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Disability and Mental Health in the Workplace

A complex area

In discrimination law, a disability is quite widely defined. A disability is “a physical or mental condition which has a long-term and substantial effect on someone’s day to day life”. In order to consider whether an employee is disabled, the individual’s personal circumstances must be considered.

Disability and Mental Health in the Workplace

A disability could be a physical condition or illness, but it could also be a mental health condition, such as depression, or an “invisible” disability such as a learning disability. Some conditions are automatically treated as a disability by the law, such as cancer or diabetes.

Mental Health in the Workplace Policy

A comprehensive mental health in the workplace policy is essential for promoting the well-being of employees and fostering a supportive and productive work environment. Such a policy outlines the organisation’s commitment to mental health, detailing the resources and support available to employees experiencing mental health issues. It includes provisions for raising awareness, reducing stigma, and encouraging open dialogue about mental health. Additionally, the policy should specify procedures for accessing mental health services, training for managers to recognise and respond to mental health concerns, and guidelines for making reasonable adjustments to accommodate employees’ needs. By implementing a robust mental health policy, employers can enhance employee morale, reduce absenteeism, and improve overall workplace performance.

Is Depression a Disability?

Depression can indeed be considered a disability under the Equality Act 2010 in the UK if it has a substantial and long-term adverse effect on an individual’s ability to carry out normal day-to-day activities. This means that if a person’s depression is severe enough to impact their everyday functioning and lasts or is expected to last for at least 12 months, it qualifies as a disability. Employers are required to make reasonable adjustments to support employees with depression, such as flexible working arrangements, changes in duties, or providing access to counselling services. Recognising depression as a disability ensures that individuals receive the necessary support and protection against discrimination in the workplace.

Employees (or job applicants and prospective employees) must not be treated differently, unfairly or less favourably because of their disability. The law provides protection from:

  • Direct discrimination (being treated less favourably because of their disability).
  • Indirect discrimination (being at a disadvantage because of a seemingly neutral provision, criterion or practice (PCP)). This could include, for example, the requirement that all employees must have driving licence. Whilst this is on the face of it neutral, it is likely to discriminate against those who are visually impaired.  When a driving licence is not necessary for the role, this requirement would be indirectly discriminatory.
  • Victimisation (being subjected to a detriment because of a complaint about discrimination or assisting a victim of discrimination i.e. by being a witness for them or a ‘companion’ at meetings).
  • Harassment, including sexual harassment (being subjected to unwanted conduct related to their disability, which violates dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment).

Employers have a duty to make reasonable adjustments to the workplace or an individual’s duties or working regime if an individual would be placed at a disadvantage because of their disability. Obvious examples of this are making physical adjustments to the workplace, but the duty could also include making reasonable changes to shift patterns, hours or even amendments to the organisation’s sickness policy, or allowing the employee to take more breaks throughout the day. It depends entirely on the disability and the needs of the individual.

As well discriminating, directly or indirectly because of the disability itself, employers must
be mindful of not treating someone unfairly because of consequences or symptoms that arise from their disability. This includes, for example, the side effects of medication taken in order to reduce the effects of disability. If employee is treated unfairly because of this, it could well be unlawful. Another example would be an employee with cancer being deprived of a bonus because of time off to receive treatment.

Some forms of discrimination can never be justified for example direct discrimination (refusing to recruit a disabled candidate), and are always unlawful. However, other forms of discrimination are not unlawful because of an employer’s ability to justify why the discrimination is needed. For example there is a real business need for a policy (PCP) which indirectly discriminates. For there to be justification an employer must show that the PCP is a proportionate means of achieving a legitimate aim (a real business need). Justification in this way only applies to indirect discrimination and discrimination arising from a disability. The tests for whether treatment is objectively justified are slightly different for each form of discrimination, so it is important to take advice on the specific circumstances. By way of illustration, going back to the above example of the driving licence requirement, if the role is for a delivery driver, then that provision might be indirectly discriminatory – but it could be justified!

It is also unlawful to subject someone to harassment related to disability, or to victimise them because they have made or intend to make a disability discrimination complaint. For more information on the forms of discrimination, please visit our Inclusion and Diversity section.