Glasgow Kelvin College
Equality Impact Assessment
Attendance Management Policy and Procedure
Glasgow Kelvin College EQIA form [Version 2]
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Contents
Step 1 – Identification and Scope ........................................................................................................... 3
Step 2 – Research and Consultation ...................................................................................................... 5
Step 3 – Assessing the Impact ................................................................................................................ 7
Step 4 – Taking Action ............................................................................................................................ 9
Step 5 – Monitoring and Evaluation ....................................................................................................10
Step 6 – Approval ..................................................................................................................................10
Central Monitoring................................................................................................................................11
Appendix ..............................................................................................................................................12
Glasgow Kelvin College EQIA form [Version 2]
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Practitioners conducting assessment
Name
Designation
Date
Step 1 – Identification and Scope
Brief description of the decision, policy or practice being assessed
Policy which provides the overarching principles of the approach taken by the College to
managing attendance, supporting those with ill health, physical or mental, and a procedure for
ensuring reasonable adjustments are made at an early stage.
Aims of the decision, policy or practice?
To create a working environment and support facilities which promote and support health
and well-being which aims to take a supportive approach to employees who suffer ill
health and provide assistance and reasonable adjustments to employees with a health
condition or disability at an early stage. The policy and procedure provides managers with
clear guidelines on how to manage sickness absence fairly, it demonstrates to employees
who are absent that they will be treated equitable, and to all employees that staff absence
is being managed in a consistent manner.
The document aims to:
 apply a consistent and fair approach across the College in the management of
sickness absence;
 provide employees and managers with guidelines defining acceptable and
unacceptable attendance and procedures to deal with unacceptable or high levels
of absence;
 promote the health, safety and wellbeing of all employees;
 provide support and advice for those unable to or finding it difficult to attend work;
 provide managers with approaches to effectively manage attendance;
 provide guidance and the need for reasonable adjustments, redeployment,
rehabilitation and retraining to support an employee’s return to work;
 allows flexibility in considering action based on individual circumstances;
 place the focus of attendance discussion on what the employee can do rather than
what they cannot, enabling them to remain at work wherever possible; and
 a process for dealing with employees with unacceptable levels of non-attendance.
Glasgow Kelvin College EQIA form [Version 2]
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Who is affected by the decision, policy or practice?
No
Students
Yes
Staff
No
Members of the public
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Step 2 – Research and Consultation
Outline evidence / research
Equality Act 2010 - legislation;
EHRC Code of Practice on Employment;
Equality Act 2010: Duty on employer to make reasonable adjustments for their staff;
ACAS - Absence Management; Managing Staff Absence and Advice and Guidance on
Disability Discrimination;
CIPD – Absence Management Survey Reports and recommended best practice;
MIND/CIPD -Managing and Supporting Mental Health at Work:
Case law and case studies;
NHS - Supporting Staff who are experiencing mental health problems;
TUC -Sickness Absence and Disability Discrimination;
HSE - Working together to prevent sickness absence becoming job loss; Absence
Management Toolkit; and Managing Sickness Absence and Return to Work; and
XpertHR.
What consultation has been undertaken on this policy or practices, including
consultation with those affected?
Trade Union representatives - Unison and Unison Solicitors;
Trade Union representatives – EIS/FELA and Full time Regional Officer;
Managers;
Staff (particularly those with a disability);
College Legal Advisors;
Health and Safety Manager; and
Occupational Health
Glasgow Kelvin College EQIA form [Version 2]
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Research Key Findings
The drafting of the policy considered a number of key documents which outlined
legislation and best practice. A framework document was produced based on the
requirements of the College, the legislation, the documents outlined above and
best practices with the aim of creating an environment and a culture in which
sickness absence is managed consistently and fairly where staff are supported
and reasonable adjustments are made. The management of absence will
potentially have a higher negative impact on particular protected characteristics
including disability, transgender, pregnancy and maternity and age. The policy
and procedure was developed with the aim of mitigating any negative impact that
may occur.
The framework policy was amended after a number of meetings with Trade Union
representatives, staff (including those with a disability) and key personnel. The
policy document was considered by the College’s legal advisors and the
recommendations put forward were incorporated into the document. The Policy
will be evaluated on an annual basis based on the monitoring and evaluation
processes. The Policy will be reviewed and revised every two years or earlier if
required as a necessity through legislative or operational requirements.
The policy clearly supports staff with a long-term health problem or disability. It
promotes disability equality and ensures that the needs of staff with or who
develop a disability during their employment are supported and provided with
reasonable adjustments where appropriate.
During the consultation period a number of changes where made the policy and
procedure, in summary these included:



special consideration of sickness absence relating to disability, long-term
illness, pregnancy or gender reassignment when trigger points for formal
interviews reached;
special leave for appointments or treatment for disability, long-term illness
or gender reassignment; and
a clearer emphasis on supporting those with a disability.
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Is there any evidence that different groups have, or may have, different
needs, experiences and priorities in relation to this policy or practice?
Protected Characteristic
Yes
Neutral
Potentially
Age
x
Disability
x
Gender
Not
known
x
Gender reassignment
x
Marriage and Civil partnership
x
Pregnancy and Maternity
x
Racial group
x
Religion or belief
x
Sexual orientation
x
x
Step 3 – Assessing the Impact
What impact could the proposal have on people who share protected characteristics
(positive, negative and/or neutral?) Please provide details below.
Protected Characteristic
Likely Impact
Age
The policy applies to all regardless of age and classifies
characteristics protected from unlawful discrimination and gives
examples of types of harassment that are unacceptable.
Older employees may have a greater potential for the impact of ill
health. The policy provides for reasonable adjustments and a
process for early retirement on the grounds of ill health where
appropriate.
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Protected Characteristic
Likely Impact
Disability
The policy applies to all regardless of disability and classifies
characteristics protected from unlawful discrimination and gives
examples of types of harassment that are unacceptable.. Policy is
available on intranet and therefore available in different fonts, text
size and through assisted technology.
This policy has a positive impact as it takes into account the
Equality Act 2010, which makes it unlawful for employers to
discriminate against current or prospective employees with
disabilities or because of a reason relating to their disability. The
College has a legal obligation to look at reasonable adjustments for
employees who have a disability to enable them to fulfil their
roe/potential role. Reasonable adjustments will be considered and
HR will seek specialist advice and support on reasonable
adjustments from external providers such as Occupational Health or
the Department of Work and Pensions Access to Work Scheme. A
higher level of absence will be acceptable where there are no
significant operational difficulties. Time off for treatment or
appointments will be provided through the Family Friendly and
Flexible Working Policy.
The policy provides for reasonable adjustments and a process for
early retirement on the grounds of ill health where appropriate.
Gender
The policy applies to all regardless of gender and classifies
characteristics protected from unlawful discrimination and gives
examples of types of harassment that are unacceptable.
Gender reassignment
The policy applies to all regardless of gender reassignment and
classifies characteristics protected from unlawful discrimination and
gives examples of types of harassment that are unacceptable.
This Policy has a positive impact as a transsexual person will be
fully supported during the process and a higher level of absence will
be acceptable where there are no significant operational difficulties.
Time off for appointments and counselling will be provided through
the Family Friendly and Flexible Working Policy.
Marriage and Civil
partnership
Pregnancy and Maternity
The policy applies to all regardless of marital status and classifies
characteristics protected from unlawful discrimination and gives
examples of types of harassment that are unacceptable.
The policy applies to all regardless if the woman is pregnant or on
maternity leave and classifies characteristics protected from
unlawful discrimination and gives examples of types.
The policy will have a positive impact as it takes into account
pregnancy and a higher level of sickness absence will be accepted
during this period. Time off for appointments will be provided
through the Family Friendly and Flexible Working Policy.
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Protected Characteristic
Likely Impact
Racial group
The policy applies to all regardless of race and classifies
characteristics protected from unlawful discrimination and gives
examples of types of harassment that are unacceptable.
Religion or belief
The policy applies to all regardless of religion or belief and classifies
characteristics protected from unlawful discrimination and gives
examples of types of harassment that are unacceptable.
Sexual orientation
The policy applies to all regardless of sexual orientation and
classifies characteristics protected from unlawful discrimination and
gives examples of types of harassment that are unacceptable.
Step 4 – Taking Action
Detail the actions you would take to remove or minimise any actual or
potential negative impacts identified, and to build positive impacts.
Policy issued to all existing staff to raise awareness.
Policy issued to all new staff as part of induction process.
Policy available on the intranet and internet.
Training for managers.
Briefings for staff.
Monitoring and reporting of absence to the Board of Management and HR Committee.
Employee Assistance Programme – external provider in place.
Occupational Health advice and Support.
Promotion activities for early disclosure of disability or ill health.
Healthy Working Lives.
Individual Stress Risk Assessment for absence where individuals feel work in having a
negative impact.
Annual HSE Stress Survey
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Step 5 – Monitoring and Evaluation
Identify how this policy will be monitored and any areas of concern
reported.
Monitoring and evaluation:
•
•
•
•
•
•
•
•
HR computerised information system records and reports absence;
Monthly absence reports to managers;
Quarterly reports to the Board of Management and HR Committee;
Benchmarking of absence percentages against CIPD Annual Absence
Survey and other FE Colleges;
informal discussions with staff and managers;
formal consultation with staff (in particular those with a disability or longterm health condition),managers and Trade Union representatives;
HSE stress survey;
Annual Health and Safety Report to the Board of Management;
Please present your EIA with recommendations for endorsement. All EIAs will be
published on the Portal and added to the current record of EIAs.
Step 6 – Approval
Identify outcome
A. Proceed –
• no potential identified for discrimination or adverse impact,
and:
• all opportunities to advance equality have been taken.
Yes
B. Proceed with adjustments to:
• remove barriers identified or
• better advance equality.
C. Stop and rethink as actual or potential unlawful discrimination has
been identified.
Approved
Yes/No
*Not Approved and Requires Further Information
*Please add Comments
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Person(s) responsible
Name
Designation
Doreen Shiels
Director of Human
Date
Resources
Signed ………………………………………………
Date ……………
Signed ………………………………………………
Date ……………
Central Monitoring
Once your EIA is complete:
1. add it to the EIA monitor on the Equalities Section of the Intranet
2. In Col A. Insert Title and Hyperlink Doc
NB: Finalisation of central monitoring & identification of compound impact will be
undertaken within Equalities Management.
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Appendix
Equality Act General Duty requires colleges to have due regard to the need to:
1.
a)
b)
c)
d)
Eliminate
discrimination,
harassment,
victimization; or
any other prohibited conduct
2. Advance equality of opportunity by
a) removing or minimising disadvantage
b) meeting the needs of particular groups that are different from the needs of
others
c) encouraging participation in public life
3. Foster good relations – tackle prejudice, promote understanding
Protected Characteristics:
1.
2.
3.
4.
5.
6.
7.
8.
9.
Age
Disability
Gender Reassignment
Marriage And Civil Partnership (applies only in relation to (1a) discrimination
in employment, not to learners)
Pregnancy And Maternity
Race
Religion Or Belief
Sex/ Gender
Sexual Orientation.
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