Internal Stakeholder Analysis Report


This report details the responses provided by each of the Directorates at Brighton & Hove City Council as part of the internal stakeholder analysis.

We attended a leadership team meeting with each Directorate to provide background to the Accessible City Strategy and the work this project was intended to undertake.

At each leadership team meeting there was a significant amount of enthusiasm expressed and commitments made to engage in follow up discussions about what accessibility meant to each Directorate. However, despite several requests, there was very limited engagement following these meetings. This has a major limiting impact on the amount and type of information this report can provide.

Additionally, we reviewed Directorate Business Plans to seek further opportunities to reflect the work of each business area and included this where possible.

The information provided tended to focus either on existing projects which Directorates are currently undertaking or broader and more generic accessibility issues (such as the importance of accessible communication routes). It is also worth noting their comments were more related to what a strategy might include rather than the process they will need to undertake to successfully support its development.

This indicates there is likely to be a need for a significant amount of support and direction to be provided by the EDI team as contributions to the strategy are sought from Directorates.

Directorate Analysis

Health & Adult Social Care

There was a recognition that an accessible city is one that is designed in a way that disabled people can live as they wish to, with choice and control. This needs to be much broader than access to statutory services and also incorporate quality of life. It should give disabled people the ability to access all services easily and in a timely way, without barriers. There was an acknowledgement that currently some disabled people have unequal outcomes and that equity rather than equality should be the driver.

The engagement of disabled people was seen as critical in understanding the goals of disabled people and avoiding a situation where the views of the Council are imposed on them.

Wider legislation clearly has a significant impact on the work of this Directorate and this needs to be part of an Accessible City Strategy.  The Care Act does set clear criteria for access to services, which may create a bar for people in some circumstances.

Access to resources is also seen as a barrier that this may prevent a wider focus on achieving people’s full potential.

The Directorate saw its role as one of signposting and partnership working in order to build equal outcomes for disabled people. Part of this is a need to seek advocacy partnerships across a range of disabilities and health impacts and a recognition that it needs to have conversations with different communities to understand the range of support options that may be required.

The Directorate wants to be part of a fair city with the best opportunities for all, including disabled people in order to reduce inequalities.

It felt that the attitude and approach of the wider community was important, which included a need for education and awareness interventions.

One of the key priorities of the Directorate was identified as mental health, particularly as the City starts to come out of its Covid response. This was linked to the importance of promoting a Dementia Friendly City.

It also recognised the opportunities it has to influence the outcomes for disabled people through connections with the NHS, CCG, mental health foundation oversight board, community services, care networks and 3rd sector providers in the City. Co-production of services across both Council Directorates and wider partners was seen as integral to accessibility for all.

On a practical note, it was acknowledged that the Council health impact assessment needed to include disability and accessibility in order to improve its effectiveness.

Language and labels were also seen as a key element to consider when developing an Accessible City Strategy. There was a view that the term “services” may not always be helpful and may lead some disabled people to feel limited by this label.

Housing, Neighbourhood & Communities

This Directorate recognised the need to building homes for the future, which are created from the start as “lifetime homes”. This included a focus on building homes for families, including those with children who have a disability.

Part of this focus is around the need for people to feel safe in their homes and neighbourhoods and to build safer communities. Therefore addressing Anti-Social behaviour and disability related hate crime was seen as critical.

Information sharing across the Council and with other service providers was identified as a key issue. An important aspect of accessibility was seen to be how residents can access information, including through digital means.

One of the key lessons learnt from the COVID response was seen to be the proven agility of services. The Directorate is committed to ensuring this is not lost as they come out of the immediate response to the pandemic.

Families, Children & Learning

This Directorate highlighted a wide range of services and support that they provided for disabled people, including children and families. The development and implementation of the SEND strategy and SEN plan was seen as a critical element of this delivery plan.

A number of projects within schools were highlighted including:

·         The Accessibility Plan which each school has, published on their website and which the Board of Governors review

·         Front line practitioner sessions were being delivered, both in mainstream and special school provision.

·         A home to school improvement plan was in place.

Accessibility was seen to include a wide range of issues including:

·         Health outcomes

·         The involvement of business

·         The impact on the environment

·         Access to public transport

In terms of wider issues to be addressed within the Accessible City Strategy, this Directorate highlighted:

·         The City infrastructure is challenging and should be considered when looking at accessibility

·         It is important to engage with non-disabled people to build awareness around accessibility and the inclusion of disabled people

Strategy, Governance & Law

In this Directorate accessibility was identified as having confidence that the disabled persons voice was heard in the democratic process.  This included ensuring that all Council meetings are accessible to the public, both in terms of physical space and support a disabled person may need during the meetings.

It was about consistency across Directorate’s which led to a 1 Council approach. This required a clearer alignment of projects across the Council, which would avoid ad hoc projects and a stronger framework in the corporate plan for how to ensure an accessible city is built and developed. Procurement was identified as a specific workstream where accessibility was important.

Communication and engagement was seen as key, particularly in ensuring the Directorate was hearing the responses of disabled people. Part of this challenge was ensuring appropriate channels through which disabled people could communicate

Specific areas to address within this Directorate included:

·         Access to cemeteries, including those on the risk register and where signage needed to be improved

·         Access to registration services (death, marriage, approved venues) with the desire to maintain changes made during the COVID response which allowed people to access these services online.

·         Electoral services including providing safe elections, voting venues and count venues

·         Conducting an impact assessment before any major project was commenced (e.g. refurbishment of building projects).

Finance & Resources

The Directorates welfare support response was highlighted as a key contribution to the Accessible City Strategy. This includes

·         mental health support

·         addressing issues benefit dependency and debt for disabled people

·         addressing the post-COVID response for this Directorate, including the reduction in COVID specific funding which was anticipated

The local transport plan was also identified as an issue to consider, including travel, bus partnerships and the impact of kerb heights.

Digital accessibility was identified as important, with links made to the Customer Digital Strategy. Specifically this was about the need to ensure that planning and consultation portals were accessible for disabled people.

Economy, Environment and Culture

This Directorate has responsibility for a wide range of services, many of which link in with wider Council departments.

A key element of this was planning, building controls and regeneration.  There was a recognition of the need to provide genuinely affordable homes, which are accessible and fit for purpose. An opportunity to achieve this was identified when working on affordable housing developments, where the Directorate recognises the importance of working with partners to ensure properties are accessible and fit for the future

Currently all buildings are accessible within current legal requirements, although there is a desire to stretch beyond this legal minimum. To achieve this, inclusion by design principles will need to be built into specifications. This is currently governed by the National Planning Policy Framework.

The implementation of the City Plan is also a key driver in ensuring access is maintained. Equality Impact Assessments that are completed for planning and building controls (which cover equality, public interest and sustainability) can support in this process.

As a corporate landlord, the Directorate recognises the need to ensure physical and cognitive access to disabled customers.

As has been acknowledged by a number of Directorates, Brighton & Hove is a densely populated city with a high number of heritage buildings and old infrastructure. This can limit the changes that can be made to these buildings and may reduce the accessibility options. However, it is still acknowledged that the City needs to make reasonable adjustments to allow disabled people to access these buildings where possible.

The Directorate also recognises its role in supporting local businesses to be accessible, by understanding and delivering the needs of disabled people. There can be conflicts here, as the COVID response has led to an increasing number of businesses operating outside. However, this does have the potential to negatively impact on disabled people (e.g. by limiting the physical space to move around the City)

The visitor economy, was seen as critical to Brighton & Hove and linked to this was the importance of accessibility of information and services. This linked into the wide range of public events organised by BHCC, with a recognition that accessibility needed to be taken into account when organising such events.

There was a further recognition that BHCC had a unique opportunity to support the creative expression of disabled people and saw opportunities to commission art and other similar installations that recognised this talent.

This Directorate also has responsibility for environmental services, including parks, outside space and green spaces. As an example, there was a commitment to better communicate where walking paths were and to maintain these paths appropriately to allow wider access.

The Local Transport Plan was flagged, with a recognition that accessibility was key to the success of this.  An important element of the Local Transport Plan was the Active Travel project and there was an ongoing focus on accessibility for disabled people as part of this.

Given the broad nature of the work this Directorate undertakes, there was a concern that accessibility could have a significant cost implication for this department. There was a strong commitment to deliver on this agenda, provided that the appropriate level of resource was provided to achieve this. As an example, any major infrastructure projects would involve significant investment, if BHCC wanted to go beyond the projects already being implemented.


It can be seen there is a significant amount of thinking which has already been undertaken and enthusiasm for these issues in the individual Directorates. However, care will need to be taken to ensure this is converted into prioritised, practical actions and outcomes and that cross Directorate issues are picked up to ensure a coherent Council wide approach.

The EDI team will need to support Directorates in how to focus their thinking at a strategic level, rather than addressing individual activities.