Welsh lessons

So, I came across an article on Special Needs Jungle on the new Additional Learning Needs and Education Tribunal (Wales) Act 2018, which came into force on 1 September 2021. This seems to represent a sweeping change in the special educational needs framework (now to be known as additional learning needs). You can read about the changes here: The new “rights-based” Additional Learning Needs system in Wales

Welsh Government Factsheet

Based on what I have read, there are some interesting and welcome features in this new legislation:

  • Covers ages 0 to 25, as opposed to 3-18 (roughly) in Scotland
  • A single statutory plan for everyone with additional learning needs, as opposed to a tiny proportion who fit with the arcane criteria for a Co-ordinated Support Plan (CSP)
  • A focus on local resolution of disagreements, backed by wide and consistent rights of access to the Education Tribunal for Wales
  • A “whole system” approach, including external agencies and the stages before and after school
  • A Code of Practice which embeds principles from the UN Convention on the Rights of the Child and the UN Convention on the Rights of Persons with Disabilities

As you know, the ASN Review is now in its implementation phase, and we are currently waiting for the review on CSPs to report and a revision to the Code of Practice (I think). So, plenty of opportunities to adopt some of these ideas from Cymru.

Image by Pete Linforth from Pixabay

Reasonable adjustments for schools in a time of pandemic

Schools have had a duty to make reasonable adjustments for disabled pupils since amendments to the Disability Discrimination Act 1995 came into force in 2001.  These duties were later expanded to include “auxiliary aids and services”.  The phrase “reasonable adjustments” is fairly well known by now, but prompts the question – “what is reasonable?” and specifically, what might be regarded as reasonable in the particular circumstances of a global pandemic crisis.

Overview of the legal framework

Part 6, Chapter 1 of the Equality Act 2010 is the part of the Act which applies to schools.  It applies to all schools in Scotland, i.e. public schools (those managed by a local authority); independent schools; and grant-aided schools (those receiving specific direct Scottish Government funding).

The legal duties rest with the responsible body for the school.  In the case of public schools, this is the local authority as a whole – an important point when the discussion turns to funding and resources.  For independent or grant-aided schools, the managing body (e.g. a board of trustees or SCIO) is the responsible body.

The Equality Act 2010 applies across all nine “protected characteristics”, but there are two types of discrimination which only apply in relation to disability.  These are the reasonable adjustments duty (Section 20) and discrimination arising from disability (Section 15).

Reasonable adjustments

In the case of disabled pupils and schools, it is only the first and third requirements of the reasonable adjustments duty which applies.

The first requirement arises where a “provision, criterion or practice” (PCP) places a disabled person at a substantial disadvantage.  The requirement is to take reasonable steps to avoid that disadvantage.  The EHRC’s Technical Guidance for Schools in Scotland gives the example of a school policy forbidding the use of external USB devices with school computers.  In the example the school amends the policy so that a disabled pupil can be given a login that will allow him to attach an adapted keyboard in class. (para 6.9)

The third requirement arises where, without an “auxiliary aid or service,” a disabled person would be at a substantial disadvantage.  The requirement is to take reasonable steps to provide the auxiliary aid or service in question.  The Technical Guidance gives the example of a school providing a coloured plastic overlay sheet for a pupil with dyslexia.

The second requirement concerns substantial disadvantage which may arise because of a physical feature.  The schools duties do not include a requirement to remove or alter physical features of the school for disabled pupils.  However, there is a planning duty contained in the Education (Disability Strategies and Pupils’ Educational Records) (Scotland) Act 2002 which requires responsible bodies for schools to set out their plans to improve access (including physical access) to the school, on a three year cycle.

Discrimination arising from disability

This type of discrimination occurs where a disabled pupil has been treated unfavourably, because of something “arising in consequence of” pupil’s disability unless that treatment is a “proportionate means of achieving a legitimate aim”.

Unfavourable treatment is a fairly broad category and (unlike other types of discrimination) does not require a direct comparison.  That is, there is no need to find someone who has been treated more favourably than the disabled pupil.

Recent cases at the Tribunal have dealt with exclusion from school, the use of physical restraint and a refusal to allow an additional year at school as unfavourable treatment.

In cases where the unfavourable treatment is admitted or established, the responsible body may argue that the treatment was not unlawful as it was a proportionate means of achieving a legitimate goal.  Often the aim pursued is self-evidently legitimate, and the question is then whether the treatment in question was a proportionate means of pursuing that goal.

The Technical Guidance gives an example (at para 5.47) of a pupil excluded from school meals because she found queueing distressing.  There may be a legitimate goal in this case, but if there are less restrictive means of achieving that goal (e.g. could the pupil be allowed to go straight to the head of the queue?) then the responsible body will struggle to show that the treatment is justified.

Overlap with additional support needs framework

The Equality Act 2010 is not the only piece of legislation which may apply, as disabled pupils may also have “additional support needs” in terms of Section 1 of the Education (Additional Support for Learning) (Scotland) Act 2004.  There are several areas in which there is an overlap between these two legal frameworks.

It is worth noting, for example, that neither the definition of additional support needs, nor the definition of disability require a formal diagnosis.  Both Acts are more focused on the day to day experience of the individual pupil.  Indeed, the definition of additional support needs specifically includes pupils who require additional support “for whatever reason”.

The First-tier Tribunal for Scotland’s Health and Education Chamber has jurisdiction for both types of case, and can join cases together where this is appropriate.  For example, in a case involving support for a disabled pupil to access an after school guitar club, the Tribunal considered the matter as a failure to comply with the child’s CSP and a reasonable adjustments case at the same time (cf. “Landmark victory for disabled pupil”, Daily Record 19 June 2013)

Issues arising during the Covid-19 pandemic

Questions of reasonable adjustments and disability discrimination arise in school even when there is no global pandemic to complicate matters.  However, there have been some specific issues arising which relate directly to the Covid-19 pandemic and the measures taken in response.

  • Some auxiliary services which required close contact with staff were restricted or ceased altogether (e.g. personal care needs, communication support needs).
  • Some auxiliary aids / assistive equipment which required handling (and therefore cleaning) were removed, or were available only on a restricted basis.
  • There was not consistent application of guidance on which children with additional support needs or disabilities could have access to learning hubs during periods of school closure. Disagreements arose as to who was regarded as “vulnerable”.
  • Some pupils required reasonable adjustments in order to access online learning.
  • Legal authority for the closure of schools – Educational Continuity Directions – was not in place at first.  The directions disapplied some of the ASL legislation, but only in a limited fashion.
  • There are ongoing issues relating to pupils who have missed education / transition planning, and reasonable adjustments may be required for disabled pupils.
  • Some disabled pupils found that access to online learning suited them well, and the return to in person lessons has been difficult, or impossible.  Reasonable adjustments may be required in terms of delivery of the curriculum in new and innovative ways.

Recent Tribunal cases

During the pandemic the Tribunal, after a short period in which only urgent cases were progressed, has adapted quickly and well to online hearings and electronic case papers.  There is no current backlog and cases (including disability discrimination cases) continue to be heard and determined.

Over the last academic year (2020-21) the Tribunal has considered disability discrimination cases which have covered a wide range of topics including: differentiation of the curriculum, subject choices in the senior secondary stages, exclusion from school, requests for additional time at school, specific strategies for addressing dyslexia, and the use of physical restraint. Few (if any) were directly related to the pandemic, but that is the context in which they took place.  To the extent that it was considered, it is reassuring to note one Tribunal’s comments in relation to transition planning:

“the COVID-19 pandemic does not remove the obligations of the responsible body to comply with the transition regulations.”

Image by Hatice EROL from Pixabay

Programme for Government 2021-22

The Scottish Government published its programme for government this week. I thought I’d take a quick look at what it says about additional support needs. There is a whole section on education, of course, and much of that will be relevant to all pupils (including those with additional support needs). There are also specific commitments in relation to care experienced pupils and those who are socio-economically disadvantaged. Many of these pupils would fall within the definition of “additional support needs” although that is not always as well recognised as it ought to be.

However, in terms of a specific mention of additional support for learning, we find it in Chapter 2:

We will act to close the gap for children and young people with additional support needs, developing a new approach for how their achievements and successes are recognised, and fully implementing the findings of the Additional Support for Learning (ASL) Review. We will ensure there is appropriate career progression and pathways for teachers looking to specialise in Additional Support for Learning – with the intention that this results in an increase to the number of teachers who specialise in ASL – and explore options for the development of an accredited qualification and registration programme for Additional Support Needs assistants with final proposals to be brought forward by autumn 2023.

A Fairer, Greener Scotland: Programme for Government 2021-22

This is, as others have commented, nothing new. The Scottish Government have already committed to implementing the recommendations of the ASL Review, and the specific commitments about recognising and celebrating wider achievement, providing an ASL-specific career path for teachers, and accrediting ASN assistants, are all taken from that self-same review. Indeed, we are shortly due ASLIG‘s first annual report on the implementation of the recommendations of the ASL Review.

More on that as it becomes available.

Pride and Prejudice

As Pride month for 2021 draws to a close, I thought it would be appropriate to write a brief article outlining what the law says about discrimination and LGBTQ pupils.

LGBTQ young people with additional support needs or a disability can face particular issues not experienced by straight / cisgender disabled people, or by non-disabled LGBTQ pupils. As the Scottish Commission for People with Learning Disabilities 2018 report “Safe and Healthy Relationships” points out: “people with learning disabilities who identify as LGBT [are] a “minority within a minority” (Elderton et al, 2013, p.302). This subgroup experience a double disadvantage which can increase the barriers in forming relationships which are safe, healthy and reciprocal.”

Protected Characteristics

The Equality Act 2010 provides protection from unlawful discrimination across nine “protected characteristics”. These include sexual orientation (section 12) and gender reassignment (section 7).

Sexual orientation is defined as “a person’s sexual orientation towards— (a) persons of the same sex, (b) persons of the opposite sex, or (c) persons of either sex.”

Gender reassignment is defined as being when “a person is proposing to undergo, is undergoing or has undergone a process (or part of a process) for the purpose of reassigning the person’s sex by changing physiological or other attributes of sex.” A recent case in the Employment Tribunal (Taylor v. Jaguar Land Rover) has clarified that the reassignment need not be viewed strictly as male to female or female to male – and thus pupils identifying as gender-fluid or non-binary would also be protected.

A person will be protected because of gender reassignment once:
• he or she makes his or her intention known to someone, regardless of who this is (whether it is someone at school or at home, or someone such as a doctor);
• he or she has proposed to undergo gender reassignment, even if he or she takes no further steps or decides to stop later on;
• there is manifestation of an intention to undergo gender reassignment, even if he or she has not reached an irrevocable decision;
• he or she starts or continues to dress, behave or live (full-time or part-time) according to the gender with which he or she identifies as a person;
• he or she undergoes treatment related to gender reassignment, such as surgery or hormone therapy; or
• he or she has received gender recognition under the Gender Recognition Act 2004.
It does not matter which of these applies to a person for him or her to be protected because of the characteristic of gender reassignment.

Technical Guidance 5.114

Schools

Part 6, Chapter 1 of the Equality Act 2010 covers all schools in Scotland (education authority, granted-aided or independent) and provides that the responsible body for a school must not discriminate against a pupil (or prospective pupil) in terms of admission to school; provision (or failure to provide) education or other “benefit, facility or service”; or by excluding a pupil or subjecting them to any other detriment. This would cover direct or indirect discrimination cases.

However, the prohibition on harassment (s.26(3)) does not apply in relation to the protected characteristics of sexual orientation or gender reassignment (s.26(10)). In practice, most incidents of harassment would be caught by the direct discrimination provisions in any event.

Example: As part of health and wellbeing education, a teacher describes homosexuality as ‘unnatural’ and states that he will be covering only straight relationships in the lesson. A bisexual pupil in the class is upset and offended by these comments. This may be direct discrimination on the grounds of sexual orientation.

Technical Guidance 5.19

Schedule 23, para 3 of the Act provides a general exception in relation to communal accommodation (which covers residential schools’ accommodation). Matters in relation to communal accommodation will not be unlawful in relation to sex discrimination or gender reassignment discrimination. In relation to gender reassignment, consideration must be given to whether the decision in question is “a proportionate means of achieving a legitimate aim”.

Consequences

Unlike disability discrimination cases, there is no specialist Tribunal with jurisdiction in relation to schools cases involving sexual orientation discrimination or gender reassignment discrimination. These cases are instead heard by the Sheriff Court (Section 114(1)(c)). To my knowledge, there is no case law involving cases of this type. It is hard to tell whether this is a good thing (because there are few examples of discrimination against LGBTQ pupils by schools) or a bad thing (because a lack of awareness or other factors mean people do not want to bring cases when they arise). It may be a bit of both.

There is a six month deadline for bringing cases to court (s.118), and the Sheriff should ordinarily appoint a specialist “assessor” to assist in considering the case (s.114(8)). The Sheriff Court has wide ranging powers to make a range of court orders where discrimination has taken place, including compensation for injury to feelings (s.119)- awarded on the so-called Vento scale.

Examples

In the absence of case law in education cases, we have to look to cases in other fields (usually employment) and to the Equality and Human Rights Commission’s Technical Guidance for Schools in Scotland. Although some of the examples are of fairly obvious cases of discrimination, it is helpful to consider what the guidance says nonetheless.

Example: An independent religious school has information on its website indicating that it does not tolerate homosexuality. This could constitute direct sexual orientation discrimination

Technical Guidance 2.17

Example: A school has a policy covering racial bullying and any pupil who participates in racial bullying is excluded for at least one day. However, the school does not have a policy dealing with homophobic bullying and pupils who participate in such bullying are usually given only a detention. This could lead to direct sexual orientation discrimination unless the bullying of homosexual pupils was not related to their sexual orientation.

Technical Guidance 3.7

Example: A lesbian pupil undertakes a project charting the history of the gay and lesbian movement as part of her coursework. Her teacher tells her that her topic is inappropriate and that she should keep her personal life to herself. As a result, the pupil is subsequently given low marks for her project. This is likely to be direct discrimination because
of sexual orientation.

Technical Guidance 3.8

Example: A school fails to provide appropriate changing facilities for a transsexual pupil and insists that the pupil uses the boys’ changing room even though she is now living as a girl. This could be indirect gender reassignment discrimination unless it can be objectively justified. A suitable alternative might be to allow the pupil to use private
changing facilities, such as the staff changing room or another suitable space.

Technical Guidance 3.20

A previously female pupil has started to live as a boy and has adopted a male name. Does the school have to use this name and refer to the pupil as a boy?
Not using the pupil’s chosen name merely because the pupil has changed gender would be direct gender reassignment discrimination. Not referring to this pupil as a boy would also result in direct gender
reassignment discrimination.

Technical Guidance 3.36

Example: A member of school staff repeatedly tells a transsexual pupil that ‘he’ should not dress like a girl and that ‘he’ looks silly, which causes the pupil great distress. This would not be covered by the harassment provisions, because it is related to gender reassignment, but could constitute direct discrimination on the grounds of gender reassignment.

Technical Guidance 5.19

For further reading, you might want to take a look at Education Scotland’s resource on Addressing Inclusion – Effectively Challenging Homophobia, Biphobia and Transphobia.

Image by Sharon McCutcheon from Pixabay

Potential Energy (Conclusion)

So, to recap…

Back in June 2020, the report of the independent review of the implementation of Additional Support for Learning legislation in Scotland was published.  The review was chaired by Angela Morgan, and the report, which is worth reading in its entirety, is titled “Support for Learning: All our Children and All their Potential”.

A formal response from Scottish Government and COSLA was issued, which accepted all of the recommendations (save for those which required external input, e.g. involving the Universities delivering initial teacher education) and set up a monitoring framework.

What did Children and Young people tell the Review?

The report begins with a statement of what children and young people might think about the implementation of the law on additional support needs. This is, undoubtedly, a very good place to start. However, it also laments the smaller than hoped for numbers of young contributors to the review.

The Young Ambassadors for Inclusion provided the headlines for this section of the report, highlighting from the outset: “Meaningful relationships between children and young people and staff are important for learning;”

This is a key point, which the review returns to time and time again.

Children and young people also underlined the importance of “willingness to adapt teaching methods to children and young people’s learning styles” and the importance of school being a safe place for them.

Other points noted by the younger contributors included:

  • school staff need to have more knowledge and understanding of additional support needs;
  • the ability and capability of pupils with additional support needs must not be underestimated;
  • more understanding and empathy from peers is needed;
  • timely (and, I presume, effective) responses to bullying are important;
  • consistency of support is required; and
  • communication needs to improve.

Participation

Central to all of this is involving children and young people with additional support needs:

“Children and young people have their own views on what works for them and what kind of support they need.”

For children aged 12 to 15 with additional support needs, My Rights, My Say provides free, independent advocacy to assist children in making use of their legal rights under this legislation.  However, that is only the tip of the iceberg, and pupil participation needs to be embedded within the education system.

Indeed, the first, and overarching, recommendation from the review is on Children and Young People’s Participation:

“Children and young people must be listened to and involved in all decision making relating to additional support for learning. Co-creation and collaboration with children, young people and their families will support more coherent, inclusive and all-encompassing policy making, which improves implementation, impact and experience.”

The good practice of the Tribunal in this area is specifically noted elsewhere in the report: “the needs and preferences of the small number of children and young people who engage with the Tribunal, are evident in the detail of the architectural and interior design of the Tribunal offices, and the operational processes developed to reduce stress and distress.”

Resources – and relationships

The ASL review does not shy away from difficult issues, nor from stepping beyond its strict boundaries when it is necessary to do so.  It is does therefore, highlight the many concerns that exist around funding for additional support for learning as well as the impact of pressure on local authority resources more generally (the term “austerity” is used seven times in the report).

This was also a point that was made by the children and young people who contributed to the report: “Additional Support for Learning needs to be adequately funded to ensure everyone gets the support they need, when they need it.”

The report therefore recommended that its own findings are considered as part of the recent Audit Scotland thematic review of Additional Support for Learning.

However, as important, if not more so, are the staff resources actually delivering the support to children and young people day by day.  The commitment and understanding of those staff and the quality of the relationship between staff, pupil and parents can make or break the educational experience.  Parents contributing to the review spoke of the importance of a professional who “just gets it”.

Time and time again, the review returns to the importance of relationships.  Indeed, two of the report’s nine themes have “relationships” in the title.  Especially in those chapters, but also throughout the report, the fundamental importance of honest trusting relationships is stated again and again.

While this is something that can be taught (and learned), it is much more difficult to legislate for, let alone enforce.   

The Tribunals (and those of us who practise within the Tribunal jurisdictions) have a part to play.  Indeed, the review notes that “it is essential that rights and associated processes for .. the Tribunal should be clear and understood and barriers to access removed”, while also recognising the heavy drain on resources (both financial and emotional) that it can be for all involved. 

Ultimately, it is the success or otherwise of the measures and recommendations from the report as a whole which will determine which cases (and how many) still require to be adjudicated in this way.  The first report on progress against the various recommendations is due from the Additional Support for Learning Implementation Group (ASLIG) in October 2021.  It is important that the report is not just accepted, but actually leads to significant and lasting change for the children and young people whose interests and rights lie at the heart of it.

This article first appeared in the May 2021 newsletter of the Health and Education Chamber of the First-tier Tribunal for Scotland.

Image by LeoNeoBoy from Pixabay

Potential Energy (Part 3)

Following consideration of Theme 1: Vision and visibility, we turn our attention to Theme 2: Mainstreaming and inclusion. This obviously covers a lot of the same ground as the revised “Guidance on the presumption to provide education in a mainstreaming setting” on which I recently completed a ten-part series of blogs. You can read my conclusions on that guidance in Mainstreaming, I presume? (Part 10).

Thankfully, this review reaches many of the same conclusions about mainstreaming, and explicitly adopts many of the key concepts and principles from the guidance:

  • the review confirms that the “physical presence of a child” in a mainstream school alone does not constitute inclusion;
  • it adopts the four principles of inclusion from the guidance – present, participating, supported and achieving; and
  • it underlines the importance of inclusion “in the life of the school” which includes the playground, school trips, sporting events, social events and being “visible as part of the community”.

Continue reading “Potential Energy (Part 3)”

Potential Energy (Part 2)

Continuing our consideration of the ASL Review Report, the main section of the report begins with “Theme 1: Vision and visibility”.  This covers two big issues.  One is that there is no defining national agenda or narrative in relation to additional support needs, demonstrated perhaps by their absence from the National Improvement Framework.  The second is that the term “additional support needs” continues to be misunderstood and misinterpreted, with the result that particular groups of children and young people who are covered by the law missing out on their rights in practice.

Continue reading “Potential Energy (Part 2)”

Recover Version

Education Scotland have issued an update of their Corporate Plan for 2019-2022, to take account of the impact of the recent interruptions to learning caused by school closures etc.

The document is called “Education Scotland: Our Recovery Year 2020/21” which does sound like they are struggling with addiction or something.  To educational jargon perhaps?

It is a relatively short and easy to read document, which recognises that the pandemic has had “huge implications for the education system”. They propose therefore to “lead and support the [education] system during a ‘recovery year’ up to June 2021”.

While noting the changed context, there are some things which remain constant, including the commitment to Education Scotland’s four values (which I had not heard of before): integrity, respect, excellence and creativity. I might quibble over whether “excellence” is really a value, but there we are…

There is clearly some concern that we are not out of the woods yet, and so one of the aims is to “increase the system’s resilience to continue to support learning in the event of any future national or local lockdowns.” and one of the ES outcomes listed is that the “education system is responsive and able to move into / out of lockdown smoothly if / as required.”.

This is most obviously reflected in the commitment to “continue to develop support for remote learning”, with Glow, Scotland Learns and e-Sgoil being name-checked specifically.

To free up capacity, the school inspection programme remains “on hold” though “targeted and risk based inspections” will be carried out as required.

This is a corporate plan document, so it’s fairly high level stuff, and perhaps not wholly surprising to see no mention of the particular impact on pupils with additional support needs – though there is a recognition in the introduction that “the impact of COVID-19 has not been felt equally .. for our different groups of learners”.

Image by Jagrit Parajuli from Pixabay

Potential Energy (Part 1)

As promised, and following a delay (for which I apologise), I finally turn my attention to the independent review of the implementation of Additional Support for Learning legislation in Scotland.  The review was chaired by Angela Morgan, and the report, titled “Support for Learning: All our Children and All their Potential” was published in June 2020. A formal response from Scottish Government and COSLA is expected in the Autumn.

There has not been much in the way of commentary on the review, with this interesting article by Alison Brown being a rare example.

I plan to take the same approach as I did with the mainstreaming guidance, which is to consider the report in shorter chunks.  This keeps things manageable for me, and allows for a more in-depth analysis of each section. As always, my focus is on the legal implications.

Continue reading “Potential Energy (Part 1)”

Educational Continuity (Nos. 4 & 5) Directions

Due to being away on annual leave last week, I didn’t get a chance to blog on the last Educational Continuity Direction, which was the fourth issued by the Scottish Government.  It was not hugely exciting in that it mainly continued the previous directions, with some additional bits and bobs about preparing for schools re-opening on 11 August.  It also effectively brought to an end the provision of childcare for keyworker and vulnerable children, as of 31 July 2020.

But 5? Five! Well, this is the one we have been waiting for.  Issued on Thursday 6th August, but not coming into force until Monday 10th?  You know we’ve got something special on our hands.

For one thing, this direction is due to remain in place until 30th August 2020, and – as things stand – “it is not anticipated that a further direction will be required.”

As before, the direction applies only to education authority schools.  The main focus is now on the re-opening of schools, and the requirements are set out plainly:

  • schools may reopen to pupils from 11th August 2020;
  • schools must reopen to pupils by 18th August 2020;
  • authorities must prepare contingency plans to be used “immediately in the event of a local coronavirus outbreak”.

There are no specific requirements about steps to be taken for safety, but there is a general objective:

preventing the transmission of coronavirus, the welfare of children and young people and staff, and the importance of continuity of education.

And, as always, education authorities have to have regard to “relevant guidance issued by the Scottish Ministers” (of which there is no shortage).

And, contrary to expectations, there is no continuation of the disregard of failures in certain statutory duties – including key deadlines and duties within the additional support needs legislation.  Therefore, the period during which education authorities (and parents) may be able to rely on failures to comply with certain duties being disregarded is limited to the period from 2pm on 21 May 2020 until 1 minute past midnight on 10 August 2020 – and only insofar as it is the restrictions within the direction(s) which have led to the failure.

This means, of course, that in returning schools have all the same duties in place to make adequate and efficient provision for pupils’ additional support needs, and to make reasonable adjustments (including the provision of auxiliary aids and services) to avoid substantial disadvantage to disabled pupils.  Under the circumstances, there may well be significant needs to be met, and adjustments to be made.  The latest direction has effectively removed any “but the pandemic” excuse for disregarding those duties.

You can access all of the Educational Continuity Directions (and the accompanying guidance documents) on the Scottish Government educational continuity direction page.