ࡱ> %` hbjbj"x"x <@@;]c%TTTFT4UUU,Uyyy8,zlzl,U{{"2{2{2{z|z|z|$hh@UFz|z|FF@UU2{2{HUЃЃЃF U2{U2{ЃFЃЃUU*2{{ `ɻZ+yfHk0ala**\aUz|6}Ѓ}l(~z|z|z|@@0z|z|z|FFFF,U,U,Ud"wd,U,U,Uw,U,U,UUUUUUU JobWatch Submission to Freedom of Religion and Belief in the 21st Century, Race Discrimination Unit: Education and Partnerships Section, HREOC. Prepared by Deborah Itzkowic and Vera Smiljanic with the assistance of JobWatch interns Natasha Koravos, Melinda Verlin and Bianca Kagan. Job Watch Inc. February 2009 CONTENTS 1. 鱨վ JobWatch 2. Executive Summary 3. Introduction 4. Exemptions in the Sex Discrimination Act 1984 (Cth) (SD Act) 5. Discrimination on the basis of sexual preference and gender identity. 6. Definition of 'employment' in the SD Act 7. Conclusion 1. ABOUT JOBWATCH JobWatch Inc. (JobWatch) is an employment rights community legal centre which, since 1980, has operated as the only service of its type in Victoria. The centre is funded primarily by the Victorian State Government (the Department of Innovation, Industry and Regional Development- Workforce Victoria). JobWatch's core activities include: The provision of advice, information and referral to Victorian workers via a free and confidential telephone information service which received 20,020 calls in the 2007/2008 financial year; A community education program that includes publications, information via the internet, and talks aimed at workers, students, lawyers, community groups and other organisations; A legal casework service provided by JobWatch's Legal Practice for disadvantaged workers; Research and policy work on employment and industrial law issues; Advocacy on behalf of those workers in greatest need and disadvantage. In 2007/2008, JobWatch received 1,918 queries relating to discrimination on its telephone advice line. In addition, JobWatch's legal practice made appearances on behalf of clients during 2007/2008 mostly in relation to discrimination and sexual harassment matters at the Victorian Equal Opportunity and Human Rights Commission (VEOHRC), the Human Rights and Equal Opportunity Commission (HREOC), the Victorian Civil and Administrative Tribunal (VCAT) and at the Australian Industrial Relations Commission (AIRC) in relation to unfair/ unlawful termination applications. 1.1 JOBWATCH'S CLIENTS JobWatch is uniquely placed to comment on the effects of legislation on a broad range of Victorian employees, particularly disadvantaged workers. Our records indicate that our callers have the following characteristics: the majority are not covered by collective agreements and are only entitled to the minimum conditions under federal awards or the minimum Standard under Workplace Relations Act 1996; the majority are not union members; a large proportion are employed in businesses with less than 20 employees; a significant number are engaged in precarious employment arrangements such as casual and part-time employment or independent contracting; many are in disadvantaged bargaining positions because of their youth, sex, racial or ethnic origin, pregnancy status, socio-economic status, or because of the potential for exploitation due to the nature of the employment arrangement, for example apprenticeships and traineeships; many are job seekers attempting to return to the labour market after long or intermittent periods of unemployment; The case studies provided in this submission are those of actual but de-identified JobWatch clients or callers to JobWatch's telephone information service. 2. EXECUTIVE SUMMARY RECOMMENDATIONS That section 37(d) and section 38 of the Sex Discrimination Act 1984 (Cth) (SD Act) be repealed and incorporated in the general inherent requirements exception discussed below. An alternative to the current exemptions related to employment of persons in the SD Act, including sections 30, 35, 37(d), 38 of the SD Act would be the repeal of those exemptions and the inclusion of an 'inherent requirements' provision. That the SD Act be amended so that discrimination on the basis of sexual preference and gender identity amounts to 'unlawful discrimination'. That the exemption for religious bodies in the definition of 'discrimination' in section 3 of the HREOC Act be removed. That the definition of "employment" in the SO Act should be expanded so that all workers (paid and unpaid) are protected by anti-discrimination law including apprentices, trainees and volunteer workers. 3. INTRODUCTION JobWatch welcomes this opportunity to comment on the Human Rights and Equal Opportunities' Freedom of Religion and Belief in the 21st Century Discussion Paper (Discussion Paper). This submission will comment on the aspects of the Discussion Paper that relate to discrimination in the area of employment, specifically, JobWatch will respond to: Part 1, Question 3: "Is there adequate protection against discrimination based on religion or belief, and protection of ability to discriminate in a particular context?" Part 7, Question 8: "Should religious organisations (including religious schools, hospitals and other service delivery agencies) exclude people from employment because of their sexuality or their sex and gender identity?" In this submission, JobWatch contends that although the Sex Discrimination Act 1984 (Cth) (SD Act) and Human Rights and Equal Opportunity Act 1986 (Cth) (HREOC Act) go some way towards meeting their objectives they could be improved by reducing or limiting the scope of the exemptions to those Acts which only work to undermine their effectiveness. In particular, we argue for the repeal of a number of employment related exemptions contained within the SD Act. We believe that these exemptions go beyond the scope of reasonable limitations on human rights and that the objectives of the SD Act will be more effectively achieved if these recommendations are implemented. Underlying principles of this submission The right to work is a fundamental human right (as outlined below) Any exemptions in anti-discrimination legislation should not be used to limit access to employment opportunities, but rather should serve to advance substantive equality between various groups in society. In the event that exemptions are retained they should be limited to only those provisions which are necessary to ensure fairness and reasonable practical application of equal opportunity principles on a case by case basis. Recruitment, selection and employment related decisions should be based on sound and defensible criteria, such as ability, merit, performance, behaviour and the operational requirements of the employer, untainted by irrelevant reference to a person's attributes ego sex, sexual preference and gender identity. The community's best interests are afforded by facilitating genuine equality of opportunity for all its members. It is only in rare circumstances that competing interests, rights or "community standards" justify limiting the operation of antidiscrimination legislation. 4. SHOULD RELIGIOUS ORGANISATIONS EXCLUDE PEOPLE FROM EMPLOYMENT BECAUSE OF THEIR SEXUALITY OR THEIR SEX AND GENDER IDENTITY? There is no simple "yes" or "no" answer to this question. The issues raised by the above question involve negotiating the delicate balance between two separate yet overlapping human rights, that is, the right to religious freedom and the right to equality in employment. These two human rights are enshrined in international laws and have been incorporated to some extent into Australia's domestic legislation, for example, in the HREOC Act and the SD Act. The International Covenant on Civil and Political Rights (ICCPR) declares that: All persons are equal before the law and are entitled without any discrimination to the equal protection of the law. In this respect, the law shall prohibit any discrimination and guarantee to all persons equal and effective protection against discrimination Further, equality of opportunity in employment translates to a recognition of the right to work. This right is specifically recognised in the Universal Declaration of Human Rights which provides that: everyone has the right to work, to free choice of employment, to just and favourable conditions of work and to protection against unemployment The ICCPR also declares that: Everyone shall have the right to freedom of... religion which includes the freedom to have a religion or whatever belief of his choice, and freedom ... to manifest his religion or belief in worship, observance, practice and teaching The Declaration on the Elimination of all Forms of Intolerance Based on Religion or Belief states that the right to freedom of religion includes the right: to train, appoint, elect or designate by succession appropriate leaders called for by the requirements and standards of any religion or belief Jobwatch submits that the federal anti-discrimination law framework does not provide an adequate balance between the right to religious freedom and the right to equality in employment. Currently, the SD Act protects the right to religious freedom at the expense of an individual's right to equality in employment. The exemptions granted to religious organisations in the SD Act are too wide, which can result in the right to equality in employment being unreasonably derogated. 5. EXEMPTIONS IN THE SD ACT The SD Act affirms that all individuals are equal before the law and are entitled to equal protection and benefit of the law and provides that discrimination against people on the ground of sex, marital status, pregnancy or potential pregnancy and, in limited circumstances, family responsibilities is unlawful. Section 37 and section 38 of the SD Act provide wide exemptions from the application of the SD Act for religious bodies and educational institutions established for religious purposes. JobWatch supports the exemptions in the SD Act that operate to protect the rights of people to freely practice their religion, namely sections 37(a)-(c). Indeed, these sections are in accordance with the United Nations Declaration on the Elimination of all Forms of Intolerance Based on Religion or Belief. However, JobWatch submits that the following exemptions are not a measured and proportionate approach to the inherent conflict between equally important human rights, namely, the right to religious freedom and the right to equal opportunity in employment. Section 37(d) SD Act - Religious Bodies Section 37(d) provides that religious bodies may discriminate on the basis of sex, sexual preference, marital status and pregnancy when undertaking an act or practice where the act conforms to the doctrines, tenants or beliefs of that religion or is necessary to avoid injury to the religious susceptibilities of adherents of that religion. Section 38 SD Act - Educational institutions established for religious purposes This exception provides that if acting in good-faith to "avoid injury to the religious susceptibilities of adherents of that religion or creed", educational institutions established for religious purposes can lawfully discriminate on the basis of: sex, marital status or pregnancy in the interview process, in deciding who to employ, when dismissing an employee or in not allowing a contract worker to work or continue to work; and marital status or pregnancy of students or potential students Recommendation - That section 37(d) and section 38 of the SO Act be repealed and incorporated in the general inherent requirements exception discussed below. Laws providing exemptions protecting religious freedom must also ensure that the exemption is not misused or misapplied such that certain groups are disingenuously excluded from employment. For example, while the marital status or sexual orientation of an employee may be relevant if the person is a religious instructor, they are of limited, or of any, significance for persons performing other roles, for example, teaching maths, cleaning or administrative duties. If this exemption is to be retained, we recommend that the SO Act implement a system similar to that in section 83 of the Equal Opportunity Act 1995 (Vic), whereby in order to rely on the exemption, religious bodies and educational institutions established for religious purposes would have to apply to a Court or Tribunal on a case by case basis and have the onus of proving that the exemption from non-discrimination laws is reasonable in the circumstances and should be granted for public interest reasons. Applications by persons requesting an exemption from the SD Act should be dealt with using a quick, informal and inexpensive process. Arguably a Court or Tribunal is better placed to make impartial decisions about where to draw the line when balancing competing human rights. For example, considerations in favour of applying discrimination law may include whether the religious organisation receives public funding, the significance of the social or economic impact of the activity and whether it is in the public interest, while considerations in favour of awarding an exemption could include whether the activity fails within the private sphere and the centrality of a particular activity to a religion. Alternatively, the application of the section should be limited to positions in religious bodies and schools which genuinely require adherence to the particular beliefs and tenets of the religion in order to carry out the inherent requirements of the positions. Case Study Pam worked as a teacher on a permanent part time basis for 7 years in a religious school and resigned when she became pregnant. After being away from the workplace for 12 months she rang the school and asked about job opportunities. The Principal at the time said she would first need to ask the teachers who were currently employed whether they would like the position before Pam or anyone else would be considered. A few months later Pam spoke to a new Principal who commenced at the school and asked whether she could replace a teacher who was resigning. The principal told Pam she could never re-employ her as she had children out of wedlock. Pam submitted a discrimination complaint with the Victorian Equal Opportunity and Human Rights Commission. The matter was unsuccessfully conciliated and was referred to a hearing at VCAT. The employers defense is that an exemption for schools exists in the Equal Opportunity Act 1995 (Vic) which allows them to discriminate against Pam on the basis that she is living in sin. Recommendation - New Exemption: Inherent Requirements An alternative to the current exemptions related to employment of persons in the SD Act, including sections 30, 35, 37(d), 38 of the SD Act would be the repeal of those exemptions and the inclusion of a provision which incorporates the following elements: 1. A statement that discrimination in employment is unlawful on the basis of sex, martial status, pregnancy, potential pregnancy, sexual preference and gender identity, unless a person is unable to perform the inherent requirements of the particular employment. 2. A list of the factors to be considered when determining whether a particular requirement is "inherent" to a position. This list should include: Whether a particular task is genuinely essential to the position. The skill set and qualifications required to do the position. Whether the position could be performed with modifications being made to accommodate the performance of the job by a person with an impairment. Whether public standards of decency require that the position be filled by a person of a particular sex. Whether reasons of artistic credibility require the position to be filled by someone with a particular attribute. Whether it is a genuine occupational requirement that a person be of a particular sex, such as a necessary physical characteristic particular to people of one sex, other than strength or stamina; or the preservation of decency or privacy; for example where employment involves fitting clothing, undertaking body searches or entering lavatories or other areas where people are in a state of undress. Whether the most effective delivery of welfare services to a particular group requires that the job be performed by a person with a specific attribute. Whether adherence and commitment to the particular beliefs and tenets of a religion are required in order to carry out the fundamental requirements of a position with a religious body or religious school. The case below demonstrates how the 'inherent requirements' exception may operate in practice. The case was decided pursuant to Queensland antidiscrimination law which, unlike the SD Act, applies equally to paid and unpaid work (i.e. volunteers). While the above case concerns discrimination on the basis of religious belief, similar principles apply when determining discrimination on the basis of sexual preference or sex and gender identity. CASE STUDY- Inherent requirements in practice In a recent decision, the Queensland Anti-Discrimination Tribunal (Tribunal) found that the St Vincent de Paul Society of Queensland (SVDP Society) had discriminated against Walsh, a non-Catholic elected president of a local conference of the SVDP Society, where she was told to convert to Catholicism or lose her position. Facts Walsh was Christian, but not Catholic, and had worked seven days a week in her voluntary position as president of the local SVDP Society conference from 2001 to 2004. In 2004 a more senior member of the SVDP Society gave her three choices; become a Catholic, resign her position and remain a member of the SVDP Society or leave the SVDP Society. Discrimination Complaint and Response Walsh lodged a discrimination claim alleging that she had been discriminated against in employment because of her religious beliefs. The SVDP Society opposed the claim on two alternate grounds. Firstly, that it was a religious body and therefore exempted from the relevant anti-discrimination law. In the alternative, that being a Catholic was a genuine operational requirement of the position as president of a conference of the SVDP Society and that they were entitled to act towards Walsh in the manner that they did. Decision The Tribunal rejected both of the SVDP Societys arguments. Having regard to the constitutional rules and guidelines that governed the SVDP Society, the Tribunal found that firstly, the SVDP Society was not a religious body, it was a Society of lay faithful. Secondly, that while there was a spiritual aspect of the job, it was not a major part and that being Catholic was not a genuine operational requirement of the position. Walsh was awarded compensation for pain and suffering, medical expenses and legal costs. 6. DISCRIMINATION ON THE BASIS OF SEXUAL PREFERENCE (OR 'SEXUALITY') AND GENDER IDENTITY Recommendation - The SD Act be amended so that discrimination on the basis of sexual preference or gender identity amounts to 'unlawful discrimination'. The HREOC Act distinguishes between 'discrimination' and 'unlawful discrimination'. The definition of 'discrimination' includes reference to sexual preference, while 'unlawful discrimination' does not include discrimination on the basis of this ground. Neither definition includes the ground of gender identity. The main differences between the two are as follows. A complainant making an 'unlawful discrimination' complaint has access to remedies from the Federal Court or Federal Magistrates' Court if the matter is unable to be resolved during the conciliation stage at the HREOC. A complainant making a 'discrimination' complaint may request that the HREOC inquire into the matter and assist them to settle the matter, however if a settlement is not reached the only remedy available is that the HREOC may report the inquiry to the Minster. The result is that pursuant to federal anti-discrimination law there are no substantive protections for persons who have been discriminated against in employment on the basis of sexual preference or gender identity. JobWatch submits that, subject to any constitutional issues, the SO Act should be amended to include unlawful discrimination on the basis of sexuality (or 'sexual preference') and gender identity. Again, the right to religious freedom is adequately protected through the implementation of the inherent requirements exemption as proposed above. Recommendation - That the exemption for religious bodies in the definition of 'discrimination' in section 3 of the HREOC Act be removed. As discussed above, there are very limited remedies at the HREOC for complainants who make a complaint of "discrimination" in employment on the basis of sexual preference or gender identity. These limited remedies are further restricted by the exemption in section 3 of the HREOC Act which provides that the HREOC may refuse to even inquire into a complaint of 'discrimination' in employment on the basis of sexual preference if the employer is a religious organisation and the alleged discriminatory act was conducted in good faith to avoid "injury to the religious susceptibilities of adherents of that religion or that creed". As discussed above, the wide discretion afforded to religious organisations by such an exemption unreasonably favours the right to religious freedom over the rights of equality in employment. JobWatch submits that the express exemption for religious organisations in the definition of 'discrimination' in section 3 of the HREOC Act is unnecessary and should be removed given that there is adequate protection for religious freedom utilising the exemption provided by the 'inherent requirements of the job' contained within the proposed definition. 7. DEFINITION OF 'EMPLOYMENT' IN THE SD ACT Section 4 of the SD Act defines "employment" to include part-time and temporary employment, work under a contract for services and work as a Commonwealth employee. Recommendation - JobWatch submits that the definition of "employment" in the SD Act should be expanded so that all workers (paid and unpaid) are protected by anti-discrimination laws including apprentices, trainees and volunteer workers. Pursuant to international human rights laws, all workers are entitled to be protected from discrimination in employment (see section 4 above). In Australia it is recognised that workers include apprentices and trainees, for example in federal legislation such as the Workplace Relations Act 1996 (Cth) (WR Act). Currently an apprentice is eligible to lodge a complaint against her employer alleging unlawful dismissal for reasons of her pregnancy pursuant to the WR Act, however not be eligible to make a complaint of discrimination on the basis of pregnancy to the HREOC against her employer pursuant to the SD Act. Unpaid workers, i.e. volunteers should be included in the definition of "employment". The fact that a volunteer is not paid a wage does not mean they cannot experience discrimination and sexual harassment. Accordingly, volunteers should be able to seek general damages for injury to feelings, even if they cannot seek special damages for lost income. Any constitutional issues may be overcome using the Corporations power in the Constitution, in the same way that it was utilised to expand the Federal Government's powers made under the WR Act. 8. CONCLUSION In order for the right to religious freedom to be adequately protected alongside the right to equality in employment, federal anti-discrimination laws must be amended to redress the current imbalance that favours the rights of religious organisations over the right to work. JobWatch calls for the implementation of a more measured approach, which refocuses attention onto the inherent requirements of a particular job, to be decided by an independent Court or Tribunal on a case by case basis, rather than deferring those decisions toreligious organisations themselves. JobWatch would welcome the opportunity to discuss any aspect of this submission further.  We understand that HREOC has or will soon be changing its name to the Australian Human Rights Commission (AHRC). For the purposes of this submission we have preferred to use HREOC.  This submission draws on JobWatch's Submission to the Review of the Exceptions to and Exemptions from the Equal Opportunity Act 1995 (Vic)  Article 26 ICCPR.  Article 23(1) UDHR.  Article 18 ICCPR.  Article 6 DEFIBRB.  Article 6. This declaration specifically affirms the right to appoint religious personnel.  EVANS, C and Gaze 13: Between Religious Freedom and Equality: Complexity and Context 49 Harv. Int'l L. J. Online 40 (2008)  Walsh v St Vincent de Paul Society of Queensland (No.2) [2008] QADT 32.  Regulation 4 Human Rights and Equal Opportunity Commission Regulations 1989 (Cth).  See the case study of Walsh v St Vincent De Paul Society in paragraph 5 above.     PAGE  PAGE 7 ? H K ] l w U _ LV@X9cz$%jk015XxڸڸΦڜړړړړړړړړ hRF^JhRFhRF^JhRFhD5^J#jhRFhD0J:5U\^JhRFhD]^JhRFhD6]^JhRFhD5\^JhRFhD^JhRFhDCJ^JaJhRFhD5CJ\^JaJ7   = > ? 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