Home » Tait v Holiday Extras: reasonable adjustments in call centre

Tait v Holiday Extras: reasonable adjustments in call centre

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Last updated 21st August, 2026.

The claimant had various disabilities, mostly mental. She worked in a call centre. This dealt mainly with voice calls, but also chat and email. An employment tribunal upheld many of her claims for reasonable adjustments. For example she could feel overwhelmed by too many voice calls, and the tribunal held that in all the circumstances, it was a reasonable adjustment to give her a higher proportion of chat/email, and the ability to switch to chat/email if struggling with voice. She should also have been allowed to turn off her camera in an online meeting.

2026, Employment Tribunal. 6012387/2024. Full decision www.gov.uk/employment-tribunal-decisions/ms-l-tait-v-holiday-extras-ltd-6012387-slash-2024

Summary and comments

Facts and decision, in brief

The claimant had various disabilities, including anxiety/depression, ADHD, and autism. She worked from home in a call centre, as a travel consultant selling insurance. There were about 30 staff on duty at a time. Most of the role was voice calls, but with staff also switching to chat/email.

The claimant could feel overwhelmed by too many voice calls. She asked for a higher proportion of chat/email, and the ability to switch to chat/email if struggling with voice. The employer said this could not be a permanent adjustment – the different channels needed to be allocated between staff fairly. The employment tribunal (ET) upheld her claim on these adjustments. In the circumstances they would be reasonable adjustments for the employer to make.

Among the other adjustments that the ET held should have been made were allowing her to join video meetings with the camera off, and adjustments to help her deal with changes to the employer’s instructions.

Comment: Adjustments relevant to stammering

This is not a binding precedent, as it is not an appeal decision. However, it is interesting as a decision on adjustments which may be relevant to stammering. (The claimant did not have a stammer.)

It should be stressed that what is reasonable will depend on the particular circumstances. It was important here, for example, that the claimant was one of a relatively large number of staff on duty at a time, so the ET felt it was workable for the employer to make many of the adjustments she sought.

Adjustments upheld by the ET which may be helpful for stammering include:

The ET rejected her argument that it would be a reasonable adjustment to provide her with a Bluetooth headset, so she could move around while on a voice call: below Bluetooth headset so could move about while on phone call. Some people who stammer may find this helpful. However the ET’s rejection was on technical grounds, and she might potentially have claimed it as an ‘auxiliary aid’: Reasonable adjustment rules: employment>Auxiliary aids and services.

Comment: Masking/hiding the disability

In this case (and normally) reasonable adjustments are to alleviate the substantial (ie more than minor or trivial) disadvantage at which the disabled person is put by a provision, criterion or practice (PCP) of the employer (Reasonable adjustment rules: employment>Substantial disadvantage). The claimant’s disadvantage to be addressed by giving her a higher proportion of chat/email shifts was expressed as ‘the effort of “masking” the claimant’s ADHD and autism symptoms caused fatigue and cognitive issues’.

Masking has been described as a strategy used by (for example) some autistic people, consciously or unconsciously, to appear non-autistic: Masking (autism.org.uk). This sounds very much like the efforts of many people who stammer to hide their stammer and to appear fluent: Hiding the stammer.

Where someone hides their stammer or other disability, there is the issue of what is the ‘disadvantage’. (In Hiding the stammer, I deal with a similar issue as regards ‘substantial effect’ and the definition of disability.) It is interesting that fatigue and cognitive issues caused by the effort of masking were accepted by the ET as disadvantages. Fatigue is perhaps the most relevant for stammering.

See further Reasonable adjustment rules: employment>Disadvantage: Hiding the disability.

The case in more detail:

Facts

The claimant had various disabilities, of which her employer was aware from different points of time. These included anxiety/depression, ADHD, autism, and gastrointestinal problems exacerbated by anxiety.

She worked from home in her employer’s call centre, as one of about 55 travel consultants selling insurance policies. The average number on shift at any time was around 30. There were three elements (channels) to their role: voice calls, live chat, and emails. The consultants were expected to work across all three channels. Sometimes they had to switch from chat/email to voice when voice calls were high.

Voice was the core role. That was where the employer made most of its sales. In 2023 and 2024, between about 69% and 78% of customer interactions were via voice calls, about 14% to 20% were chat, and about 5% to 12% were emails. The employer would put staff on the various channels according to demand. This usually resulted in two or three people on chat at any one time, but there would be occasions when nobody was on chat/emails.

The claimant started taking time off work due to health issues, particularly from November 2022. Some adjustments were made, and others were refused. She was off with anxiety and stress from 26 June 2023, and began a phased return (including some adjustments) from 7 August. She was signed off sick on 15 October 2023 on similar grounds, and at the time of the ET decision she had not returned to work.

One recurring issue was that the claimant asked for more chats and emails. She said she was often overwhelmed on voice calls. As early as September 2022, for example, she said she found voice calls mentally draining, talking for 8 hours, 5 days a week. She preferred chats as she had more time to gather her thoughts before responding, it better suited her personality, and it was better for her mental health. However, the employer said it was not possible to give her more chats/emails long term. The shifts would be distributed ‘fairly’.

She made an employment tribunal claim for failure to make reasonable adjustments.

ET decision

The employment tribunal (ET) upheld her claim in respect of many of the reasonable adjustments she sought.

The ET commented that while the employer put some adjustments in place, they were temporary and mostly connected with the claimant’s phased return to work. She sought permanent reasonable adjustments so that she could be confident of being able to successfully do her job going forward. The temporary measures put in place by the employer were inadequate. The employer should have considered permanent solutions, given her ongoing disabilities.

The ET held that the employer had failed to make a number of reasonable adjustments, specified below. Accordingly the claimant, as a disabled person, was left with substantial disadvantages in the workplace, which resulted in her having significant sickness absences.

Note: Her claims were for adjustments in relation to PCPs. That is where a provision, criterion or practice (PCP) applied by or on behalf of an employer puts a disabled person at a substantial disadvantage in comparison with persons who are not disabled. I also set out below the relevant PCPs and disadvantages.

ET: Adjustments related to ‘masking’, and proportion of chat/email shifts

She claimed the following adjustments in relation to ‘PCP1’ (3.2.1 in the list of issues), namely the requirement to undertake mostly ‘voice’ (telephone) shifts. These adjustments were in order to address the disadvantage that ‘the effort of “masking” the claimant’s ADHD and autism symptoms caused fatigue and cognitive issues’ (3.3.1 in list). [Above: Comment: Masking/hiding the disability.]

Higher proportion of chat/email shifts

The ET accepted (contrary to the employer’s argument) that more chat/email shifts would be likely to remove the disadvantage of masking.

As to whether this adjustment was reasonable, the ET said that whilst most of the workload was voice, there was still a significant proportion that was chat/emails. With around 30 employees on shift at any one time, there was sufficient scope to provide the claimant with additional chat/email shifts, whilst maintaining cover on voice.

Although the employer had said flexibility was essential and there was sometimes a need to shift an employee from chat/email to voice, this would not prevent the claimant being rostered more chat/emails whilst remaining flexible.

The ET did not accept the employer’s argument that allocating the claimant more chat/email shifts would de-skill other employees in chat/emails. The impact spread across 50+ other travel consultants would be minimal. Also, as the claimant would still be taking a significant volume of voice calls, the ET rejected the employer’s argument that her proficiency in voice would reduce, or that her experience might not remain current.

The ET’s conclusion was that a higher proportion of chat/email shifts was a reasonable adjustment to make from August 2023.

Ability to switch to chat/email if struggling with voice

The ET considered that this adjustment, in combination with more chat/email work, would remove the disadvantage.

As to whether the adjustment was reasonable, the employer argued that it could cause serious practical difficulties and disruption to client service. The ET said it had not been taken to any evidence of this from the time the adjustment was in place temporarily.

The ET found that it was a reasonable adjustment from August 2023.

Transition period of one hour if being moved from chats/emails to voice calls

The ET agreed with the employer that a transition period of one hour would significantly impact business operations. One hour’s transition was excessive, so there was no failure to make a reasonable adjustment in this regard.

ET: Adjustments related to changes in instructions etc

She claimed the following adjustments in relation to ‘PCP3’ (3.2.3 in the list of issues), namely the practice of regularly changing policy terms and instructions for staff on how to interact with clients. These adjustments were in order to address the disadvantage that ‘the claimant’s conditions mean that it takes longer to assimilate those sorts of changes, and changes cause anxiety as the claimant wants to make sure she is doing everything right’ (3.3.5 in list).

Additional help when policy/procedure/scripting changes are made

The employer submitted that from the outset of her employment, the claimant could ask for one-to-one time with a manager, support from trainers, or time with a mentor. The employer also ran Buzz sessions where employees could ask questions. The claimant was offered buddying and extended breaks.

The ET said the buddying and extended breaks were part of the phased return to work and not permanent. The other provisions were available generally. However, the claimant needed more than this so that she could properly assimilate changes.

The ET held that providing additional help was a reasonable adjustment to put in place from August 2023.

Time at the beginning of the day to catch up on any changes

The ET concluded that a modest amount of time at the start of the day to catch up on any documents relating to changes, was a reasonable adjustment to make from August 2023, when the employer knew of the disadvantage.

ET: Bluetooth headset so could move about while on phone call

Alleged PCP4 was ‘The requirement to conduct calls from seated at a desk’ (3.2.4 in list of issues). The claimant said that this put her at a disadvantage in that her ADHD meant that when under-stimulated, for example on a lengthy call, she found it hard to concentrate (3.3.6 in list).

To address this, she claimed it would be a reasonable adjustment to provide her with a Bluetooth headset to enable her to move around.

Her claim on this failed. The ET found that there was no requirement to conduct calls from a desk, and therefore no PCP4, so there could not be a reasonable adjustment to it. In any event, the ET noted that when the claimant requested a Bluetooth headset, it was provided.

[Comment: A bluetooth headset might potentially have been claimed as an ‘auxiliary aid’ (if not provided), which would not require there to be a PCP: Reasonable adjustment rules: employment>Auxiliary aids and services. Or the relevant PCP might have been the requirement to make voice calls.]

ET: Ability to join meetings with camera off

On 24 August 2023 the claimant was doing a remote training session by video, and asked to have her camera off, as she felt ‘super anxious’. She was asked to start with it on and to see how she went. However, she was not able to cope, and so she was told that was fine, and to log off.

The claimant argued that the employer had failed to make the reasonable adjustment of allowing her to leave her camera off. This related to PCP5, namely ‘The requirement to join meetings or training session with camera on (specifically a training session on 24 August 2023)’, at 3.2.5 in list of issues. She said this PCP put her at the disadvantage that ‘joining meetings with video on can cause overwhelm’,

Her claim succeeded. The employer did not allow the requested adjustment on 24 August 2023, when first made aware of the claimant being overwhelmed. However, the employer did not require her to come on camera thereafter, and the Chief Operating Officer formally agreed to the adjustment in October 2024.

The ET took the view that the adjustment was reasonable and should have been put in place from 24 August 2023.

Other adjustments, in brief

Other adjustments considered by the ET were:

  • A compressed working week of four longer shifts – accepted by the ET as a reasonable adjustment from mid-September 2024.
  • Two set days off together – this had not been requested by the claimant, and was not a reasonable adjustment given that the employer did not know (and should not have known) it would benefit her.
  • Regular rota – accepted by the ET as a reasonable adjustment from mid-September 2024.
  • Flexible start and finish times – accepted by the ET as a reasonable adjustment from mid-April 2024.
  • Single point of contact in place as part of her phased return to work, subject to staff rotation and absences – accepted by the ET as a reasonable adjustment from August 2023.
  • Redeployment to another role – claim failed because the claimant had specified neither a substantial disadvantage that this adjustment would address, nor a PCP from which any disadvantage flowed.

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