Cynulliad Cenedlaethol Cymru	National Assembly for Wales
Bil Awtistiaeth (Cymru) drafft	Draft Autism (Wales) Bill
Llythyr Ymgynghori DAB26b	Consultation Letter DAB26b
Ymateb gan Cymdeithas Genedlaethol Awtistiaeth Cymru	Evidence from National Autistic Society Cymru

Please refer to questions in the consultation Letter.

Question	Answer
01	Yes we agree because it is useful to have a starting point. The English Autism Act 2009 and the Irish Autism Spectrum Disorder Bill 2017 do not have a definition of ‘autism spectrum disorder’.
02	The alternative would be to refer to “autistic spectrum conditions” in the same way that it is defined in the English Autism Act 2009. Is the use of neurodevelopmental disorder and the World Health Organisation’s definition of autism spectrum disorder wide enough? To be discussed.
03	The definition of “relevant bodies” is suitably wide. We think it is important to cover local authorities and NHS bodies. In addition, it may be useful to expand on what is meant by local authorities and NHS bodies, for example: “local authority” means: (a) each of the 22 county, borough, city and district councils in Wales; (b) a county council; (c) a borough council; (d) a city council; and (e) an NHS body “NHS body” means: (a) NHS Wales; (b) NHS (Wales) Trusts; (c) a Local Health Board; and (d) a Special Health Authority performing functions only or mainly in respect of Wales.
04	This could be useful, and may even act as an incentive to encourage relevant bodies to have regard to the autism strategy.
05	5 months were allowed for publication of the Autism Strategy under the Autism Act 2009. 6 months should be sufficient and is broadly in line with the Autism Act 2009. The Autism Strategy needs to be published promptly to give effect to the Autism Bill.
06	Perhaps this could be shortened slightly to 2 months, again this is in line with the Autism Act 2009 and it is key for the relevant bodies to be provided with the guidance to assist them.
07	This could be reduced to 2 months, in line with the Autism Act 2009.
08	Yes, particularly as appropriate timescales may change.
09	Yes, we think it is useful to include a longstop date here.
10	Yes, provided that this list is not exhaustive and there is scope for other appropriate professionals to be included as necessary.
11	Yes, we suggest also including the following: − A counsellor; − GP; − Paediatrician; − Care manager; and − Health visitor.
12	To be discussed.
13	Yes in light of the laws and ongoing concerns surrounding data protection.
14	This should be looked at carefully in light of the new data protection legislation, the General Data Protection Regulation, which comes into force on 25 May 2018.
15	The types of data could be specified in the guidance together with reference to the current data protection legislation and to allow for amendments to the data protection legislation. The main reason for this is that the types of data may change fairly frequently as this is a topical and fast moving area.
16	Yes we agree that it is appropriate for Welsh Ministers to request anonymised data from relevant bodies and that it should be included on the face of the Bill. We suggest expanding section 5(3) of the Bill to make it clear that any such data shall be used in accordance with all relevant data protection laws. As currently drafted, the Bill covers the receipt of the information, but not the subsequent use.
17	A campaign to raise understanding and awareness of the needs of person with autism spectrum disorder should be rolled out on a continuous basis for the first two years of the Autism Bill coming into force because it is a new type of disability specific legislation in Wales. Thereafter, it may be more appropriate to roll out an awareness campaign every two years.
18	There is scope to promote items (a) to (c) above. To be discussed.
19	(a) We suggest including the training of staff who provide relevant services to children and adults with autism spectrum disorder to section 2(1).  (b) In addition in section 3(5), the reference to autism strategy should be amended to refer to the “current” autism strategy as the strategy may change under the Bill. (c) It may be worth considering whether a register of persons with autism and a separate register of children with autism should be maintained. This will need to be considered alongside data protection issues and legislation. (d) We suggest adding a definition of “autism strategy” to the interpretation section 7: “autism strategy” means the strategy required to be published under section 1(1). (e) Is there a more specific definition of “carer” that could be used especially as the guidance will not be published immediately upon the enactment of the Bill? (f) Should the definition of “local authority” be expanded to include city and district councils in Wales? (g) Should a section on expenses in connection with the preparation of the Bill be included? (h) Under section 10, should a statement be included to make it clear that the Bill only applies to Wales for completeness?