Chapter 26 - Inclusive Practice within Teaching and Learning


  1. Introduction
       Aspiration statements
    1. The University of Exeter has always welcomed and supported disabled students to be part of its rich learning community and strives to enable all students to reach their full academic potential. The University has embraced its responsibilities within existing diversity and equality legislation and developed models of practice in keeping with institutional obligations and at the forefront of sector provision.
    2. The University is fully committed to adopting an inclusive approach to teaching and learning. This is clearly embodied in the aims of the University’s Education Strategy. All programmes of study consider how to increase access for marginalised communities and ensure that no-one is disadvantaged in their learning because of their disability.
    3. The University understands and embraces the social model of disability, which recognises that people are disabled because of the barriers society puts up; not because of their specific disability. The University further adopts an inclusive approach to staff, students and the community.
    4. The University is also committed to the provision of individual reasonable adjustments to ensure that disabled students are not placed at a substantial disadvantage when compared with their peers. The University seeks to uphold this principle, noting the requirement to make reasonable adjustments insofar as they do not compromise the integrity of academic competency standards.

      Legislative Background 
    5. The University is aware of, and has regard to the legislative background in which it operates. The Equality Act 2010 (“the Act”) makes it clear that the University is legally bound to facilitate disabled access to Higher Education. The University understands that compliance with this obligation could involve treating some people more favourably than others. The Act also provides protection against discrimination, harassment and victimisation on the grounds of disability.
    6. The Act also sets out the general equality duty which applies to all public sector organisations and requires the University to have ‘due regard’ for advancing equality. The University is required to:

      a) Remove or minimise disadvantages suffered by people due to their disability.
      b) Take steps to meet their individual and collective needs.
      c) Encourage participation in public life or in other activities where their participation is disproportionately low.
    7. Additionally, the University has an anticipatory duty to act in advance and make adjustments so as to remove any disadvantage that might reasonably be foreseen as likely to affect students with disabilities. Whilst this may appear to present challenges, insuring the University embeds inclusive teaching and learning practices within all education provision means many of these requirements will already be met.
    8. The way in which the University complies with these legal obligations is detailed within this policy. All staff are expected to adhere to this policy.
  2. Definitions Referred to within this Policy
    1. For the purpose of this policy the University uses the definition of ‘inclusive learning and teaching’ as stated by the Higher Education Academy

      “Inclusive learning and teaching recognises all students' entitlement to a learning experience that respects diversity, enables participation, removes barriers and anticipates and considers a variety of learning needs and preferences. Inclusive learning takes into account educational, cultural and social background and experience, physical or sensory impairment and mental well-being. Students may be less able to learn if they are not included and feel that they belong. All staff and students benefit from learning that acknowledges and draws upon differences and commonalities and is based on principles of equity, collaboration, flexibility and accountability.”
    2. The University uses the same definition of disability as found in the Act namely that “A person (P) has a disability if – (a) P has a physical or mental impairment and (b) the impairment has a substantial and long-term adverse effect on P’s ability to carry out normal day to day activities”.
    3. The Act requires that the University make reasonable adjustments to ensure that a disabled student is not placed at a substantial disadvantage when compared to their peers.
    4. The Act also places on the University a duty to ensure that there is no discrimination against a disabled student, either directly or indirectly.
    5. Direct Discrimination: is treating a student with a disability less favourably than a student without a disability on the basis of that disability.
    6. Indirect Discrimination: occurs when provisions, criteria or practices are applied in the same way for all students or a particular student group, but have the effect of putting students with a disability at a particular disadvantage. Indirect discrimination may arise even if it is not the intention to put disabled students at a disadvantage.
    7. Knowledge of Disability: if the University treats a disabled student in an unfavourable way it will be unlawful unless the University does not know that the student is disabled and/or could not have been reasonable expected to know the student is disabled. It is important to note that the University is deemed to know the moment a student informs any member of staff they have a disability, unless they request absolute confidentially. Therefore it is important at this point that the member of staff to whom they have disclosed their disability refers the student to the Wellbeing Services, Mental Health Pathway, AccessAbility and the Accessibility Services.
  3. Definitions of Reasonable Adjustments and Competency Standards 
    1. Reasonable Adjustments are put in place for disabled students to avoid discrimination arising from disability, and remove barriers to learning and teaching for disabled students. The application of an adjustment will result from consideration of the circumstances of the individual student and will involve discussions with the student regarding possible courses of action. What is ‘reasonable’ for the University will vary according to a range of factors and will depend on the circumstances of the individual case. Factors influencing the determination of what is reasonable will include the effectiveness of taking particular steps in enabling the student to overcome the particular disadvantage, health and safety issues, the effect on other students and the cost to the University.
    2. There is no requirement to make a reasonable adjustment to a competency standard which the Act defines as ‘an academic, medical, or other standard applied by or on behalf of an education provider for the purpose of determining whether or not a person has a particular level of competence or ability’.
    3. It is important that competence standards set by the University are assessed internally to ensure that they do not have a discriminatory impact on students with disabilities or certain groups of disabled students. If a competence standard is found to be discriminatory, then to remain lawful they must be ‘objectively justifiable’; that is, they must be a ‘proportionate means of achieving a legitimate aim’.
    4. A ‘legitimate aim’ would be any lawful decision made in running programmes or modules, but if there is a discriminatory effect, the sole aim of reducing costs is unlikely to be lawful. ‘Proportionate’ means that there must be no other way of achieving that aim which would be less detrimental to the rights of students with disabilities.
    5. Sometimes the process of assessing whether a competence standard has been achieved is inextricably linked to the standard itself. The passing of an assessment may be conditional upon having a practical skill or ability which must be demonstrated by completing a practical test. Therefore, in relatively rare circumstances, the ability to take the test may itself amount to a competence standard. This is particularly relevant to programmes where the competence standards may be prescribed by an external professional body (e.g. medicine and education) and may be linked to fitness to practice.
    6. The University’s way of implementing reasonable adjustments is through an Individual Learning Plan (“ILP”). This is following an assessment by a competent professional who has assessed a student’s need and written the ILP on this basis. The ILP lists the adjustments the student requires, it does not, nor is there any legal requirement that the ILP includes information on the student’s specific diagnosis or disability. Students are encouraged to discuss their needs with other staff beyond the professional drawing up the ILP, however this is not a requirement. ILPs apply equally to both formative and summative assessment. 
  4. Roles and Responsibilities 

    This section sets out the various responsibilities on behalf of specific parts of the University as well as the University’s overall responsibilities.
    1. Responsibilities of the University

      The responsibilities of the University are as follows:

      a) The University is under a legal duty to comply with the Act.
      b) The University is committed to inclusive practice and to support a diverse population of students.
      c) The University is committed to ensuring all students can learn effectively.
    2. Responsibilities of the Wellbeing Services, Mental Health Pathway, AccessAbility and the Accessibility Services 

      The services are collectively responsible for the following:

      a) Reviewing relevant documentary evidence/information and writing up ILPs.
      b) Meeting with the student to assess their needs.
      c) Reviewing ILPs when requested.
      d) Liaising with relevant staff where non-standard adjustments are required.
      e) Inputting the ILP onto the Student Record System ('SRS').
    3. Responsibilities of the Exams Office 

      The Exams Office is responsible for the following (note for the BM/BS, these responsibilities maybe carried out by the local assessments team, who should implement any exam requirements as stated on the ILP, liaising with the relevant services as required):

      a) Implementing the required adjustments by a student’s ILP, providing it is received by the deadline.
      b) Liaising with the Wellbeing Service as required over any specific adjustments, or over the provision of any specific materials or support, i.e. specialist chairs or a scribe.
      c) If requests are made after the deadline, making reasonable attempts to accommodate these requests, given the constraints of the exam timetable. (If the required adjustments are not able to be made by the Exams Office, a student should contact their College who may be able to arrange for the exam to be sat in College with the required adjustments, or if this is not possible then deferring the exam.)
    4. Responsibilities of Colleges (or equivalent) 

      The College (or equivalent) is responsible for the following:

      a) The Associate Dean for Education and Associate Dean for Research (or equivalent) is responsible for ensuring that all ILPs within a College are complied with. At the Discipline level the Director of Education and Director of Research/Director of Postgraduate Research (PGR) (or equivalent) is responsible for ensuring all ILPs are complied with.
      b) Where organised at College level, mid-term/in class tests/exams: making the required reasonable adjustments.
      c) Ensuring that when the College is directed to do something, that someone is undertaking this action.
      d) Should a personal tutor be incorrectly recorded in SITS, to ensure that the ILP is sent to the correct personal tutor and SITS updated accordingly.
      e) Respond to student enquiries about how their ILP will be implemented.
      f) Respond to student requests for extensions and mitigation based on their ILP.
      g) For the BM/BS it is for the Programme Administrators to ensure that the Student receives any slides in advance of the teaching sessions.

    5. Individual Responsibility for all Teaching and Research Staff

      Individual members of staff who are teaching or supervising a student with an ILP have the following responsibilities:

      a) Where the member of staff is the Module Convenor or Programme Lead, ensuring that all members of the students teaching staff are aware of any adjustments they are required to make. Please note this includes any Graduate Teaching Assistants, Guest Lecturers, or Technicians who are delivering any parts of the module.
      b) Where the member of staff is the Lead Supervisor, ensuring that all others on the supervisory team are aware of a student’s ILP, including the Mentor.
      c) Implementing the ILP.
      d) If part of the ILP is not understood or it is not possible to implement a certain adjustment, to discuss this with the relevant Service as soon as possible (details on how to do this are included in section 10.2).
      e) Discuss with the Senior Tutor/Mentor as appropriate.

    6. Individual Student Responsibilities 

      a) To ensure that they declare their disability to the University and any partner institutions for students engaging in study abroad programmes. The University can only act and support a student if it is aware of a student’s needs.
      b) Attend the appointment to agree the ILP, and provide relevant documentation as required.
      c) Give consent to share the information in their ILP, to ensure reasonable adjustments can be put in place. If consent is not given this will limit what adjustments can be made for the relevant student.
      d) Engage with the recommendations within the ILP, and the support processes put in place as part of the ILP.
      e) Ensure once the ILP has been created that they take the time to review the ILP and respond to the advisor if there are any problems.
      f) Understand that there are deadlines by which the Exams Office has to be in receipt of all ILPs so they can put in place adjustments for centrally organised exams.
      g) Inform the University if their adjustments are not being made so the University can remedy this as soon as they are made aware (details on how to do this are included in section 5.9).
      h) Students also need to be aware that their ILP is a living document and they need to keep the University informed of any changes which need to be made (e.g. if attending a field trip requires additional adjustments) and allow plenty of time for these to be made.
  5. Summary of the Process of getting an Individual Learning Plan. 
    1. The student must disclose to the University that they have a disability. If this is done prior to arrival i.e. as part of a UCAS application form, then the student will be contacted by Wellbeing Services (Mental Health Pathway, AccessAbility and Accessibility). The student may also make a disclosure in year to any member of staff; it is important at this point that the member of staff refers the student to Wellbeing Services (Mental Health Pathway, AccessAbility and Accessibility) for an assessment.
    2. The student will then be assessed and full consideration will be given to their needs. As part of this assessment the relevant advisor will draw up an ILP. The student may or may not be happy for their College to know their disability, therefore it may or may not be stated on the ILP itself. The ILP is the University’s way of communicating what reasonable adjustments a disabled student requires. Its recommendations are adjustments the advisors consider required, in good faith, so that students are able to perform without barriers to their learning.
    3. The advisor will then explain to the student that this document will be shared with the student’s College and the Exams Office to ensure that all necessary adjustments can be put in place. Students should be aware that the ILP is a living document and that they will need to be reassessed if their needs change.
    4. The advisor will also give advice about Disabled Students’ Allowance where this is relevant.
    5. The advisor will then input the ILP into SRS which then notifies the relevant College, who will then ensure that all those who are teaching the student are aware of the required adjustments.
    6. The student is then informed that their ILP is in place and they are requested to review it to ensure it is accurate. The student has 2 weeks to discuss this further with the relevant advisor after which point the ILP is live.
    7. The Exams Office will be responsible for all provisions within centrally arranged exams. The College will be responsible for these provisions being organised for any in class tests, or non-centrally organised exams.
    8. The relevant member of staff then makes the required adjustments. If it is not possible to make the recommended adjustment then the member of staff must follow the procedure below in section 10.
    9. If a Taught Student does not believe their ILP is being correctly implemented, then they must raise this with the Student Services Hub/College Office, who shall then consider this as an informal complaint as under the Student Complaints Procedure. The Hub Manger shall investigate, as per the Complaints procedure, and respond to the Student within the timescales published in the procedure. The student is able to escalate the matter in line with the Complaints Procedure if they do not receive a satisfactory response.
    10. If a Postgraduate Research Student does not believe their ILP is being correctly implemented, then they must raise this with the PGR Manager HASS/STEMM, who shall then consider this as an informal complaint as under the Student Complaints Procedure. The PGR Manager HASS/STEMM shall investigate, as per the Complaints procedure, and respond to the Student within the timescales published in the procedure. The student is able to escalate the matter in line with the Complaints Procedure if they do not receive a satisfactory response.
  6. Students who are on courses leading to professional qualifications 
    1. Students on a professional qualification courses will have professional standards to meet, set by the accrediting/awarding body. Therefore there will be additional competency standards for these courses. Such courses will involve a fitness to practice assessment which may make recommendations in addition to those within an ILP. However, as set out in this policy, the principle of provision of reasonable adjustments still needs to be adhered to.
    2. The competency standards/learning outcomes for each module must be explicit. Reasonable adjustments cannot be made to these competency standards but can be made where there is an identified barrier to learning and that barrier is not a competence standard.
  7. Postgraduate Research Students 
    1. It is recognised that PGR students’ method of engagement in studying is different from that of Taught Students and therefore the types of adjustments are likely to reflect this. PGR Students are also subject to the full range of responsibilities listed about in section 4.6.
    2. An ILP for a PGR Student may suggest specific adjustments to their study space, or pattern. They may also recommend specific tutoring based on their needs assessments, or that the PGR student would benefit from specific software or equipment.
    3. PGR Students need to be aware that whilst an ILP may result in some flexibility with deadlines where appropriate they also need to show adequate progress in their research. They need to be prepared to engage with relevant services to ensure that this is the case.
    4. PGR Students should be aware that should they need an ILP, they should seek to have this drawn up as soon as possible. Indeed, it may be possible to have one put in place prior to registration. PGR students should be aware that their ILP is a living document and should ensure it is kept up to date with any developments.
    5. PGR Students should be aware there are a number of points in the cycle of their study where they may need to seek specific adjustments through the creation or review of an ILP. As supervision agreements are reviewed annually, it is advisable to review the ILP at the same time, with updates made to the supervision agreement to take into account the ILP as needed. Preparing to submit any work for formal review should also trigger a PGR Student to ensure that their ILP is up to date with any adjustments they require, this could be a submission for consideration by a College Upgrade Committee, or submission of their work for examination.
    6. The ILP will then be communicated, normally via the Student Record System (SRS) to the student’s College, the supervisory team and mentor, and the Postgraduate Administration Office.
    7. Where adjustments are made to the examination process an NEIC must normally be appointed, unless a case can be made as to why the NEIC is not needed (e.g. if very minor adjustments only are being made.
    8. Where adjustments are required to the examination process these will be implemented in line with the provisions within Chapter 12 of the PGR Handbook – Handbook for Examination of Postgraduate Research Programmes – specifically section 3 Assessing Candidates with Disabilities and section 4 Nomination of the Board of Examiners and the Non-Examining Independent Chair.
    9. All PGR facing staff (e.g. supervisory staff, Professional Services Staff, discipline and College Directors of PGR and the Associate Dean for Research and Knowledge Transfer) should also be aware that they need to be prepared to discuss specific student needs with both the individual student and with the relevant advisor to ensure there is no barrier to a disabled student from achieving their potential.
    10. For PGR Students who are also engaged as members of University staff for any purpose, any adjustments required to their working practice need to be handled by Occupational Health, and not through an ILP.
  8. Students who are on Study Abroad 
    1. The University offers opportunities for their students to study abroad as part of their programme of study (“outbound”), as well as for students attending Exeter as part of their degrees from other institutions (“inbound”).
    2. For outbound students the University cannot guarantee that any specific adjustments that they have in place at Exeter will be put in place by the host institution, as they are not bound by UK law.
    3. Students should consult with the Wellbeing Service as well, who may be able to provide them with guidance on local support. Study Abroad co-ordinators may also be able to provide advice about host institutions.
    4. Should the student meet with the Wellbeing Service, and give their consent to share their personal information, then the Wellbeing Service can forward on any additional information to the Study Abroad co-ordinator, who should then make this available to the host institution.
    5. Outbound students need to recognise that they are adults undertaking study abroad, and whilst the University may be able to provide advice on the most suitable placement, it recognises that this is the student’s choice. It is also the student’s choice to select their study abroad option without consultation with the University. Students should also make their host institution aware of their needs in advance of their placement and provide the host institution with a copy of their ILP.
    6. Inbound students will be treated with equivalence to Exeter students, however there maybe limitations if the student is only studying for a term, unless they are in contact with the relevant services prior to arrival.
  9. Students who have a Temporary/Transitory Illness 
    1. The term ‘temporary injury’ applies to students who experience a short term, acute physical injury and require temporary adjustments to continue their studies. The term transitory illness applies to students who are experiencing a short-term, acute physical or mental health condition, which does not meet the criteria of a disability under the Act, but means that they require temporary adjustments to continue their studies.
    2. Students who require adjustments due to an injury or transitory illness will be set up with a temporary ILP. Students must contact Wellbeing Services (Mental Health Pathway, AccessAbility and Accessibility) with relevant medical evidence to make arrangements for a temporary ILP to be created. Wellbeing Services (Mental Health Pathway, AccessAbility and Accessibility) will advise the student on the duration of their ILP. A provisional end date will apply to the specific adjustments recommended on a temporary basis. It is a student’s responsibility to check their ILP and any recommended adjustments end date. If the injury or illness is likely to continue past this end date, the student should contact Wellbeing Services (Mental Health Pathway, AccessAbility and Accessibility) to arrange a review of their ILP.
    3. Students should be aware that temporary exam adjustments requested after the specific provision deadline will be reviewed on a case by case basis. The University will endeavour to put the exam recommendations of the temporary ILP in place but if the University is unable to facilitate the necessary adjustments in time for a student’s exam, given the constraints of the exam timetable, then students should be advised to contact their College to discuss applying for mitigation with the aim of deferring the exam.
    4. Students who become injured or unwell up to 48 hours before an exam should be directed to contact their College to discuss their options including applying for mitigation.
  10. Clarifying the Nature and Content of Individual Learning Plans
    1. If the student does not agree with the content of their ILP then they should write to the Head of the Wellbeing Services (Mental Health Pathway, AccessAbility and Accessibility), and explain why they do not agree with the recommendation(s). The Head of Wellbeing will then review the ILP, and then may confirm that the appropriate adjustments have been made, or that there should be additional adjustments made.
    2. If a College/member of staff does not agree with a recommended adjustment or that a specific adjustment is not possible or feasible then they should seek to engage in a dialogue with the advisor responsible for the plan. Staff need to be aware that advisors are experts in their respective fields, but cannot know the details of every programme at the University. Staff should not hesitate to engage in a discussion about ILP recommendations where it would compromise an intended learning outcome, or the required adjustment is not possible or feasible on the student’s programme. The aim would be to ascertain whether there is an alternative adjustment that can be put in place and ensure that the student achieves the relevant intended learning outcome.
    3. The College/member of staff and advisor should discuss why the recommendation is not a reasonable adjustment, or not possible or feasible. The primary nature of the adjustments must be at the centre of this discussion, i.e. the removal of barriers to learning and teaching which place the student at a disadvantage as a result of their disability. If another method of removing this barrier is proposed and felt by the academic and advisor to be reasonable, then a discussion needs to be held with the student, to inform them of this. It may be appropriate for the College to discuss and negotiate alternatives to the recommended adjustment first to see if an agreed alternative can be put in place.
    4. There may also be cases whereby modules have been designed to be accessible from the outset, and therefore adjustments are not required to the module. Should this be the case then the academic responsible for the module should clarify with the advisor that the required adjustment is not applicable due to the way the module is designed, and then inform the student of this.
    5. If an appropriate adjustment cannot be agreed, then the matter should be referred to the Director of Education/Discipline Director of PGR for initial mediation, this should involve discussing any and all options with the Student. If the Director of Education or Discipline Director of PGR (or equivalent) cannot resolve this matter to the agreement of all parties then the matter should be referred to the Associate Dean for Education for the College or College Director of Postgraduate Research (or equivalent). The ADE/DPGR will hear from all parties, and may seek legal advice as to the risk to the College from not complying with the adjustment. The ADE/DPGR will have the final decision on whether to implement the adjustment or not.
  11. Monitoring
    1. The implementation of ILPs within each College is the responsibility of the Associate Dean for Education (or equivalent) and the Directors of Education. In the case of PGR students the responsibility rests with the College Director of Postgraduate Researchers and the Discipline Directors of Postgraduate Research (or equivalent, e.g. Director of Doctoral Studies). Implementation of ILPs should be monitored through the Annual Student Experience Review (“ASER”)
    2. As part of the Discipline level ASER meeting Disciplines should discuss their adherence to ILPs and review the report from SRS on how many ILPs remain unread within their Discipline. This is recorded within Annex A of the Quality Review Framework.
    3. At the College level this should be considered College wide as to how many ILPs have not been read or actioned by the College, and if improvement is required this should be recorded within the ASER action plan.
    4. Colleges should be mindful that at the University level meeting, which occurs in the Spring Term, Colleges maybe asked about their implementation of ILPs, as non-compliance may prove to be a substantial educational and institutional risk.

Appendix A

Guidance for marking scripts for students with specific learning difficulties

According to the Equality Act of 2010, Higher Education Institutions have an anticipatory duty to make reasonable adjustments to ensure that disabled students are not less favourably treated. In this respect, the marking system in these guidelines should be seen as a levelling of the playing field rather than leniency.

These guidelines are intended to assist academic staff when assessing the written work of students who have diagnosed specific learning difficulties, such as dyslexia or dyspraxia, and have ‘Marking Guidelines’ as a requirement within their ILP. They are intended to avoid penalising the written work of such students for features associated with their specific learning difficulty. However, whilst language-based errors may not be a barrier to demonstrating knowledge, understanding and ideas, in certain subjects these guidelines should not compromise competence standards, or core learning outcomes.

General guidelines for marking

There are a range of common characteristics that may be evident in the written work of students with specific learning difficulties; they are likely to make more spelling errors, even in word processed work; punctuation, grammar and sentence structure may be weak; their proof reading skills tend to be unreliable; and language structure may be unsophisticated with omitted or repeated information, words or phrases.

Read quickly initially, to assess for ideas, understanding and knowledge.

Aim for a clear separation between the content of the work and language errors, to ensure there is no subjective interpretation of the student's ability.

Mark principally for content and understanding - disregarding, as far as possible, errors in spelling, grammar and punctuation.

Be very clear about the marking criteria, especially in terms of spelling, grammar and punctuation.

Avoid using red to denote errors, due to negative associations that the student may have encountered in the past.

Ensure that feedback is clear, constructive and sensitive to the student’s difficulties. Write legibly, avoiding complex sentence structures.

Error Analysis Marking

Even if you are marking without penalising for mistakes in the technical use of language, students do need help to develop their written English skills. The following marking system will help a student to aim towards independent learning, as long as it is augmented with explanations, examples and models of good practice.

Error analysis marking encourages the student to find and correct errors identified by a tutor through a coded mark in the margin e.g. Sp - spelling, G -grammar, SS - sentence structure, P - punctuation, V - vocabulary, O - word omission, R - repetition, T - tense.
Using this guidance the student will examine the line of writing, identify the highlighted error and attempt to correct it. Once a student learns to identify particular types of error, s/he can begin to check their own work and re-draft accordingly.

Last reviewed August 2020

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