The Dictum of Equal Applicability

"Let justice be done though the heavens fall" 

William Watson, 1602

Right.. this has to be perceived of as fair. So, we get the whiskered berk to stand just 
there clenching the email between his arse cheeks... if he drops it, shits himself 
or his feet get blisters, according to the non-codified procedure, 
he's up the friggearing road!

I've made the recent decision to lodge a second claim with the Employment Tribunal against my former employer. I can hear the collective cries of 'Sir!!! you have clearly parted company with your reason?' as I quill out these words. 'Tis not an action one embarks upon without a great deal of rumination for all the obvious reasons. But what recourse does one have when the Vice Chancellor simply chooses to reject a request to have grievance against the current Deputy Vice Chancellor Dr Adrian Graves investigated under the terms of the University's own Grievance Procedure? It's here that I usually suggest that a modicum of clarification and elaboration may be necessary. But first things first.

The Dictum of Equal Applicability

I'm a great believer in the dictum that rules should apply evenly across the board. I'm also a person who believes that if a procedure exists, then an employer should abide by its conditions. Few would disagree with this sentiment, with the possible exception of an unreformed member of Charles the First's retinue on a fixed-term contract who definitely doesn't believe in regicide because it poisons the ladybirds and kills the bees. In the last couple of years I've formed an opinion that certain senior managers at UoS operate under a policy of executive immunity. Keen to avoid a second libel claim, readers can rest assured that I haven't just extrapolated this from a handful of steaming gizzards plucked from a hapless chicken and the less-than-random distribution of tea leaves in the form of a weeping Virgin Mary in the bottom of my old red enamel mug. Let me steer your collective attentions to the University's own published report which speaks directly to this issue.

The Gus John Report 2005

I refer to the 2005 Gus John Partnership Report into Equality and Diversity which states: 

"Perception of double standards as far as management responses to cases of professional misconduct are concerned, with certain managers and staff being perceived as “getting away with the kind of gross misconduct that would get others the sack..."

"...Perception that the University stops at ‘compliance’ and that there is no Executive Team commitment to leading the agenda to promote equality and fairness in the workplace... ”

A non-starter?

You may ask what bearing does this have on matters? Yesterday I received a response to a post-employment grievance I lodged with the Vice Chancellor Martin Hall on the 3rd May (see notes and references). The response came not from Hall but from Eversheds the University's lawyers. It was an interesting letter with some factual inaccuracies stating for example that my employment ended on the 5th August 2009 when in fact it ended on the 6th. The gist of the letter stated that the University Deputy Vice Chancellor Registrar and Secretary did not encourage a breach of the Data Protection Act 1998. They also claim that the University considers that there has not been a breach of the University's disciplinary procedure by Graves. According to the letter the University have decided that  it would not be 'appropriate, in the circumstances' to treat my letter of the 3rd May as a formal grievance against the Deputy Vice Chancellor. They then give several reasons:

• that the evidence I presented to back my grievance has been in my possession for over 15 months and given this that it would not be reasonable to commence a formal investigation given the lapse of time,
• as my employment ended over 22 months ago that the University does not consider it appropriate to progress complaints under their Grievance Procedure, which they say is for the use of employees or recent employees of the University,
• that the issues I've raised relate to the disciplinary action taken against me in 2009 and that these fall outside the scope of the University's Grievance Procedure.

The letter also addresses another issue which I won't elaborate on here. Readers may rest assured that this will explored fully over the coming weeks.

A post-employment grievance

Evidence had come to my attention that I believe is serious enough to warrant an internal investigation at the University of Salford. One can raise these matters by instigating a grievance. This I decided to do. It's known in the trade as a 'post employment grievance' which according to section 7 of the University's own Grievance Procedure is a perfectly legitimate avenue to explore.

Is this Grievance Procedure worth the paper it's written on?

For the record, it does not state anywhere within this procedure that there are time limitations on invoking a post-employment grievance. Now I'm not known for indulging in literary flights of fancy. But like a dream sequence emerging from the ghoul-ridden mist-soaked depths of north Suffolk or south Norfolk, a nightmarish narrative began to coalesce that could only be ascribed to the fevered imagination of a Roger Corman look-a-like free basing on formaldehyde. I mused on what the ramifications for society might be if the police adopted this policy? Murderers would become pretty adept at hiding bodies for 22 months and one day. I also thought it a little silly to infer as does the University, that the 'post-employment grievance' bit within the Grievance Procedure, is intended for use by current employees. A reverse Mr Spock would neither prosper nor live long under such a nonsensical schematic. As for the issues being part of the disciplinary action against me in 2009, well let's explore the evidence and decide for ourselves.

The actuality

Armed with the procedure in my left hand, with my right I wrote to the Vice Chancellor Martin Hall on the 29th March 2011.(1) In this letter I laid out specific evidenced allegations against the Deputy Vice Chancellor, one of which was raised at the Employment Tribunal on March 1st and 2nd of this year. The Tribunal heard how the Deputy Vice Chancellor had suggested to managers and senior managers to breach the Data Protection Act 1998. The University dispute this despite the evidence. His encouragement came in direct response to an initiative from international students who I taught who'd produced a petition supporting me against my suspension on or around May 19th 2009. Events went something like this.

Dr Adrian Graves: not to be internally investigated 
according to University lawyers

A rather stinging amendment

Two days after my suspension, a statement was prepared by Dr Paul Rowlett, the suspending manager Professor Brian Longhurst and others in response to the petition. It read:

'Dear IFY student

You may be aware that Mr Gary Duke has been suspended from his post at the University. A number of you have in fact signed a petition in support of Gary, which I have forwarded to relevant senior managers within the University.

I am sure that you will appreciate that it would be inappropriate for me to comment on the details of Gary's suspension; however I can assure you that the University is dealing with the situation in an appropriate way through legal processes to ensure that Gary's rights are protected...'

The remainder of this internal release reassured students as to the teaching and assessments of their modules. Fair enough you might think. Students are entitled to be kept appraised.

Belay that order Mr Riker!

Prior to the sending of this release, it was altered and another section introduced which read:

'The situation is that there has been a series of posters appearing in the Salford Business School, but also elsewhere across the campus, that viciously attack a female student of an ethnic minority and a Head of School. The content of these posters is sexist, deeply offensive and defamatory. Mr Duke has been suspended owing to allegations that he is responsible for the production and dissemination of these posters...'

It was inserted between the first paragraph and the line that stated that it would be 'inappropriate for me to comment' bit and quite a bit before the rather hilarious line about protecting my rights and sent to the students. Readers might agree that the insertion of this paragraph fundamentally changes the tone of the release and is suggestive of a racist motivation on my part. Now I don't recall being a racist. I don't own a T-shirt with the words 'I'm a racist bugger!' emblazoned across the front. I've also taken the opportunity to re-read the Vice Consul's Newsletters and I can't find any sentence that focuses on the issue of this woman's ethnicity. It's simply not the sort of thing I would do. So the question therefore must be, why would Rowlett and Longhurst allow this to be introduced?

The Deputy Vice Chancellor's email - a 'toxic shard'?

An email exchange between the Deputy Vice Chancellor Dr Adrian Graves and several senior managers such as Watkinson of HR, Longhurst and Dr Rowlett prior to the sending of the internal release to students is rather enlightening. Dr Graves response email states:

"I strongly support this approach. This is and[sic] orchestrated event and the soco voce way forward you have adopted is appropriate. I was tempted to suggest that as apart of your briefing you might slip in the fact that the allegations include the harassment of a female student of Chinese ethnic origin – but I guess that would be departing from the moderation you are proposing…”

On first reading, this may seem unimportant. I'm of the view that this is akin to one of those toxic shards that Professor Hall wrote about several months back in his blog. It may even represent a rather splendid example of the type of 'deliberate misinformation' that Professor Hall is opposed to the use of.(2) Yet there is another reason why I see Graves' email as singularly important. For not only would this have been 'departing from the moderation' they were 'proposing', but it would in my considered opinion also be departing from the law. You see it's all about a not too inconsequential thing called Sensitive Personal Information.

That old devil called... er... Sensitive Personal Information

According to the Data Protection Act 1998, Sensitive Personal Information might be something like a person's religious or political views or their ethnicity or racial origin which according to the University's own website, ‘is subject to much stricter regulation than ordinary personal data’.(3) If there's one thing that can be trusted to make one ask questions it's a breach of the Data Protection Act 1998. Oh yes and possibly the daily grind of a grumpy prostate perched atop the leather-clad razor blade that is a Brooks B17.

A Brooks B17 - can make those with a lumpy Biffin's Bridge ask important questions

Is unclearness a defence?

'Was Graves unclear as to his obligations under the Data Protection Act 1998'? I asked myself. 'Of course not' I answered almost immediately. His duties are probably laid out in his contract of employment just like mine were. Besides, if he was unsure he only had to ask Mr Matthew Stephenson the University's Freedom of Information and Data Protection Act chap. Graves could also have asked the University's own internal legal advisers or if he wished, chatted with one of many external legal advisers or a chap called Ian Austin who is a lawyer and sits on the University Council as Chair of Audit. At the very least, Graves should have erred on the side of caution. He is the UoS 'FOI Champion after all.

The issue in one's hand... a Duty of Care

But there's something a little more troubling about this. It's a little thing called 'Duty of Care' and it's enshrined within a piece of legislation called the Health and Safety at Work etc Act 1974. Like any employer, the University of Salford and in particular Dr Graves (he or one of his proxies did on his behalf, sign my Contract of Employment after all) have a clear duty to provide a safe working environment and prevent risks to health. Now call me old fashioned -  my partner does often as she's not keen on my Harris Tweed underpants - but I had a notion that even if I was suspended my employer had a duty of care towards me... to 'protect' my 'rights' as Rowlett claimed in his optimistic first draft email to those international students.

And no reasonable employer would wish to disseminate information in a manner that could potentially affect my health or potentially prejudice the ongoing disciplinary proceedings? No responsible employer would seek to create a working environment that might prove hostile to a chap who although democratically elected as a union branch officer, was suspended and banned from University grounds and union meetings and therefore unable to counter the inferences within the internal release? One wonders whether Dr Graves considered any of this prior to suggesting to senior managers that they 'slip in the fact' of this person's 'Chinese ethnic origin'? By now many of you like me are possibly wondering what motivated Graves to make this suggestion? Was it concern for the allegedly bullied member of staff? Was it a concern for the international students? Was it a concern for my well-being?

Human Resources and silver linings...

Readers might be asking 'what were Human Resources doing throughout this sorry state of affairs?' Let us for one moment consider the response one of the recipients of Graves' email Mr Keith Watkinson. For the uninitiated, Watkinson is the current Executive Director of Human Resources and will be giving evidence at the forthcoming Tribunal in mid August 2011. Every cloud as they say...

Watkinson's response to Graves suggestion? Well it appears to have been rather muted as nowhere in the voluminous bundle of documents I received under my November 2009 Subject Access Request (or any SAR for that matter) is there an email from Watkinson to Graves with a brief explanation as to why the introduction of Sensitive Personal Information might be a little out of order and potentially illegal. Nor was there another email or note to Graves highlighting the employer's duty of care towards me with regard to the legislation. I couldn't even find the Watkinson email vehement in its defence of my rights nor the one in defence of the rights of the Data Subject not to have her ethnicity used in this manner. They may exist. If they do I'd appreciate copies under my November 2009 Subject Access Request.

The former Charlton Heston holding a copy of  Heaven's Grievance 
and Disciplinary Procedures in tablet form. Like the UoS Grievance 
Procedure, they apply equally to all except of course to God 

Goose sauce and gander... not a new game

But what about the Dictum of Equal Applicability? You see I'm of the view that Graves' actions were an act of bullying. Graves was and is in a position of authority over managers and of course he was in a position of authority over me prior to my being sacked. He authored an email that sought to introduce the issue of a person's Chinese ethnic origin when this was never an issue. He then distributed this email to senior members of staff (I won't dwell here on the responsible use of the University's IT facilities). Should he be suspended pending a full disciplinary investigation? Well according to the Dictum of Equal Applicability then yes. If I could be processed through the UoS Disciplinary Procedure for authoring and distributing the Vice Consul's Newsletters which the University claimed were acts of bullying, should not Dr Graves? This I suggested to Martin Hall (see below).(4) It's quite simple really. The University Disciplinary Procedure should be a one-size-fits-all policy.

Challenging behaviour

As for the delay in providing the email/evidence to the University. Graves had a copy long before I received one. He wrote it. Did he challenge his own behaviour? Watkinson, Longhurst and Rowlett were all in receipt of a copy on the 21 May 2009. Did they challenge Graves' behaviour? Did they raise the issue with the Michael Harloe the old VC? The University and their lawyers have not provided me with evidence to suggest they did?

Moreover, the University claim that this issue relates to disciplinary action taken against me in 2009. Are they suggesting that encouraging managers to use Sensitive Personal Information in this manner, bullying and breaching their duty of care towards me was part of the disciplinary action taken against me? Can they direct me to the section in the 2008 Disciplinary Procedure where it codifies this type of behaviour? And there was little me thinking that the worst that could happen was that I could be dismissed...

An alternative dessert-based scenario

But it got me to thinking which is nearly always a bad thing. I wondered if Hall considers the allegations made as part of my grievance unimportant a mere trifle? This surely couldn't be maintained in the eyes of a reasonable person. Yes, like a trifle I'm a bit rummy. Unlike a trifle, I don't make hundreds and thousands of grievances against Deputy Vice Chancellors. That would be vexatious and frankly silly. But the refusal of the University to act upon the evidence I've presented to them as well as the conditions laid out within their own Grievance Procedure is eminently suggestive and in my view sends out all the wrong signals. One of the recommendations made in the Gus John Report states:

"The Vice Chancellor should be seen to take the lead in promoting Equality and Diversity within the Institution and to its partners, including chairing the Equality and Diversity Committee..."(5)

So we have a newish Vice Chancellor who I gather is keen to promote Equality and Diversity at UoS a policy which has my wholehearted support. Yet given the above evidence, he refuses to instigate an investigation or consider a post-employment grievance according to their own rules. I deliberated a while over the University's  'Listen!' Equality and Diversity Strategy 2010-2013 where on page 11 it states:

"A benchmark for improvement in equality and diversity at our university was set by the recommendations of the Gus John Partnership report in 2005 (the Equality and Diversity Final Report)... Since this report was presented to the university, many of the issues addressed in its 22 recommendations have been addressed, at least in part, and there have been structural changes to the organization of the university..."(6)

If anyone can point me in the direction of 'addressed' 'recommendations' I'd be most appreciative.

A brave new world

I find such inspired communications from the University's lawyers on the whole eminently entertaining. Some may view this as a set-back. The opposite is the case as such missives nearly always open more doors than they close. And of course, the point of this article is not to spread despair or woe. I wouldn't want anyone to perceive of me as resembling some sort of Dr Doom type of character high on aphorisms; a down-brow; a weekly purveyor of negativity and unglad tidings only one step removed on the tree of life from a malfeasant macaque on Mirtazapine.

So let me throw this little alternative purview into this potential cauldron of despair. Let's together imagine a brave new world. It's a world where the Dictum of Equal Applicability rules supreme where rather than encourage such behaviour, senior managers in the workplace concern themselves with challenging such behaviour? Try and conceptualise a futurity where highly paid persons in positions of responsibility, actively familiarise themselves with ‘acceptable standards of conduct, relevant policies, procedures and practices, rules and regulations…’ Nurture within your collective consciousnesses a grand vision of your workplace where your right to a fair hearing is not potentially prejudiced by senior managers actively going out of their way to smear your name and damage your reputation. Finally, cogitate and ruminate over a wide and beautiful vista-to-come where your employer actually adheres to the letter of their own grievance procedure.

Notes and Resources

(1)Excerpt from email to Professor Martin Hall, 29th April 2011

"Dear Professor Hall

It is with great regret that I seek to draw to your attention several incidences which as Chief Executive Officer of the University of Salford I hope you will address.

You may be aware that during the two day Employment Tribunal hearings earlier this month evidence was presented to the Tribunal that demonstrated unequivocally that the Deputy Vice Chancellor and Registrar Dr Graves encouraged a serious breach of the Data Protection Act. In evidence, I would like to draw your attention to an email sent by Dr Graves to Mr Watkinson, Professor Longhurst and Dr Rowlett onthe 21st May 2009. In it Dr Graves says:

“I strongly support this approach. This is and[sic] orchestrated event and the soco voce way forward you have adopted is appropriate. I was tempted to suggest that as apart of your briefing you might slip in the fact that the allegations include the harassment of a female student of Chinese ethnic origin – but I guess that would be departing from the moderation you are proposing…”

As you can see from Dr Graves’ commentary, he is clearly encouraging the misuse of sensitive personal data which as you are no doubt aware, is afforded a much higher degree of protection under the Data Protection Act 1998 than other types of personal data. The Tribunal heard on the 2nd March that Dr Graves encouraged this serious breach of the Act as part of an internal release to students whom I taught in the International Foundation Year within the School of Languages. That these students were all international students opposed to my suspension and had of their own volition presented a petition to the former Vice Chancellor Michael Harloe in my support, casts light on Dr Graves’ intent. This was established within the Employment Tribunal, who heard that Dr Graves had cynically encouraged the illegal use of the sensitive personal data of Ms Li’s ethnicity in order to smear me as a racist. Moreover, it is disconcerting when one also considers that those senior managers in receipt of this email - Watkinson, Longhurst and Rowlett - appeared to raise no objection to the use of this sensitive personal data for the ends specified by Graves.

What makes this act more disreputable is the fact that Dr Graves is as you are aware, corporately responsible for the University’s adherence to the provisions of the Freedom of Information Act 2000 and the Data Protection Act 1998. This action demonstrates a clear instruction to staff to breach the Data Protection Act and therefore the law and displays a disdain for the Eight Principles of Data Protection that are an integral part of the Act..."

Yours faithfully

Dr Gary Duke

(2) M Hall, The Dark Side of the Internet, sourced at http://www.corporate.salford.ac.uk/leadership-management/martin-hall/blog/2011/01/dark-side-of-the-internet/

(3)http://www.infogov.salford.ac.uk/dataprot/intro/personal.php

(4) Letter to Vice Chancellor Martin Hall, dated 3rd May 2011

Subject: Notification of wish to institute a grievance against Dr A Graves

Dear Professor Hall

In light of documentary evidence that has come to light as part of a Subject Access Request in November 2009, specifically an email from Dr Graves to Keith Watkinson,Paul Rowlett and Brian Longhurst dated 21st May 2009, sent during my period of employment with the University, I wish you to consider this letter as a formal notification of my wish to instigate a grievance against the Deputy Vice Chancellor and Registrar Dr Adrian Graves, the grounds of which I will outline below.

I direct you towards my letter to you sent on the 29th March 2011 as my attempt in seeking redress through the less formal grievance route. I note that you have not acknowledged or responded to my letter.

On or around the 22nd of May 2009, a release was prepared for the students whom I taught on the International Foundation Year within the School of Languages. Many of these students had signed a petition in my support against the University’s decision to suspend me. The wording of this email was altered prior to its distribution to IFY students to include a paragraph that stated that the ‘posters’ ‘viciously attack a female student of an ethnic minority and a Head of School. The content of these posters is sexist, deeply offensive and defamatory…’

The Employment Tribunal heard in March how prior to the distribution of this release to the IFY students, Dr Graves had encouraged senior managers (Dr Rowlett, Mr Watkinson, Professor Longhurst) to introduce into this release the issue of Ms Li’s Chinese ethnicity. Dr Graves states in this email ‘…I was tempted to suggest as part of your briefing you might slip in the fact that the allegations include the harassment of a female of Chinese ethnic origin…’ (email dated 21st May 2009; subject: Petition from Languages Students)

It is clear from this sentence that Dr Graves - who is the Chief Operating Officer of the University – was using his position of seniority to influence proceedings during the period of my suspension, during the investigation period and the period prior to my disciplinary hearing. This breached my right as a member of staff under the DP 2008 to be ‘treated fairly and consistently’ (DP 3.1.5). Given that his email was in response to a petition handed in by students in my support as indicated by the subject heading on his email, it is clear that Graves was seeking to prejudice my case and the attitudes of students towards me by portraying me as a racist. What other purpose could be served in revealing Ms Li’s ethnicity other than to portray me as a ‘racist’ picking on an ‘vulnerable’ individual from an ethnic minority. This was intended to defame me and I consider this to be an act of bullying and accordingly would like this to be included as a major part of my grievance against Dr Graves.

You are on record as opposing defamation and the use of deliberate misinformation (Martin Hall, Dark Side of the Internet, published 24th January 2011). I view Dr Graves suggested use of Ms Li’s ethnicity and the underlying insinuation of racism against me as an example of both and in your own words demonstrates that Dr Graves deliberately abrogated his ‘duty to behave responsibly’.

In encouraging the use and release of Ms Li’s Chinese ethnicity and to insinuate that I was racist, several breaches of the University’s disciplinary procedures were committed by Dr Graves in that he:

• did not ensure that ‘appropriate levels of confidentiality and privacy’ were ‘maintained during the disciplinary process’ (DP2.1)
• did not conduct himself with ‘honesty’ or’ integrity’ in ‘promoting an atmosphere of mutual respect in accordance with the University’s equality, diversity, harassment and dignity at work policies…’(DP3.1.1)
• through his directions in the above email Dr Graves sought to breach section 1.2 of the DP and did not consider the implications that his specific directions to use legally protected Sensitive Personal Data in this manner might have on the University’s Equality and Diversity policy,
• That as Chief Operating Officer, either Dr Graves had not familiarised himself with acceptable standards of conduct, relevant policies, procedures and practices, rules and regulations…’ (DP3.1.2) or had wilfully ignored and sought to circumvent the above in seeking to influence the release of the above information to IFY students.

Clearly these are serious breaches of the 2008 DP. Yet Dr Graves must have been aware of these conditions in as much as the University had agreed the disciplinary procedure with the main campus unions and had been taking ongoing advice concerning my case from the University’s internal and external legal advisers.

According to the University’s disciplinary procedures, managers are governed by a series of minimum responsibilities (DP3.2). It is clear that not only did Dr Graves personally ignore many of these responsibilities in encouraging managers to include the use of Sensitive Personal Information in using Ms Li’s ethnicity which is protected under Schedule 3 of the Data Protection Act. It is apparent that he was suggesting mangers below him also ignore such responsibilities.

Dr Graves as the second most senior manager within the University failed to confront, challenge and deal with his own unacceptable behaviour in a timely manner (DP3.2.1), and it appears that he actively encouraged unacceptable and possibly illegal behaviour in the breaching of the Data Protection Act. This is made perfectly clear on the University’s own website which states that sensitive personal information such as ethnicity or racial origin, ‘is subject to much stricter regulation than ordinary personal data’ (http://www.infogov.salford.ac.uk/dataprot/intro/personal.php).

Dr Graves sought to circumvent accepted standards of behaviour and did not ensure that staff complied with such standards of behaviour (DP3.2.2). In encouraging the use of Sensitive Personal Data in this manner, Dr Graves did not ensure that his actions were lawful and that they did not expose the University to legal liability either by taking bad advice or indeed through his own negligence (DP3.2.7). You are also aware that Dr Graves has overall corporate responsibility within the University in the field of Freedom of Information and Data Protection.

I consider Dr Graves’ actions in encouraging the use of a student’s ethnicity to have been prejudicial to my case in 2009, to be malicious and an example of serious misconduct. Given the gravity of these matters, in line with the University’s own disciplinary procedure and for the sake of consistency and the equal application of the disciplinary procedure, Dr Graves should therefore be immediately be suspended pending a full investigation into the above matters.

I would consider it proper that a letter containing an admission of responsibility for the above and an apology from Dr Graves as an integral part of the outcome being sought as a result of raising this grievance.

I look forward to your acknowledgment of my grievance in line with a timetable for investigation of the grievance under the conditions of the University’s own Grievance Procedure.

I reserve the right to bring this letter of notification of grievance against Dr Graves to the attention of the Employment Tribunal.

Yours faithfully

Dr Gary Duke

(5) Gus John Final Report sourced at http://www.google.co.uk/url?sa=t&source=web&cd=4&sqi=2&ved=0CDIQFjAD&url=http%3A%2F%2Fintranet.chssc.salford.ac.uk%2Fopen%2Fminutes%2Fedp%2FGus%2520John%2520Final%2520Report.doc&rct=j&q=gus%20john%20partnership%20report%202005%20university%20of%20salford&ei=GBz_TaDlPMazhAfJja3IDw&usg=AFQjCNGwEMvGfdOYK6oaRfETaWYBrLPL7g&sig2=qEuucyJqeLVK5Uai1wRd6w

(6) Listen! University of Salford Equality and Diversity Strategy 2010-2013 sourced at http://www.google.co.uk/url?sa=t&source=web&cd=3&sqi=2&ved=0CCwQFjAC&url=http%3A%2F%2Fwww.equality.salford.ac.uk%2Fcms%2Fresources%2Fuploads%2FFile%2FEngagement_Consultation%2Ff160610%2FListen!%2520v4.pdf&ei=GBz_TaDlPMazhAfJja3IDw&usg=AFQjCNF6D_ShLU1jpw1w9jnjmCysanu3Zw&sig2=XQ3O8600HL654BoyNFvDOA