Ensuring every participant can access independent support to speak up for their rights
This policy sets out how Together Two Limited (trading as Rozelle Neighbourhood Centre) supports the right of every participant to access advocacy services, and how we work with advocates to protect and promote participant rights.
Advocacy is a fundamental safeguard. For participants with complex communication needs, cognitive disability, psychosocial disability, or autism, an independent advocate can be the difference between a concern being heard and a concern being missed. Together Two recognises that our organisation, no matter how well-intentioned, holds power in the relationship with participants. Independent advocacy exists to balance that power and ensure the participant’s interests are always at the centre.
The Circles of Support Engagement Framework recognises the critical distinction between informal support from a participant’s circle and formal independent advocacy. While a participant’s Circle of Support provides invaluable knowledge, connection, and everyday advocacy, independent advocates bring expertise, legal knowledge, and separation from the service provider. Both are important, and neither replaces the other.
→ Participant Rights Policy: Section 6.4 (Advocacy Access); Circles of Support Engagement Framework: Access to Advocacy.
This policy applies at all times and across all settings where Together Two provides supports and services, including Supported Independent Living (SIL), the ZigZag Day Program, in-home supports, community-based supports, School Leaver Employment Supports (SLES), support coordination, and aged care services delivered in partnership with Trilogy Care.
It applies to all representatives of Together Two including the Board of Directors, Senior Leadership Team, permanent and casual workers, contractors, volunteers (including Good in the Hood volunteers), and students on placement.
This policy covers both the participant’s right to access external independent advocacy and the role of informal advocacy within the participant’s Circle of Support.
This policy supports compliance with:
National Disability Insurance Scheme Act 2013 (Cth)
NDIS (Provider Registration and Practice Standards) Rules 2018, Core Module: Rights and Responsibilities (Independence and Informed Choice outcome)
NDIS (Code of Conduct) Rules 2018
NDIS (Complaints Management and Resolution) Rules 2018
National Disability Advocacy Framework (Australian Government)
Disability Discrimination Act 1992 (Cth)
United Nations Convention on the Rights of Persons with Disabilities (UNCRPD), in particular Article 12 (Equal recognition before the law) and Article 13 (Access to justice)
Children’s Guardian Act 2019 (NSW)
→ Business and Operational Plan 2025–2028: Section 9 (Legislative and Regulatory Framework) and Compliance Register (Form 17).
Together Two is committed to ensuring that every participant can access independent advocacy at any time, at no cost, and without any negative consequence to their supports or services. This commitment is absolute and applies regardless of whether the advocacy relates to Together Two’s own services, another provider, a government agency, or any other matter.
We will:
Never obstruct, discourage, delay, or penalise a participant, family member, or supporter for seeking or using an advocate.
Never treat a request for advocacy as a reflection of dissatisfaction or disloyalty. It is a right, not a complaint.
Actively inform participants of their right to advocacy during onboarding, in service agreements, through Easy Read materials, and on an ongoing basis.
Provide named advocacy services and contact details in formats the participant is most likely to understand.
Work cooperatively with any advocate chosen by or appointed for a participant.
Ensure all workers understand the role of advocacy, the difference between advocacy and complaints, and their obligation to facilitate access.
→ Participant Rights Policy: Section 4 (Our Commitment to Participant Rights).
Participants may access different types of advocacy depending on their needs and circumstances. Together Two supports access to all forms of advocacy.
Self-advocacy is when a participant speaks up for their own rights and interests. Together Two supports self-advocacy by:
Encouraging participants to express their views, preferences, and concerns in everyday interactions and in support planning.
Providing information in accessible formats so participants can make informed decisions and raise issues independently.
Supporting participants to develop decision making skills and confidence, consistent with the Keys to Citizenship principle of Freedom.
Creating environments where participants feel safe to speak up, disagree, or say no without fear of consequences.
Informal advocacy occurs when a person who knows and cares about the participant speaks up on their behalf. This is a natural function of the Circles of Support model. Family members, friends, and long-term supporters provide informal advocacy every day by:
Communicating the participant’s known will and preferences when the participant cannot verbally express them.
Raising concerns about the quality or safety of supports with Together Two staff or management.
Participating in support plan reviews, the Family and Supporter Committee, and co-design sessions.
Contacting Together Two through the Support Circuits AI portal, by phone, by email, or in person to raise issues or ask questions.
Informal advocacy is valuable but has limitations. Family members and supporters may not have specialist knowledge of disability rights, NDIS legislation, or complaint mechanisms. They may also have their own perspectives that differ from the participant’s wishes. For these reasons, informal advocacy does not replace the right to independent advocacy.
→ Circles of Support Engagement Framework: Giving Voice to Those Who Cannot Speak.
Independent advocacy is provided by organisations and individuals who are separate from the service provider, the government, and the participant’s personal network. Independent advocates are funded through the National Disability Advocacy Program (NDAP) and are free for participants to access.
Independent advocates can:
Represent a participant’s interests in discussions with Together Two, the NDIA, or other service providers.
Support a participant to make a complaint, including to the NDIS Quality and Safeguards Commission.
Assist a participant with guardianship, financial, or legal matters.
Provide information and advice so a participant can advocate for themselves.
Support a participant through an incident investigation, review process, or transition between providers.
Help a participant understand and exercise their rights under the NDIS, including challenging decisions by the NDIA or a provider.
Independent advocates do not provide counselling, make decisions for a participant, provide mediation, or perform case management. Their role is to amplify the participant’s voice, not to replace it.
Legal advocacy involves a lawyer or legal service providing representation, advice, or assistance to a participant on matters of discrimination, human rights, guardianship, or other legal issues. Together Two supports participants to access legal advocacy where needed and will cooperate with legal processes.
Systemic advocacy aims to influence laws, policies, and practices that affect people with disability as a group. Together Two supports systemic advocacy by engaging with peak bodies, sector organisations, and policy consultations. The Family and Supporter Committee provide a mechanism for collective advocacy on issues that affect multiple participants.
Together Two provides participants with information about the following advocacy services. This information is included in service agreements, displayed at service delivery sites, and provided in Easy Read and other accessible formats.
| Service | What They Do | Contact |
|---|---|---|
| Disability Advocacy NSW (DA) | Individual advocacy for people with disability in NSW, including NDIS participants | 1300 365 085 or da.org.au |
| People with Disability Australia (PWDA) | National cross-disability rights and advocacy organisation, led by people with disability | 1800 422 015 or pwd.org.au |
| Family Advocacy (NSW) | Advocacy for families of people with disability, including Resourcing Inclusive Communities (Circles of Support resources) | 02 9869 0866 or family-advocacy.com |
| Disability Advocacy Network Australia (DANA) | National network connecting people to local advocacy services | dana.org.au |
| NDIS Quality and Safeguards Commission | Complaints about NDIS providers, quality, and safety concerns | 1800 035 544 or ndiscommission.gov.au |
| NSW Ombudsman | Complaints about NSW government agencies and some service providers | 1800 451 524 or ombo.nsw.gov.au |
| Anti-Discrimination NSW | Complaints about discrimination, harassment, and vilification | 1800 670 812 or antidiscrimination.nsw.gov.au |
New participants are informed of their right to access advocacy services during the intake and service agreement process.
Service agreements include a plain-language statement about advocacy rights and contact details for key advocacy services.
The Circles of Support Easy Read document explains advocacy in accessible language: “An advocate is someone who is not from Together Two. They help you speak up for your rights. They are free.”
Workers involved in onboarding are trained to explain advocacy in a way the participant is most likely to understand, using their preferred communication methods.
Advocacy information is displayed at all service delivery sites, including the main office at 754 Darling Street Rozelle, ZigZag Day Program at 756 Darling Street, and SIL dwellings.
Workers remind participants of their right to access an advocate whenever a significant decision is being made, a complaint is raised, or the participant appears distressed or unhappy with their supports.
The Support Circuits AI portal includes advocacy service information accessible to family members and authorised circle members.
Participants are offered advocacy support during support plan reviews, incident investigations, and any process where the participant’s rights or interests may be affected.
When a participant chooses to involve an advocate, Together Two will:
Welcome the advocate and cooperate fully with them.
Involve the advocate in all areas of the participant’s service planning and decision making, as directed by the participant.
Provide the advocate with information relevant to the participant’s supports, with the participant’s consent.
Document the advocate’s involvement and keep records of all communication.
Respect the advocate’s role even when there is disagreement between the advocate and Together Two. Disagreement is not a reason to exclude an advocate.
Record the advocate’s authority to act, including the issues important to the participant and their goals.
Participants are supported if they choose to self-advocate, change advocates, or withdraw their authority for an advocate at any time.
The participant’s decision to change or withdraw an advocate is documented in their file.
Workers do not influence a participant’s choice of advocate or suggest they no longer need one.
Understand the role of advocacy and the difference between advocacy, complaints, and the Circles of Support model.
Actively inform participants of their right to an advocate, particularly when a participant is making a significant decision, raising a concern, or appears distressed.
Facilitate access to advocacy services without delay, including helping participants contact an advocacy organisation if needed.
Never discourage, obstruct, or delay a participant’s access to an advocate.
Work cooperatively with advocates and treat them as valued contributors to the participant’s support.
Report any concerns about a participant’s access to advocacy being restricted or obstructed.
Aisling Scully, Head of NDIS Services (Policy Owner), is responsible for ensuring advocacy access is embedded in all NDIS service delivery processes, including onboarding, support planning, and review.
Sergio Pinzon, Head of HR and Business Improvement, is responsible for ensuring advocacy training is included in worker induction and ongoing professional development.
All members of the Senior Leadership Team are responsible for modelling a culture where advocacy is welcomed, not resisted.
The CEO is responsible for ensuring that Together Two’s organisational response to advocacy is constructive and non-defensive, and that any issues raised through advocacy are treated as opportunities for improvement.
→ Business and Operational Plan 2025–2028: Section 3 (Senior Leadership Team); Human Resources Policy.
Advocacy and complaints are related but distinct. A participant may seek an advocate to help them make a complaint, but accessing an advocate is not itself a complaint. Together Two:
Treats a request for advocacy as a rights-based action, not as a sign of a problem with the organisation.
Does not require a participant to make a formal complaint before accessing an advocate.
Supports advocates to assist participants through the Together Two complaints process or the NDIS Commission complaint process.
Ensures that outcomes from advocacy and complaints are fed into the Continuous Improvement Register for analysis and action.
→ Complaint Management Policy; Continuous Improvement Policy; Internal Audit Schedule and CI Register.
This policy supports the Independence and Informed Choice outcome and the Feedback and Complaints Management outcome within the NDIS Practice Standards Core Module.
| Quality Indicator | How Together Two Demonstrates This | Evidence |
|---|---|---|
| Each participant is supported to make informed choices, exercise control, and maximise their independence | Advocacy access during onboarding and throughout service delivery; self-advocacy supported; Easy Read materials; Circle of Support informal advocacy; independent advocacy facilitated | Service agreements; advocacy information displays; Circles of Support Easy Read; training records |
| Participants are informed about how to give feedback, make a complaint, and access advocates | Advocacy services named in service agreements and Easy Read materials; information displayed at all sites; workers trained to explain advocacy access; Support Circuits AI portal includes advocacy information | Service agreement templates; site signage; induction training records; portal content |
| The provider works with advocates chosen by participants | Advocates welcomed and involved in service planning and decision making; advocate involvement documented; cooperative approach even in disagreement | Participant files (advocate involvement records); meeting minutes; support plan review records |
Key companions: Participant Rights Policy; Person-Centred Practice Policy; Decision Making and Consent Policy; Circles of Support Engagement Framework; Complaint Management Policy; Abuse, Neglect and Exploitation Policy; Diversity and Inclusion Policy; Child Safe Policy; Entry and Exit Policy; Continuous Improvement Policy; Circles of Support Easy Read; Skill and Competency Matrix.
| Version | Date | Author | Change Description |
|---|---|---|---|
| 1.0 | May 2023 | Emma Pollard (Centro Assist) | Initial version, generic template |
| 2.0 | March 2026 | Steven Lowrie, CEO | Complete rewrite. Organisation-specific content integrating the Circles of Support model and the distinction between informal and independent advocacy. NSW-specific advocacy services listed with contact details. Advocacy access embedded in onboarding, service delivery, and complaints processes. Aligned to NDIS Practice Standards Core Module quality indicators. Cross-referenced to companion governance documents. |