Equality Impact AssessmentTraining

History

• Stephen Lawrence case

• The Macpherson Report

• Police Force ‘institutionally racist’ - policies, procedures, operations, culture

Institutional Racism

“the collective failure of an organisation to provide an appropriate and professional service to people because of their colour, culture, or ethnic origin. It can be seen or detected in processes, attitudes and behaviour which amount to discrimination through unwitting prejudice, ignorance, thoughtless and racist stereotyping which disadvantage minority ethnic people”.

Stephen Lawrence Inquiry

(Macpherson Report 1999)

Legal Drivers

Legal Requirement:– to undertake Equality Impact Assessments on all

new or revised policies & practices (all activities)

• Race Relations Amendment Act 2000• Disability Discrimination Act 2005• Equality Act 2006 (Gender)• Forthcoming Single Equality Bill

Other Requirements

• Public Sector Duties

• Care Quality Commission Standards

• NHS Constitution

• WCC

• External Funders

• PCT Strategy & Policy

What is an EIA?An EIA is a process:

• Support managers in analysing work• Demonstrate understanding of community• Assess of needs• Check impacts on public & minority

groups• Take action to improve services for all

Good policy making

What is an EIA?

EIAs serve as legal back up:

• understand the impact of our work on different groups

• take action to prevent unintentional discrimination

• ensure that the organisation is accountable for its actions

Southall Black Sisters v Ealing Council

• Domestic violence services to BME community• Council provided 1/3 of funding• Council changed funding structure to invest in

services for all local women• Adverse impact on a minority group• No consultation and no EIA• SBS sued and won

Average payout - half a million!

Aims of an EIA

Outcomes - Actions - Improvements

• Assess how our work affects minority groups • Identify negative & positive impacts• Identify alternative solutions• Promote equality of opportunity • Create needs-led, responsive services • Help manage relations with groups

What Should Be Assessed?

All new and revised:

• Policies

• Procedures

• Projects

• Strategies

• Services

• Functions

Directorates to identify existing policies.

The Policy Process

Responsible Role

Policy Author

E&D Lead

Manager

E&D Coordinator

Policy Committee

E&D Coordinator

Policy Author

carry out EIA

support on EIA

check for EIA before sign off

quality check EIA

check for approved EIA

publish final EIAmonitor progress and carry out follow-up actions

Types of EIA

• Relevance Screening

• Initial Assessment

• Full EIA

Relevance Screening

Minimum requirement for all policies

• Outline aims

• Nature of policy (strategic? major project?)

• Likely impact on minority groups?

• Identify to undertake further work

Next Step

Strategic? Yes No

High impact Full Initial / Full

Medium Impact Full Initial

Unknown Impact Initial Initial

Low Impact x x

Initial EIA

• Aims of the policy

• Evidence your assessment is based on?

• What data says about minority groups?

• Consultation work - what minority groups said

- what experts have said

• Could policy impact on a minority group?

• How will you monitor impacts?

• Unanswered questions? Full EIA

Full EIA

A Full EIA will be done in one of two situations:

1.The “policy” is of substantial national or local public concern or is of such significance that a Full EIA was identified in the screening process.

2.The Initial EIA identifies large gaps in knowledge or considerable concerns of possible negative impact or on different groups.

What’s The Difference?

• A Full EIA is an extension of an initial EIA.• Greater level of analysis• Requires consultation• Clear outline of alternative options • Rationale of decisions• Clear recommendations• Specific Actions • Monitoring Arrangements

Full EIA

• Aims of the policy • Gather and use data• Assess impact• Consider measures • Consult on the impact of existing policies and

the likely impact of proposed policies • Decision making• Establish monitoring systems• Publish EIA

Positive Impact

Example:– A targeted training programme for black

and minority ethnic women would have a positive impact on black and minority ethnic women, compared with its impact on white women and men. It would not, however, necessarily have an adverse impact on white women or men.

Differential Impact

For example:

- An organisation does not offer flexible hours as part of their work life balance policy. Although this should impact both men and women, the impact is likely to be different for women as the predominant primary carers of children or other dependants.

Negative Impact

Example:– A community consultation event held in a

building with no Induction Loop facility would have a negative or adverse impact on some attendees with a hearing impairment.

Resolving Negative Impacts

• Consider alternative methods to implement policy

• Consider additional measures to help minority groups receive equal access

• Consult on options• Make changes to the strategy / policy• Put actions to reduce or eliminate

impacts into a 3 year plan and publish

Consultation

• Who will the policy affect?

• Have you spoken to them?

• What do service users want?

• Have the questions already been asked?

• Do you need more information?

Consulting Methods

• Specialist groups

• Service monitoring

• Survey

• Open event (interpretation? access?)

• Focus group

• Community Interviewers

Help With Consultations

• PALS

• LINkS

• Community Liaison Staff

• Specialist groups

• Consultants

• Consultations database

Follow-Up

• What did people say?

• How can we best respond to needs?

• Action Plans

• Monitoring

• Analysis

• Update Consultation database

Key Points• Start an EIA at the beginning of the

process• Use of Evidence / Data• Consultation• Monitoring Arrangements

– To address knowledge gaps– impact of the “policy”

• Quality Check• Publish EIA• Follow-up & Review

Who To Go To For Advice

• Equality Leads in each Directorate

• Equality Steering Group

• Engagement Team

• Head of Equality

Where to Get More Information

• Corporate Shared Drive

• Website

• Specialist Groups

• Equality & Diversity Coordinator

EIA Exercise

Mock policy:

• Relevance screening

• Initial EIA

• What data do we need to assess?

• Consultation needs?

• Potential impacts?

• Full EIA