focus
areas of Standard 1 Know students and how they learn, is “1.6 Strategies to support
full participation of students with disability”. In order to be able to achieve this,
graduate teachers should “demonstrate broad knowledge and understanding of leg-
islative requirements and teaching strategies that support participation and learning
of students with disability” (p. 9). What are then the key elements of the relevant
legislation?
The main principle that underpins the DSE is that the education of students with
disability should be on the same basis as the education of other students. This means
that students with disability have access to the same opportunities and choices as
their peers. It does not mean that all students should have the same experience of
these opportunities and choices, as students with disability may require reasonable
adjustments, but that they should have equitable opportunities. To give an example,
in the past, it was common for a student with disability to be excluded from aspects of
the curriculum by not participating in specific subjects. For example, students with a
physical disability were often excluded from fully participating in physical education.
Instead, they were provided with alternatives like extra instruction in another subject,
acting in an assisting role like being a timekeeper, or simply observing the lesson.
It is easy to understand that such alternatives do not provide an on the same basis
as opportunity. What is then practice that will constitute on the same basis as other
students? This is where another key element of the legislation comes into play,
reasonable adjustments.
An adjustment is any action taken to ensure that a student with disability partici-
pates on the same basis as their peers. An adjustment is reasonable when in addition
to allowing for on the same basis as their peers participation, it takes into account the
student’s learning needs, and balances the interests of all parties involved, including
the student with disability, other students and staff members. In making decisions on
reasonable adjustments, consultation, another key element of the DSE, is essential.
Consultation should involve engaging with the child or student with disability and
their family to identify barriers to their learning, establish reasonable adjustments
and review them. Consultation is an ongoing process, and adjustments need to be
regularly reviewed. The DSE prescribe the nature of such consultation, requiring
that consultation should explore (a) whether the adjustment is reasonable, (b) the
extent that the adjustment will achieve its purpose, and (c) “whether there is any
other reasonable adjustment that would be less disruptive and intrusive and no less
beneficial for the student” (p. 15).
Sarah, a sixteen-year-old Aboriginal girl attends Blackwater Creek Secondary
School and has hearing loss due to Otitis media (glue ear). Otitis media is a condi-
tion that occurs after repeated ear infections leaving a glue-like secretion in the ear.
It often affects hearing, which in turn may have an impact on language development.
28 3 Anti-discrimination Legislation and Disability in Education

Otitis media rates are much higher for Aboriginal children than non-Aboriginal chil-
dren, and Sarah’s family, community and school are familiar with the condition and
its implications. Sarah is wearing a hearing aid but at times, she doesn’t use it and
complains about it. Sarah is a keen drums player, and she finds her hearing aid a nui-
sance particularly when practising. She has preferences in terms of receiving written
instructions and specific ways that work better for her to access information. When
she listens and doesn’t understand what it is said, she tends to “switch off” and day-
dream. Sarah is very reluctant to ask clarification questions in the classroom. Without
regular consultation with Sarah and her family, the school may make assumptions
about what are the most appropriate adjustments for her or about the extent that the
existing adjustments are still working as intended. Without consulting with Sarah,
it is not possible to know whether not using her hearing aid throughout the day is
part of being self-conscious about it, discomfort due to amplification of loud noises
in specific environments, cultural reasons, a combination of the above or something
entirely different. As it will be discussed in Chaps. 8 and 12, consultation needs
to be culturally sensitive. For example, in Aboriginal languages, there is no word
for disability, and disability is understood within a different framework of human
diversity, which as Avery (2018) explains, it means “‘Do you have a disability?’ is
a question that is culturally insensible for Indigenous peoples” (p. 5).
The DSE includes the following five categories of standards:
• standards for enrolment
• standards for participation
• standards for curriculum development, accreditation, and delivery
• standards for student support services
• standards for harassment and victimisation.
The first four standards comprise all aspects of educational experiences that are
developed, delivered, and administrated by education providers. In addition to the
adjustments for individual children and students discussed above, the DSE requires
education providers to take measures that increase access and participation in general.
For example, enrolment information should be available in accessible formats for
prospective applicants.
The final standard, harassment and victimisation, is slightly different from the
other four, as it focuses on relationships amongst participants. Harassment refers to
actions that have the effect of humiliating, offending, intimidating or distressing a
person with disability and relate to their disability. Victimisation refers to detrimental
actions towards a person with disability because the person of disability has made
or has proposed to make a complaint in relation to treatment received due to their
disability. Education providers should take steps to ensure that they offer environ-
ments that are free from harassment and victimisation by having clear statements
in relevant policies, providing professional development, and reminders of expecta-
tions and rights, and having appropriate mechanisms to respond to any instances of
harassment or victimisation. To understand the distinctive importance of the standard
for harassment and victimisation, for the other four standards there is the option for
an education provider to claim the exception of unjustifiable hardship, in case that
Disability Australian Anti-discrimination … 29

compliance with the standards results in an excessive burden. The burden to pro-
vide proof that a reasonable adjustment will cause unjustifiable hardship falls on the
education provider and it is established on a case-by-case basis. Nevertheless, the
exception of unjustifiable hardship does not constitute an exception for the standard
of harassment and victimisation.
We presented an overview of DSE and its key elements. You may have noticed
that there is a very central concept that we haven’t discussed that of disability.

What is your understanding of disability? Can you give a definition? Can

you develop a list of what conditions or impairments are included in your
understanding of disability? What are the inclusion and exclusion criteria that
you used to compile your list?

According to the DDA and DSE, disability refers to:

(a) total or partial loss of the person’s bodily or mental functions; or
(b) total or partial loss of a part of the body; or
(c) the presence in the body of organisms causing disease or illness; or
(d) the presence in the body of organisms capable of causing disease or illness; or
(e) the malfunction, malformation, or disfigurement of a part of the person’s body;
or
(f) a disorder or malfunction that results in the person learning differently from a
person without the disorder or malfunction; or
(g) a disorder, illness, or disease that affects a person’s thought processes, per-
ception of reality, emotions, or judgment or that results in disturbed behaviour
(Commonwealth, 1992, n.p.).
The DDA covers temporary and permanent disability as well as disability that a
person have had in the past or may have in the future or are assumed to have. This
is a definition that is dissimilar to how we usually talk about disability in education,
where we tend to name an impairment or a condition or to refer to broad area of
impact like, learning, behaviour, and so on. The advantage of the DDA definition
is that it allows for the list of conditions or categories of disability to change and
evolve and it is broad. The underlying common element is that there is significant
functioning limitation.
Owen is a student at Blackstone Primary School. He has asthma and the school
has developed an emergency management plan. Lately, Owen’s parents have been
communicating with the school their concerns about Owen being the target of several
bullying incidents. Owen was teased about his weight, he is obese, and he was chased
by several younger students. Owen’s parents want the school to take decisive action
to put a stop to these incidents. Is Owen protected by the Disability Discrimination
Act? Asthma is considered a condition that is protected under the DDA disability
definition, as it may result in loss of functioning. Asthma and allergies are two
conditions for which substantial awareness has developed in recent years in schools.
30 3 Anti-discrimination Legislation and Disability in Education

This is due to the increase in the prevalence of these conditions but also due to
compliance with the DDA. What about obesity? This is an example of how the DDA
disability definition evolves. Until recently, obesity per se was not protected under
the DDA but related health conditions, e.g., diabetes, were. However, the current
information on the Australian Human Rights Commission website states that:
Obesity can be covered by the definition of disability in the Disability Discrimination Act.
The law defines a ‘loss of functioning of a person’s body or part of the body’ as a disability.
Therefore, a person whose weight impairs his or her functioning would be covered (n.d.,
par. 1).

What is the significance of this? All this may appear as a very technical discussion
and to some extent that is the nature of interpretation of any law. Under what condi-
tions are or should obesity being considered a disability is an ongoing discussion in
society, but while this discussion is ongoing, Owen’s needs should to be addressed
in the school. This gives us the opportunity to focus on the core intention of anti-
discrimination disability. The DDA doesn’t give people with disability extra rights;
it makes it unlawful to discriminate against a person with disability. What Owen and
his family want is for Owen to be able to participate in school safe in the knowledge
that the school personnel have the skills to address his needs in case of an emergency
and free from harassment and bullying. This is what education should offer to all
children and students.

Anti-discrimination Legislation in Practice

Disability anti-discrimination legislation has a long history in Australia, and since its
implementation, it has changed the educational experiences of children and students
with disability. However, its implementation has not been straightforward and there
is the recognition that a lot still needs to be done. While the introduction of DSE
in 2005 provided further guidance about the expectation of the law, its adoption
and translation into practice by educational systems, sectors, and schools have been
ongoing. There is an in-built process of reviewing the DSE. There have been two
reviews in 2012 (DEEWR, 2012) and 2015 (Urbis, 2015), and there is evidence
of increased awareness over the years. There is still strong evidence that the key
elements of the legislation that have been discussed in this chapter allow for flexibility
of interpretation on a case-by-case basis. The other side of this is that this broadness
of interpretation can lead to confusion and lack of consistency. As the most recent
review of the DSE states:
The extent to which the objectives of the Standards are achieved is dependent on a range of
factors including the construction and clarity of the Standards themselves. However, where
the Standards provide a static point of reference, the extent to which supporting policies
and programs are developed, funded and effectively implemented is what drives outcome
achievement. (Urbis, 2015, p. ii)
Anti-discrimination Legislation in Practice 31

Some of these supportive policies and policies shape considerably how educa-
tional settings and educators operate. We have mentioned in this chapter, for example,
the Australian Professional Standards for Teachers (Australian Institute for Teaching
and School Leadership (AITSL), 2011), and the EYLF (Department of Education,
Employment and Workplace Relations, 2009). Similarly, the Australian Curriculum
is informed by the DDA and DSE (see Chap. 5). There is another initiative that has
an increased impact in the implementation of the legislation and school practice, the
Nationally Consistent Collection of Data (NCCD). NCCD is an annual data collec-
tion that (a) counts the number of students in schools across Australia who receives
an adjustment, (b) the level of adjustment that they receive, and (c) the broad cat-
egory of disability. NCCD was piloted and progressively implemented from 2013.
From 2018, information provided by the NCCD will be used to calculate the dis-
ability loading provided in the Australian Government funding; the loading is varied
according to the level of adjustment.
We discussed above the disability definition in DDA and DSE. Under NCCD,
this definition collapses into four categories; physical, cognitive, sensory, and
social/emotional. In this categorisation, Sarah has a sensory disability and Owen
has a physical disability. There are four levels of adjustment:
• Support provided within quality differentiated teaching practice
• Supplementary adjustment
• Substantial adjustment
• Extensive adjustment.
The first level, support provided within quality differentiated teaching practice,
recognises that all students require teaching that is responsive to their characteristics
and needs, and for some students with disability, this level of provision is sufficient.
This applies to Owen’s asthma management. This category doesn’t get a funding
disability loading, which applies to the next three levels of adjustments. Moving
from supplementary, to substantial and extensive adjustments, there is evidence of
increased impact of the disability in terms of functioning in specific areas and increase
necessity for the adjustments to be in place, with extensive adjustments being required
all the time. It is important to distinguish in terms of adjustments that are ongoing and
those that have a specific purpose and timeframe. For example, an adjustment may
be temporary, e.g. to facilitate transition, with the expectation that at some point, it
will cease to be used as it won’t serve a purpose. For example, Sarah has a preference
for receiving written instructions and this is a support that Sarah and her teachers
see as ongoing. It is also a practice that assists other students in the class when
instructions, for example, are displayed for all students. Sarah is also very reluctant
to ask clarification questions in class as sometimes she cannot follow the answers
because of the noise. Sarah would like support with that, for example, in the form of
short one-to-one catch-ups with teachers at the end of lessons, but ideally, she would
like to participate more actively in class.
32 3 Anti-discrimination Legislation and Disability in Education

Read again the information provided about Sarah. What adjustments can you
identify? Are any other adjustments that she may require? Are all of them
covered by “support provided within quality differentiated teaching practice”
or do they belong to one of the other levels? What kind of supports is required for
Sarah’s teachers and school for them to be able to implement these adjustments?

As part of the NCCD, the school needs to collect evidence under four categories:
• assessed individual needs of the student
• adjustments being provided to the student to address the disability—this includes
support provided within quality differentiated practice
• ongoing monitoring and review of the adjustments
• consultation, and collaboration with the student and/or parents and carers or
associates (NCCD, n.d., par. 7).
We can see how these NCCD expectations relate to the key elements of the DSE,
as in the need for consultation and ongoing review of adjustments. Looking back
at how we discussed Sarah’s and Owen’s educational experiences in this chapter,
it is evident that anti-discrimination legislation brings together the student, family,
teachers, and schools in identifying what constitutes reasonable adjustments. The
perspective of the person with disability is central in this consultation process.

A Note on Language

Legislation and policy in Australia use person first language. Throughout the book,
we are also using person first language. Person first language puts the person before
the disability. Person first language was a response to disability terms being used
with labelling and negative connotations. We recognise that there isn’t only one
appropriate way to disability language. For many, within a social model of disability
understanding, the use of disabled person or disabled people instead of person with
disability or people with disability is crucial in highlighting the oppression that
disabled people have historically experienced in society. For others, the use of identity
first language is essential in presenting themselves and others without separating the
person from their disability. In that sense, one is autistic rather than a person with
autism. Within the framework discussed in this chapter, it is important that we use
language that is not discriminatory. It is important, therefore, to call out derogatory
use of disability language or deficit-orientated language. At the same time, it is
essential to consult with people with disability about their preferred use of language
and respect their preferences. It is finally important to be open to understand different
perspectives and to learn from them.
Conclusion 33

Conclusion

This chapter provided an overview of a human rights approach to disability in educa-

tion at the international and national level. The Disability Discrimination Act 1992
and Disability Standards in Education 2005 were discussed in detail, in planning
and developing services, planning for individual students with the use of reason-
able adjustments, and responding to circumstances of discrimination, harassment
or victimisation. The implementation of the standards is dependent on educational
settings and educators having an understanding of their responsibilities in realising
an equitable education.

References

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gov.au/quick-guide/12069.
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standards for teachers. Carlton, VIC: Education Services Australia.
Avery, S. (2018). Culture is inclusion: A narrative of Aboriginal Torres Strait Islander people with
disability. Sydney: First Peoples Disability Network (Australia).
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www.austlii.edu.au/au/legis/cth/consol_act/dda1992264/.
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you have evidence to support the student’s inclusion in the data collection? Retrieved from http://
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Spandagou, I. (2018). A long journey: Disability and inclusive education in international law. In K.
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34 3 Anti-discrimination Legislation and Disability in Education

Additional Readings

Commonwealth of Australia FaHCSIA. (2009). SHUT OUT: The experience of people with disabil-
ities and their families in Australia-National Disability Strategy Consultation Report. Canberra:
Author.
de Bruin, K. (2019). The impact of inclusive education reforms on students with disability: An
international comparison. International Journal of Inclusive Education, 23(7–8), 811–826.
Dunn, D., & Andrews, E. (2015). Person first and identity-first language developing psychologists’
cultural competence using disability language. American Psychologist, 70(3), 255–264. https://
doi.org/10.1037/a0038636.