This Agency Multicultural Plan (AMP) is an individual agency plan under the Attorney-General's portfolio.
To ensure that all clients and stakeholders have access to essential information and services to meet their needs and ensure equitable outcomes in all dealings with us.
Our purpose is to provide improved and equitable financial outcomes for consumers, business and the community through application of bankruptcy and personal property securities laws, regulation of personal insolvency practitioners and trustee services. We achieve our purpose by:
- providing information about options to deal with unmanageable debt
- providing information about transacting with the Personal Property Securities Register (PPSR)
- maintaining the National Personal Insolvency Index (NPII) and the PPSR
- investigating alleged Bankruptcy Act and Personal Property Securities Act offences
- acting as trustee for personal insolvency administrations and other types of administrations where a private trustee is not appointed-regulating personal insolvency practitioners.
We administer Australia’s personal insolvency system and the national PPSR. Unmanageable debt impacts a diverse range of stakeholders and clients including those from culturally and linguistically diverse (CALD) backgrounds, their families and people to whom they owe money. In addition, the PPSR is utilised by consumers, businesses and the finance industry including those from CALD backgrounds.
The AMP helps to ensure an ongoing focus on supporting all stakeholders and clients (including CALD clients) to obtain the information and services they need in relation to personal insolvency and PPSR.
The AFSA senior Executive Multicultural Champion is Paul Shaw, National Manager Regulation and Enforcement.
Our AMP working group is comprised of senior members of the organisation whose business areas will be directly involved in delivering outcomes for the AMP. Represented business lines included:
- Insolvency and Trustee Services (I&TS)
- People and Capability (P&C)
- Regulation and Enforcement (R&E)
- National Service Centre (NSC) - representing insolvency and PPSR
- Communications (Comms)
Meeting whole of government requirements assists us in:
- increasing knowledge and compliance of bankruptcy and PPSR law within the CALD community
- ensuring equity in service delivery
- increasing awareness of the needs of CALD stakeholders and clients across all aspects of our business
- providing support for all stakeholders and clients (including CALD clients) to obtain the information and services they need, in relation to personal insolvency and PPSR.
There are six key dimensions which the AMP must address: leadership, engagement, performance, capability, responsiveness or openness.
Our focus areas during 2013–15 will be leadership and engagement.
Leadership is important in ensuring commitment to our AMP from the ‘top down’. Commitment to the plan from senior leaders sends the message that the AMP, its purpose and objectives, are important to our organisation and ensures that agency consideration is given at a strategic level to governance, budget and resourcing commitments to appropriately implement our AMP. Leadership further ensures a uniform and consistent approach with other high level agency documents and considers ways in which key issues can be embedded in day to day work.
1.1 Executive accountability: Department or agency to assign a Senior Executive Officer to be responsible for implementation of multicultural access and equity obligations.
1.2 Department or agency commitment: Department or agency leadership to ensure that staff understand and are committed to multicultural access and equity implementation.
Agency to appoint a Multicultural Champion to be responsible for the implementation of the Policy obligations.
|National Management Board (NMB)||May 2013||SES Sponsor appointed within time frame.|
|1.2||Department or agency commitment|
AMP Working Party to be established that comprises of senior leaders; to support the Sponsor in the implementation and delivery of the AMP.
Operational Management Committee (OMC)
Working party established within time frame.
|1.2.2||Agency to consider how best to include multicultural access and equity into high level planning including strategic plan, budgets, reporting and service delivery.||NMB||June 2014||Inclusion on agenda for Agency planning days.|
|1.2.3||Development of draft AMP||Working group||
Draft AMP provided to Department of Immigration and Citizenship (DIAC) by 13 March 2013.
Final plan delivered by DIAC by 7 June 2013.
|1.3.1||Develop internal communication strategy to promote awareness of AMP and CALD clients and stakeholders.||Comms||
July 2013- July 2015
Communication strategy for term of plan developed.
Initial communication of AMP, background and our commitments delivered to all staff.
Ongoing communications about AMP and outcomes.
Effective engagement assists us to better understand the diversity and needs of our stakeholders and clients who our work impacts. It helps us build relationships, mitigates risk and increases people’s understanding of our work and how to access essential information and services relating to personal insolvency and PPSR.
Stakeholder engagement: Department or agency to have an engagement strategy to understand culturally and linguistically diverse communities’ interactions with department or agency.
Language and communication: Department or agency to have a language and communication plan for culturally and linguistically diverse communities, including on the use of languages other than English and incorporating the use of interpreters and translators.
|2.1.1||Review our stakeholder engagement plan to ensure relevance to CALD stakeholders and clients and include reference to AMP.||Comms||Dec 2013||Stakeholder engagement plan reviewed and updated.|
|2.1.2||Commit to undertaking analysis to better understand who our CALD stakeholders and clients are - with particular focus on financial counsellors, registered trustees, registered debt agreement administrators, Federation of Ethnic Communities Councils Australia (FECCA), Australian Taxation Office (ATO), Australian Securities and Investments Commission (ASIC), Commonwealth Director of Public Prosecutions (CDPP), PPSR stakeholder groups, and their networks.||Working group||Dec 2014||Develop list of key CALD stakeholders for future liaison/consultation.|
|2.1.3||Engage with key stakeholders on options to better support the diversity of our clients, eg assistance from FECCA to investigate the impact of unmanageable debt on CALD clients and accessibility of PPSR by the CALD community.||Comms||
Establish discussions with FECCA and other stakeholders regarding needs of CALD clients.
See options for more targeted products to clients eg other formats.
|2.2||Language and communication|
|2.2.1||Develop and implement a language and communications plan.||Comms||July 2014||Plan developed and implemented within time frame.|
|2.2.2||Develop policy on using translators and interpreters.||Comms||July 2014||Translator policy and scripts developed and implemented within time frame.|
|2.2.3||Agency to review key publications to ensure they are easy to understand, relevant and translated into appropriate languages where required.||Comms||July 2015||Establish need for additional targeted translations or materials in other formats to address client diversity.|
|2.2.4||Agency to review website and online services to identify any additional measures required to support access by CALD stakeholders and clients.||Working group||July 2015||Establish need for additional measures to assist CALD stakeholders and clients.|
|2.3.1||Develop a priority languages list to define the languages to be selected when translating information products (agency and other department data can be used as a basis for this).||Comms||
List developed and published on intranet.
List reviewed every 12 months to ensure continued relevance.
|2.3.2||Review our media policy to ensure inclusion of CALD stakeholders and clients.||Comms||July 2013 - July 2015||Develop options and costings for CALD media for consideration.|
|2.3.3||Consideration to be given to leveraging off existing mechanisms (eg newsletters, other agency stakeholder forums and service provider conferences) to promote our messages/services to CALD stakeholders and clients.||Working group||July 2014||Develop a list of external providers and products that service CALD stakeholders and clients and could be used to distribute our information.|
|2.3.4||Consideration to be given to appropriate CALD publications/communication channels when conducting any formal advertising campaign activities.||Comms||Jan 2014||Documentation for advertising campaigns updated to reference the need to include CALD stakeholders and clients.|
It is important for us to know if our plan has been successful, what actions have been met and what needs further work. Allows for the tailoring of resourcing and influences future priorities for the organisation. Annual reporting ensures accountability and provides information for our staff, clients, stakeholders, Parliament and the wider community in relation to our service delivery for CALD clients.
Performance indicators and reporting: Department or agency to develop a set of Key Performance Indicators (KPIs) relating to engagement with, or outcomes of services to, culturally and linguistically diverse clients.
Feedback: Department or agency to have arrangements in place to ensure affected culturally and linguistically diverse communities are able to provide feedback on department or agency multicultural access and equity performance.
|3.1||Performance indicators and reporting|
|3.1.1||Undertake to develop a reporting framework including the implementation of KPI's to report on performance against AMP.||Working group||
Key discussions to occur with OMC regarding KPI establishment and ongoing measurement as part of our operational plan.
Reporting framework developed and implemented.
|3.1.2||Research ways to increase and improve data collection in relation to CALD clients eg CRM, PPSR, Insolvency.||Comms||June 2014||Report on options to be prepared for consideration.|
|3.2.1||Review our complaints and feedback mechanisms to ensure accessibility and appropriateness for CALD stakeholders and clients.||Comms||September 2013||Report on review finalised and options identified (if required).|
|3.2.2||Explore additional ways to raise awareness of existing feedback mechanisms to CALD clients and stakeholders.||Comms||December 2013||Communication strategy developed and implementation commenced.|
|3.3.1||Give consideration to reviewing client satisfaction mechanisms to ensure capturing feedback from CALD clients and stakeholders about responsiveness of our services etc.||Comms||September 2014||Review finalised. Recommendations submitted.|
To ensure that our staff, contractors and service delivery partners have an awareness of the needs of our diverse stakeholder and client base and consider ways in which we can improve access to essential information and the services they need in relation to personal insolvency and PPSR. This awareness better enables us to recognise barriers to clients’ use of our services and equips us to focus on improving the delivery of appropriate and effective services to all stakeholder and client groups.
Cultural competency: Department or agency to have training and development measures to equip staff with cultural competency skills.
Research and data: Department or agency to collect ethnicity data on the culturally and linguistically diverse groups with which the department or agency engages and to which it delivers services directly or indirectly.
|4.1.1||Implement a cultural competency training package to equip staff with cultural competency skills suitable to their roles.||P&C||
100% of staff to complete DIAC e-learning package.
Cultural awareness package to be developed and included in induction package.
NSC to include Telephone Interpreter Service policy in staff induction package.
|4.1.2||Agency to seek input from CALD staff in the AMP.||Working group||December 2013||Staff invited to participate and provide feedback on cultural awareness requirements.|
|4.2||Research and data|
|4.2.1||Agency to examine ways to build on collection of ethnicity data for clients.||Comms||July 2014||Current collection methods maintained and options for improvement documented for future consideration.|
|4.2.2||Agency to regularly analyse ethnicity data and use information to inform development of products and enhance service delivery.||Comms||December 2014||Annual review and update on ethnicity data included as part of reporting framework.|
|4.3.1||Agency to||P&C||Annually in July||Diversity Plan adhered to.|
|4.3.2||Agency to review||Working group||December 2013||Decision around the use of multilingual staff to assist with engagement with CALD stakeholders/clients made.|
We are committed to excellence in service delivery and strive to ensure that essential information and our services are easily accessible to our diverse client base. We have a range of measures in place to invite feedback from clients and stakeholders and the development and implementation of the AMP will assist us to review and supplement, if needed, our approach to effectively support our CALD stakeholders and clients.
Standards: Any whole-of-government standards and guidelines developed by the department or agency must address multicultural access and equity considerations.
Policy, program and service delivery: Provision to ensure that policies, programs, community interactions and service delivery (whether in-house or outsourced) are effective for culturally and linguistically diverse communities.
Outsourced services: Where relevant, provision for incorporation of multicultural access and equity requirements into contracts, grant agreements and related guidance material of which the department or agency has carriage.
|5.1.1||Agency to promote awareness of and adherence to relevant Australian Government standards and guidelines.||Comms||December 2013||Agency to review government advertising standards and data collection information to ensure compliance.|
|5.2||Policy, program and service delivery|
|5.2.1||Agency to develop process to periodically review policies, programs and service delivery to ensure needs of all stakeholders and clients, including those from CALD backgrounds, are taken into account. Where needed, action is identified (and implemented) to better meet the needs of stakeholders and clients.||Working group||July 2014||A plan for the periodic review of policies, programs and services developed and approved.|
|5.3.1||Agency to review and ensure compliance with Department of Finance and Deregulation (DoFD) procurement guidelines and any updates in relation to CALD clients.||Finance, People & Capability||July 2014||Review of procurement guidelines and Agency contracts undertaken and required changes made.|
|5.3.2||Agency to review contract clauses/provisions to ensure inclusion of CALD.||Finance, People & Capability||July 2014||Review of procurement guidelines and Agency contracts undertaken and required changes made.|
We will strive to ensure public confidence and set expectations through the AMP. It will allow for transparent service delivery, and will advise stakeholders and clients of our standards and obligations. The AMP will ensure accountability and equity of services.
Publishing: Department or agency to publish AMPs on department or agency websites and performance reports against KPIs for culturally and linguistically diverse clients in department or agency annual reports.
Data: Department or agency to make culturally and linguistically diverse data available to other departments or agencies and the public.
|6.1.1||Publish AMP on website.||Web team||By 1 July 2013||Report published on time in easy to find location.|
|6.1.2||Meet reporting requirements for agency annual report and DIAC biennial reporting obligations.||Working group||Annual Biennial (DIAC)||Reporting requirements met to time.|
|6.2.1||Agency to review integrity of ethnicity data and determine most effective means of dissemination/sharing.||Comms||July 2014||Integrity of data assessed and documented. Means of distribution/sharing endorsed by NMB.|
|6.2.2||Data collection in accordance with Australian Bureau of Statistics (ABS) guidelines.||Comms||July 2014||Collection of data meets ABS guidelines.|