Equality Impact Assessment EIA Toolkit

Transcription

1 Equality Impact Assessment EIA Toolkit A practical guide to assess the impact functions, policies and procedures have on different groups of people With thanks to Sport Scotland

2 Contents 1. Introduction to EIA 2. Initial Screening 3. Full EIA 4. Guidance for each step 5. Initial Screening template 6. Full EIA template 2

3 1. Introduction to Equality Impact Assessment (EIA) What is an EIA? EIA is a tool to help us ensure that our policies, functions and practices do not have a negative impact on equalities groups, including age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, gender, sexual orientation, and socio-economic status. EIA involves the gathering of evidence, consultation with people from different groups and analysis of impact. It will also require consideration of the changes necessary to address any negative or unintended impacts, and, the changes necessary to actively promote equality for the various equality groups. Why do we need to do EIA? Sport Wales is committed to Equality and understands the need to embed the principles of this agenda in all that we do. Research shows that there are differential participation rates between equalities groups. Using the equality impact assessment framework on new and proposed polices will expose any unintended consequences and/or effects that could undermine or prevent the achievement of stated policy aims (e.g.: participation could be lower than expected.) The EIA will prompt consideration of ways that this can be avoided or monitored from the earliest stages and provide a framework for action. EIA also helps us to meet our legal requirements under the public sector duties in the Equality Act Failure to assess the likely impact of new or ongoing work could lead to legal challenge as well as the inability of services to provide for those who need them most. There may well be policy initiatives that are assessed as having no specific impact on anybody from a disadvantaged community, but it is essential that the process outlined is followed and that evidence for this decision is outlined. Partnership working While Sport Wales is not a delivery agency, our core objectives to increase participation and improve performance provide an opportunity for strategic leadership across a range of activities and functions e.g.: People development, resource/programme development, communications, sports development. This means that we need to impact assess policies, functions, frameworks, programmes, strategies and plans. What is meant by a policy? Policies is the legal term used in the statutory Codes of Practice on the three duties, and is intended to be an umbrella term, which covers all functions and activities. Policy does not simply mean formal written policies e.g. remote working policy or disciplinary policy, although these are included in the definition. 3

4 Some examples of policies in Sport Wales might include: Procurement procedures Recruitment and selection procedures Criteria for investing in NGBs Corporate plan and business plan Active Young People programmes Active Adults programmes Volunteering programmes LAPA plans The website and intranet Grant schemes Who should carry out EIA? The person carrying out the EIA should be the staff member who would normally be developing/reviewing policy, as they have the expertise in that policy area. They may wish to work with another colleague who has knowledge of the way that policy is implemented and experienced on the ground. When should an EIA be carried out. EIA should be carry out Project Set Up Stage, without full information this may well be a screening exercise. A follow up EIA should be undertaken as the policy is reviewed. (As part of the system for monitoring progress.) Please refer to PPD Project Management Tool. 4

5 2. Initial Screening at the Project Set Up Stage To determine whether a full EIA is required, you will need to complete an initial screening. Some policies, activities or functions are of minimal impact, relevance to the equality considerations and do not affect people e.g. accounting policies. In this case an initial screening will justify not conducting a full EIA. In some cases there is insufficient evidence at this time to conduct a full EIA, in this case an initial screening should be undertaken, which should identify when the full EIA will be completed. Initial screening process Define the aims of your programme, policy, function or activity Gather evidence about the needs of equality groups that may be impacted by the policy Is there enough evidence at this stage to indicate that there is a positive or negative impact on a particular group? YES No, there is insufficient evidence at this stage Does the evidence show a positive or negative impact on the different groups? YES No Impact Identify what information you require and how you will collate it. Set timescales for revisiting this process Proceed to full EIA Initial screening completes the process 5

6 Initial Screening Form Title of function, policy, procedure or activity Who is undertaking the screening? Department Lead officer Others involved in the assessment What is the purpose of the activity, function policy? Who is affected by the policy, activity or function and/or who is intended to benefit from it? Is there enough evidence at this stage to indicate that there is a positive or negative impact on a particular group? If there is sufficient evidence, does it show a positive or negative impact on the different groups? When will a full EIA be undertaken If a full EIA is not needed, what are the reasons for this? Date of screening 6

7 3. Full Equality Impact Assessment Step 1 Step 2 Step 3 Step 4 Step 5 Step 6 Step 7 Step 8 Step 9 Define the aims of your programme, policy, function or activity Gather evidence about the needs and/or experiences of equality groups that may be impacted by the policy Analyse how the policy might impact positively or negatively on the different groups Consider what else you need to know to help you understand the diverse needs and/or experiences of your target audience Based on the work you have done rate the level of relevance of your policy for the equality strands and rate the level of potential impact HIGH, MEDIUM OR LOW. Make changes to your policy, where identified, or indicate the timescale for the changes Consider whether further impact assessment is required Outline how you will monitor and evaluate this policy to measure progress. Sign off, summarise and send off. 4. Step-by-step guidance notes Before you start, you will require knowledge of the following where available; For EIA of non-employment policies Findings of research that have informed the policy. Participation data/trends that have informed the policy. Sport Wales Vision and Aspirations. Business Case, project mandate. Results of consultation/feedback on the policy, programme, function or activity. Details of your system for monitoring progress. Strategy for financial management. For EIA of employment policies Information about different employment patterns, pay rates and results of a pay audit or review Your equal pay policy Polices for grievance and discipline 7

8 Rules covering entitlement to and payment of expenses Personal performance planning system Sickness absence policy Employee terms and conditions Eligibility criteria for promotion Results of staff consultation or surveys Details of your system for monitoring and reviewing Analysis of current data on grievance and discipline Step One Define the aims of the programme, policy, function or activity The first step of the impact assessment process is to identify the outcomes that the policy is designed to achieve, and to show how the policy links to the organisation s overall responsibilities and objectives. This stage should be straightforward, as all policies should already have clear aims. Step Two What kind of information do you have about the diverse needs and/or experiences of your target audience? To understand the different needs and experiences of the people you are making policy for, you will need to gather the facts and figures about the target audience for your policy. It is important to know who will be affected by your proposed changes and how. Evidence may include data (facts, figures, research findings, etc) from your own information management systems or research, surveys, consultation exercises and engagement with various representative groups. In the absence of research there may be anecdotal evidence, feedback from service users and affected groups or ongoing experience, which may indicate positive or negative impacts. Points to remember: Evidence may indicate that there may or may not be an equality impact associated with a policy. The absence of evidence or indicators does not necessarily mean that there is no impact on equality. Arrangements should be made to obtain the relevant information to help in the process of deciding whether or not a policy has a differential adverse impact or whether the policy requires further, in-depth equality impact assessment. Consultation/engagement/involvement is a key part of the process. The public sector equality duties require Sport Wales to involve, consult and engage with communities as widely as possible. 8

9 Step Three What does the information you have tell you about how this policy might impact positively or negatively on the different groups within the target audience? In this section you should be looking at the information you have collected to assess what it is telling you about the needs of different groups of people, i.e. whether their needs would be met by your policy (or changes to an existing policy) and whether your policy (or changes to an existing policy) would affect some groups differently. Some questions to consider whilst assessing the evidence: How does relevant current policy affect different groups and sections of those groups? Will the impact of the proposed policy/function be the same or different for each group? Is there any indication or evidence of higher or lower participation or uptake of programmes, services by different groups? Are there any groups of people who are excluded from programmes? Will the proposed changes be beneficial to some or all groups? If the change(s) are going to have an adverse effect on any of the groups - could it amount to unlawful discrimination? Step Four What else do you need to know about to help you understand the diverse needs and/or experiences of your target audience? Do you believe that there is a potential issue for an equality group (or strands) that may require further exploration? Are there any gaps in data, i.e.: Is there a group of people for whom you have little or no information? If so, how do you know how the policy will impact on them? Have you spoken to the right people and asked the right questions, Have you asked your colleagues in research for relevant data? Would it be more helpful if data were disaggregated by different categories (i.e. age, disability, religion and belief, gender, LGBT (lesbian, gay, bisexual and transgender), race, socio-economic status)? Things to be considered: How are you going to fill the gaps in knowledge? 9

10 Do you need: more data; the data you have to be disaggregated; some research carried out or do you need to consult interested parties? Who should/will you ask? Who should/will collect the information/data? What is the best way to indicate to internal and external colleagues about gaps in information and data? Evidence You should remember that you will need to record details of the evidence that you have collected and how this collection has been done. You will also need to record details of who has been consulted and how you have involved equality groups. Step Five Relevance and impact Based on the work you have done - rate the level of relevance of your policy for the equalities agenda and rate the level of impact in respect of the intervention. You should now have enough information to decide whether or not there is an impact, for any/all of the equality groups and what that level of impact might be. You will now need to decide whether the impact is high, medium or low for any of the strands. Step Six Will you be making any changes to your policy? If your policy is likely to have an adverse impact on a group of people, the presumption should be that the policy should be changed or amended to lessen or remove this adverse impact. However, when considering making changes to policies the actions taken should be proportionate. It may not be practical or cost effective to make significant changes that will result in minor effects on outcomes for certain groups of people. However, you will need to be able to justify not taking action if potentially unfair outcomes have been identified through the EIA process. It may be possible to make a change that may remove a barrier or have a lasting effect on one or all of the equality groups. It will also be essential to avoid unlawful discrimination. You should also consider if you do make any changes whether it will have any resource implications, i.e. will it cost more or should your resources be focussed on ensuring that your policy delivers effectively across different groups? If changes are going to be made, you should also consider who is required or responsible for making those changes and set out a clear timetable for when the changes will be made. Step Seven Do you need to carry out further assessment work? 10

11 Further assessment work should be undertaken if more detailed investigation and analysis is required. There will be some policies where, as a result of undertaking this equality impact assessment process, that you decide further impact assessment work is necessary. This work may not be necessary for all equality groups, depending, on the nature and focus of the policy in question and the information available. Further impact assessment work could include: Collecting further data, Commissioning research and analysis Considering alternative ways to collect information Consulting further with people affected by the policy or service Step Eight Equality within the systems for monitoring progress? It is important to establish monitoring and evaluation processes to periodically assess if and how it is affecting the diverse needs of the target audience - in case there is any unexpected adverse affect or unintentional discrimination. The key to evaluating policy is good management of information. This can be through data collection and/or research but should include engaging with the appropriate people from different groups or communities. Engagement will give you indicators that will enable you to assess how far your policy, activity or programme is achieving the desired outcomes. This information may be collected as part of your ongoing monitoring, or may be a separate qualitative exercise. It will be important to clearly distinguish between evaluation of the process and evaluation of the policy/activity or function itself. At this step of the assessment you should consider how you intend to monitor and evaluate to ensure there are no unfair outcomes of the policy on equality groups. It may be helpful to liaise with colleagues in Research and Marketing to consider how you will carry out the monitoring or evaluation. Step Nine: Full EIA and Sign off A copy of the full EIA and sign off should then be sent to the Senior Officer for Equality for, who will return the sign off to the project board. Satisfactory EIAs will be published on the website. Where there is no need for a full EIA initial screenings should be sent to the Senior Officer for Equality. 11

12 Equality Impact Assessment Step 1: Define the aims of the policy Title of programme, policy, function or activity Department Lead officer Authorisation (Head of service or Director) Date: What is the purpose of the policy (or purpose of changes to be made to the policy)? Who is affected by the policy, or who is intended to benefit from the proposed policy and how? How has the policy been, or will be put into practice, and who is or will be responsible for delivering it? How does the policy fit into Sport Wales s wider or related policy initiatives? What is the timeframe for the policy? Have resources (i.e. financial/staff time) been allocated? 12

13 Step 2: What kind of information or evidence do you have about the diverse needs and/or experiences of equality groups? (Evidence can come from data, statistical sources, research, literature reviews, evaluation, focus groups or consultation) Do you have information on: Age Yes No Disability Yes No Gender Yes No Lesbian, Gay, Bisexual & Transgender Yes No Race Yes No Religion and Belief Yes No Socio-economic status Yes No If you do have equality information indicate where it was gathered from: Age Evidence Consultation Disability Evidence Consultation/Involvement Gender Evidence Consultation Lesbian, Gay, Bisexual & Transgender Evidence Consultation Race Evidence Consultation Religion and Belief Evidence Consultation Socio-economic status Evidence Consultation 13

14 Step 3: What does the information you have tell you about how this policy or programme might impact positively or negatively on equality groups? Age Disability Positive Negative Neutral Justification: (Details of research, evidence, consultation to support your answer) Gender Lesbian,Gay, Bisexual & Transgender Race Religion Belief and Socioeconomic status 14

15 Step 4: Do you have enough information to help you understand the diverse needs and/or experiences of your target audience? If not, what else do you need to know? Do you have enough information to proceed? Age Yes No What else do you need to know? Disability Gender Lesbian, bisexual, transgender gay, Race Religion and Belief Socio-economic status 15

16 Step 5: Based on the work you have done - rate the level of relevance of your policy/activity or programme for the equality strands and rate the impact level of the policy/activity or programme. Tick one box for each strand Relevance Age Disability Gender LGBT Religion belief High Medium Low Unknown and Race Socio-economic status Impact Age Disability Gender LGBT Religion and belief High Race Socio-economic status Medium Unknown 16

17 Step 6: Will you be making any changes to your policy? Are there any changes to be made to improve the results for particular groups? Age Yes No Disability Yes No Gender Yes No Lesbian, Gay, Bisexual & Transgender Yes No Race Yes No Religion and Belief Yes No Socio-economic status Yes No Please set out: What actions you will take Roles and responsibilities. At what point in the project management process will the actions be addressed? Are there resource implications in terms of time, people and financial allocations? How does this address the issues identified in the screening or assessment? 17

18 Step Seven: Is further impact assessment required? Please circle: Yes / No When will a further impact assessment be conducted? If you have answered yes please explain why If you have answered no but have identified a high impact on policy please explain your decision Step Eight: Please explain how you will monitor and evaluate impact as part of your monitoring systems. Please explain how monitoring will be undertaken, when it will take place and who is responsible for undertaking it. For example, Which KPIs will be monitored? What equality strands will be monitored? What processes and criteria will be monitored for change? 18

19 Step 9: sign off A copy of the full EIA and sign off should then be sent to the Senior Officer for Equality for, who will return the sign off to the project board. Satisfactory EIAs will be published on the website. Where there is no need for a full EIA initial screenings should be sent to the Senior Officer for Equality. Officer responsible for conducting EIA: Date: Name of policy: Summary of policy: Key issues identified during Equality Impact Assessment: Key actions to be taken as a result of the Equality Impact Assessment: Date of further assessment if required: To be completed by the Senior Officer for Equality. Proceed Don t Proceed Don t Proceed make changes Proceed with recommendations Recommendations: Name: Date: 19