HDC Initial Equality Impact Assessment Form (EIA1)
Service Area/Section
Revenues and Benefits Service
Name of policy or
function to be assessed
Housing/Council Tax
Overpayments Policy
1. Briefly describe the aims, objective
or purpose of the policy, or service
function.
2. Are there any associated objectives
of the policy/function?
3. Who is intended to benefit from this
policy and in what way?
4. What outcomes are wanted from this
policy/function and for whom?
5. How do these outcomes meet or
hinder other policies, values, or
objectives of HDC?
6. What factors/forces could
contribute/detract from the intended
outcomes?
Persons undertaking the assessment
(please also state name of contact officer)
Date of
assessment
Leigh Butler
New or existing policy
30th September
2010
New Policy
To notify customers of overpayments of Housing and Council Tax Benefit, and to recover overpayments in
accordance with legislation.
▪ Minimising the loss to public funds
▪ Maximising revenue to the Authority with regard to customers’ ability to pay
▪ Adherence to the Corporate Debt Policy
▪ Harborough District Council
▪ Harborough residents by protecting public funds
▪ Prompt recovery of overpayments
▪ Revenue to the Council
▪ Deterrent to Fraud
▪ Backlog of work causing late notifications therefore delaying recovery action – detracts from the outcome of
the service
Contributes to:
▪ Ensuring a pro-active approach
▪ Full compliance with legislation
▪ Robust policies and procedures
▪ Effective and regular training
7. Who are the main
stakeholders in relation
to this policy?
9. Are there any concerns that the policy/function could
have a differential impact on racial groups?

Y
Leigh Butler, Revenues and Benefits
Manager
As with other Benefit and Taxation functions, for non-English speaking
customers, there could be an access problem. The notifications for
overpayments are only available in English: this has potential to impact on
non-English speaking groups
What existing evidence (either presumed or otherwise) do you have
for this?
10. Are there any concerns that the policy/function could
have a differential impact due to gender?

8. Who implements the
policy/function and is
responsible for the
policy?
HB/CTB customers
DWP
Landlords
CAB and Welfare Right Groups
Landlord Forums
N
What existing evidence (either presumed or otherwise) do you have
for this?
The overpayment policy has no differential effect on gender. Both males and
females have equal access to Benefits. Application forms ask for an individual
title, so gender is usually known, but the individual would be treated equally
regardless of this.
The overpayments recovery procedures advise to take into account various
criteria but gender, race and religion would not be considered.
11. Are there any concerns that the policy/function could
have a differential impact due to disability?

Y
What existing evidence (either presumed or otherwise) do you have
for this?
12. Are there any concerns that the policy/function could
have a differential impact due to sexual orientation?
N
In some circumstances it would be unreasonable to pursue a debt due to the
health/disabilities of an individual. The Authority aims for its recovery actions
not to cause further ill health or distress. However, there are some cases
where it may be necessary to suspend recovery action until an individual’s
circumstances improve. But each case is determined on individual merits and
is dependent on the customer’s situation.
Overpayments Policy
Since the introduction of the Civil Partnership Legislation in 2005, we can
recover from a civil partner, in the same way as a married couple or opposite
sex couple.
The legislation addresses inequalities.

What existing evidence (either presumed or otherwise) do you have
for this?
13. Are there any concerns that the policy/function could
have a differential impact due to age?

Y
What existing evidence (either presumed or otherwise) do you have
for this?
Benefit Application form
An individual’s age is one element that would be considered. Particularly with
regard to older people, it may be deemed unreasonable to recover an
overpayment. The overpayment policy does mention that decisions on
recovery should not cause unnecessary stress or contribute to ill health and
that decisions are mindful of individuals’ circumstances.
Overpayments Policy.
14. Are there any concerns that the policy/function could
have a differential impact due to religious belief?

What existing evidence (either presumed or otherwise) do you have
for this?
15. Are there any concerns that the policy/function could
have a differential impact due to people having
dependants/caring responsibilities?

N
Y
What existing evidence (either presumed or otherwise) do you have
for this?
16. Could any differential impact identified in 9-15 amount
to there being the potential for adverse impact in this
policy?
N
The process of recovering of an overpayment would not be affected or
determined by the religious beliefs of a customer.
None of the benefit forms ask for this information, the assessment is based on
financial circumstances.
Overpayments Policy
We would consider customers with dependents favourably, provided that they
have justifiable expenses. A debt could be suspended if the customer has
limited income that is likely to remain low for a considerable period of time.
Individual circumstances are considered when making payment arrangements
to avoid financial hardship for a customer and their family.
Overpayment recovery procedures
The differential impacts identified were of a positive nature and are in
accordance with legislation.
The policy/function does have a negative impact on non-english speaking
customers, due to information not being available in other languages. This is
the case for all Benefit and Taxation functions.
17. Can any adverse impact be justified on the grounds
of promoting equality of opportunity for one or more
groups or any other reason?
18. Should the policy proceed to a full impact
assessment?
Y
Yes – as above
N
The function satisfies all current legislative requirements
19. If no, are there any recommended changes required
to the policy to improve it around the equality
agenda?
This is a new policy
Additional
notes/guidance
(Policy Officer)
Signed (completing officer) ……
………………. Date 30 /09/2010
Signed (completing officer) ……………………………………………………. Date __/__/____
Signed (Head of Service) ……………………………………………………… Date __/__/____