FOI Request - Policies and Treatment of Vulnerable Individuals
Request 101003740195
I am requesting the following information regarding Moray Council’s handling of vulnerable individuals, particularly those with disabilities and complex needs:
1. The number of homelessness applications submitted by individuals classified as "extremely vulnerable" in the past five years, and the number of these applications that resulted in permanent or temporary housing placements.
2. The number of homelessness applications from individuals with disabilities or complex needs that were refused or deemed ineligible.
3. Copies of any policies or guidelines Moray Council follows when supporting homeless individuals with disabilities, PTSD, or other mental health conditions.
4. The number of requests for reasonable adjustments under the Equality Act 2010 that have been received in the past five years, including how many were granted, partially granted, or refused.
5. A copy of the council’s internal guidelines for assessing and implementing reasonable adjustments.
6. Details of any training provided to council staff regarding their duties under the Equality Act 2010.
7. The number of individuals with disabilities or mental health conditions who have been required to attend in-person meetings rather than being offered remote or local alternatives.
8. A list of procedures the council follows to assess the impact of its decisions on vulnerable individuals.
9. The number of complaints received regarding the council’s failure to accommodate disabled individuals, including outcomes of any formal investigations.
10. The number of complaints made against Moray Council relating to disability discrimination, failure to provide housing, or lack of support for vulnerable individuals, and how many resulted in investigations or policy changes.
11. Details of oversight mechanisms in place to ensure council staff comply with legal obligations to protect vulnerable residents.
Response 03-04-2025
1. Not held. Information that is not held falls under Section 17 of the Freedom of Information (Scotland) Act 2002 - Information not held.
2. Nil
3. The following Housing Service Policies are available on the Moray Council website. This information is therefore exempt under section 25 of the Freedom of Information (Scotland) Act 2002, information otherwise accessible. For ease of reference please find a link to the web pages here:
Moray Council Homelessness Policy: http://www.moray.gov.uk/downloads/file45711.pdf
Moray Council Allocations Policy: http://www.moray.gov.uk/downloads/file154032.pdf
Moray Council Housing Support Policy: http://www.moray.gov.uk/moray_standard/page_75232.html
Moray Council Housing Functional Assessment: http://www.moray.gov.uk/moray_standard/page_42973.html
Moray Council Housing Service will also refer onto other teams within the Council where necessary.
The internal Housing Policy and Procedures portal also holds all policies, procedures and national guidance relevant to Housing and Equalities, for staff training and reference. This includes Shelter Scotland’s:
• Reasonable Adjustments and the Equality Act 2010
• Homelessness and the Equality Act 2010
• Allocations and the Equality Act 2010
Homelessness and the PSED Briefing Note – 2023
4. The table below details the number of Major Adaptations to properties in Moray. We do not keep a record of Minor adaptations.
Year No of major adaptations
16/17 68
17/18 53
18/19 71
19/20 76
20/21 29
21/22 31
22/23 52
23/24 53
5. Reasonable adjustments under the Equality Act 2010 can vary significantly across services and depending on the individual’s needs and can be determined by each service depending on what they deliver.
The Housing Service Policy and Procedures Library holds all policies, procedures and national guidance relevant to Housing and Equalities, for staff training and reference. This includes Shelter Scotland’s Reasonable Adjustments and the Equality Act 2010.
Moray Council also has an Integrated Impact Assessment and guidance which is used internally to identify if there are any impacts on protected characteristic groups (including disability). This is used for any new (or revision to any existing) service, strategy, policy, plan, project, budget proposal affecting members of the public. Any negative impacts on any of the groups should be identified and any mitigations identified to reduce or eliminate the impact and any inequality or disadvantage.
6. An Introduction to Equalities, Diversity, and Inclusion Online Module - 2395 (2019-2025) members of staff accessed
Skills 4 Change – covers Integrated Impact Assessments (IIAs
Interview Skills
Health and Work
Third Party Hate Crime Reporting by Police Scotland
Individual Services throughout Moray Council also provide their own Service specific ED&I training that is more tailored to their own staff /service. Examples of this are the Housing Service who have had the following:
• Equality and Human Rights in Housing and Homelessness by Shelter Scotland
• Sexuality, gender identity and homelessness in Scotland - Centre for Homelessness Impact
• Human Rights Bill - Homeless Network Scotland.
7. Not held. Information that is not held falls under Section 17 of the Freedom of Information (Scotland) Act 2002 - Information not held.
If you are homeless or threatened with homelessness, you are required to attend an interview with a Housing Needs Officer. This would usually happen in the Moray Council HQ Annexe building but remote or local alternatives can be offered depending on the circumstances of the applicant.
8. As Q5 above, Moray Council uses an internal Integrated Impact Assessment and guidance to assess the impact of its decisions in relation to any change to, revision of or new service, strategy, policy, plan, project, budget proposal that affects members of the public in relation to the protected characteristic groups under the Equality Act 2010.
9. There were total of 6 complaints; the number of complaints upheld, not upheld and partially upheld each were between 1 and 5. The low numbers associated with this response may result in the identification of individuals, therefore this part of the response is exempt under Section 38(1)(b) of the Freedom of Information (Scotland) Act 2002
- personal information. Please note that we have taken the word accommodate as to mean “to allocate someone” rather than “making reasonable adjustments.”
10. The number of formal complaints made which included a reference to “disability discrimination” is between 1 and 5. This part of the response is exempt under Section 38(1)(b) of the Freedom of Information (Scotland) Act 2002 - personal information.
11. Individual Services will have their own policies, procedures, monitoring mechanisms and quality assurance in relation to vulnerable adults and will refer on to other Moray Council Services where identified or necessary such as the Adult and/or Child Protection Team.
Moray Council Housing Service hove the following internal operational procedures that cover identifying, assessing, supporting and signposting customers with vulnerabilities:
Housing Options Procedures
Homelessness Procedures
Housing Support Procedures – Housing Support Matrix Assessment where required
Housing First Procedures
Allocations Procedures
Functional Assessment Process: http://www.moray.gov.uk/moray_standard/page_42973.html