Equality Impact Assessment Form Part 1: Screening Name of Strategy/Policy/Project/Function: Completing Officer’s Name: Completing Officer’s Telephone Number: Date Completed: Interim Tenancy Strategy Ray Langley 01737 276316 Lynne Kelly 01737 276363 Esther Lear 01737 276323 Above 10 March 2012 Section One: Identify Your Aims and Objectives The purpose of an Equality Impact Assessment is to improve the work of the Council by making sure that we promote equality and do not discriminate. This method is used to ensure that individuals and teams consider the likely impact of their work on residents and take action to improve strategies, procedures, projects and functions where necessary. What is the main purpose of this strategy? The Interim Tenancy strategy was drafted to provide guidance to Registered Providers of social housing (and other providers of social housing who are not Registered Providers) operating in the Reigate & Banstead local authority area with the overall aim of keeping housing affordable for those in housing need. List the main activities & objectives or main policy areas of this strategy The Interim Tenancy Strategy seeks to: ensure that affordable housing meets locally identifiable housing need provide guidance and direction to Registered Provider partners regarding implementation of the new higher rent levels under the Affordable Rent programme indicate to existing and prospective tenants what they can expect from an Affordable Rent tenancy. The tenancy strategy provides guidance for Registered Providers, who are required to publish their own equality and diversity strategy and to assess their own policies and procedures for potential impact on different individuals and groups. The tenancy strategy deals specifically with length of tenancy and affordability of rents; it does not aim to give advice to Registered Providers on wider equality and diversity issues. Page 1 of 7 Who are the main beneficiaries of this strategy? (1) Registered Providers/other providers of social housing (2) Applicants on the Council’s Housing Register (3) Current tenants of social housing seeking a transfer (2) and (3) above includes all protected characteristics under the Equality Act 2010 and the Interim Tenancy Strategy refers specifically to the needs of the elderly, households with children, applicants and tenants with disabilities including mental health problems. In what way are the main beneficiaries affected by this strategy? This strategy provides advice to Registered Providers on the Council’s position regarding rent levels and fixed term tenancies. The introduction under government policy of shorter tenancies (rather than lifetime tenancies) and higher rent levels may have an adverse impact on some groups. This strategy seeks to mitigate the impact of government changes and to ensure that social housing remains affordable, offers security for people who most need it and frees up accommodation that is no longer needed enabling it to be allocated to households with a greater need. Section Two: Consider Data and Research Exploring available data and conducting research will help to give an indication as to what impact the strategy will have on equality and diversity. Where data is limited or unavailable, managers should identify this as a limitation and identify ways to overcome this. This may include contacting specialist or other external organisations, or by conducting further research of existing regional and national data. What data is available to help direct the EIA? Evidence of the housing need of social housing applicants from our Housing Register (recorded in the Housing Strategy Statistical Appendix) Data about broader housing need in the borough collated through the Strategic Housing Market Assessment have informed the approach taken in the Interim Tenancy Strategy. Responses from an initial consultation with Registered Providers and partner agencies undertaken in February/March 2012. The data in our Housing Register database gives us some equality information about social housing tenants and applicants, however as identified in the Housing Register & Nominations Policy EIA and the Housing Options EIA, we need to improve the equality data we collect in order to have a fuller picture of housing need in the borough. Page 2 of 7 Are there any gaps in data that may require further research or consultation? The initial consultation on the Draft Interim Tenancy Strategy in spring 2012 was with Registered Providers, to gain initial feedback, rather than with social housing tenants and applicants. This means that we do not yet have an insight into tenants’ and applicants’ views on our Interim Tenancy Strategy. A second consultation with a wider range of stakeholders, including social housing tenants and applicants on the Housing Register will be carried out in autumn 2012, after which this Equality Impact Assessment will be revised. As identified in the Housing Register & Nominations Policy EIA and the Housing Options EIA, we need to improve the equality data we collect in order to have a fuller picture of housing need in the borough. Extending the categories of equality data collected by the Housing Service is an objective of our Function Plan for the year 2012-13. Section Three: Assess The Impact on Equality Target Groups Assess where you think the strategy could have a negative impact on any of the equality target groups i.e. where it could disadvantage them. Also consider where the strategy could have a positive impact or could contribute to promoting equality, equal opportunities or improving relations with equality target groups. Consider the following: Publicity, including design, distribution and accessible communications issues Physical access Location, geography Poverty, deprivation and social exclusion issues Employment Safety Direct discrimination: does the strategy intentionally exclude a particular equality group? If so, is this exclusion justified? Are the strategy and its outcomes likely to be equally accessed by all (are there barriers that might inhibit access to the service for some people)? Lack of data may make completing this section difficult, but is not be a reason to halt the process. Please continue to complete this form. Completing the table below will predict the likely impact on the target groups. You are not required to complete each box, only those that are relevant. Relevant boxes are those where there is a disproportionate or greater impact either way. Positive Neutral Impact Age Negative Impact Older people Low High Younger Low High Reason The tenancy strategy aims to ensure that social housing under Page 3 of 7 people & children Physical Low High Disability Sensory Low High Long-term health impairment includes mental health problems, asthma, heart conditions, chronic fatigue etc Learning Low High Long-term Health Impairment Low High Women Low High Men Low High Low High Gender Gender Trans-men reassignment and -women Marriage and civil partnership People who are married or in a civil partnership Low High Pregnancy and maternity Mothers or women who are pregnant Low High Asian Low High Black Low High Mixed race Low High White Low High Chinese Low High Other racial or ethnic groups (specify) Low High Race These categories are those used in the 2001 census the new govt regime is used as efficiently as possible to meet the needs of social housing applicants at different stages of their lives. The tenancy strategy aims to ensure that applicants with physical disabilities, learning disabilities, sensory impairments, long term ill health, or mental health problems are granted tenancies of a length which is appropriate to their support needs. The tenancy strategy exists as guidance for Registered Providers, who have their own equality and diversity strategies. It does not deal with issues of gender, gender identity or marriage/civil partnership status. The tenancy strategy aims to ensure that families with children are granted tenancies of an appropriate length to enable their children to grow up in a stable environment. The tenancy strategy exists as guidance on tenancy length and affordable rents for Registered Providers, who have their own equality and diversity strategies. It does not attempt to deal with issues of race or nationality, however language and accessibility issues will be taken into account when designing the second phase Page 4 of 7 Religion or belief Consider faith groups individually and collectively Sexual orientation Faith groups Low High Heterosexuals, lesbians, gay men and bisexuals Low High consultation with service users. The tenancy strategy exists as guidance on tenancy length and affordable rents for Registered Providers, who have their own equality and diversity strategies. Issues of tenancy length and affordability of rents are not considered to impact differently upon different religious groups, however the second phase of our consultation will give us more information on this. The tenancy strategy exists as guidance on tenancy length and affordable rents for Registered Providers, who have their own equality and diversity strategies. Issues of tenancy length and affordability of rents are not considered to impact differently upon different people of different sexual orientations, however the second phase of our consultation will give us more information on this. If you have indicated that there is a potential negative impact on any target group, are these Intentional and/or of a High Impact? Intended? i.e. can be justified in terms of legislation e.g. concessionary fares older people Yes No High Impact? i.e. it is or may be discriminatory against one or more groups Yes No Page 5 of 7 Is the negative impact NOT INTENDED and/or of HIGH IMPACT? If YES, a full assessment is required. Please complete the Equality Impact Assessment Form Part 2: Full Assessment. If NO, complete the rest of this form. Do not ignore low impacts- these could help you to develop services in the future. Section Four: Improvement Planning It is important to consider any influence that the strategy is having, or could potentially have, on the individual strands of equality. The strategy should be examined for its effectiveness in: Promoting equality Eliminating discrimination Achieving equality Could negative impacts be removed or minimised? Could positive impacts be improved and if so, how? Analysis must be undertaken with the strategic objectives of the Council in mind and the questions should reflect legal requirements, the emerging Local Development Framework and population needs. Use the table below to record how you could minimise or remove any low negative impact or improve the positive impact of the strategy. Issue Feedback from the consultation on the Draft Interim Tenancy Strategy showed that more detail was needed on support for vulnerable people. Action The Draft Interim Tenancy Strategy was updated to better reflect the needs of different types of households, for example, those with physical disabilities, those with mental health problems, older people and families with children. We do not hold sufficient data on housing Extend collection of data during 2012-2013 as register applicants and social housing tenants to identified as an action in the Housing Function be able to make a reliable assessment of the Plan. impact of our policies and strategies on all applicants. If there is no evidence that the strategy promotes equality, equal opportunities or improved relations, could it be adapted so that it does? If so, how? The strategy exists to promote equality, by ensuring that different households are granted tenancy lengths appropriate to their needs, to keep social housing affordable and to minimise potential negative impact of the new government framework for delivering affordable housing. Page 6 of 7 Section Five: Monitoring and Reviewing What data do you have that monitors the impact of the strategy on protected groups? The Housing team is monitoring local Registered Providers’ tenancy policies as they are developed to check that these policies have regard to the Council’s views. A second consultation which will seek the views of social housing tenants and applicants on the Housing Register on this Interim Tenancy Strategy will be carried out in autumn 2012, after which this Equality Impact Assessment will be revised. As identified in the Housing Register & Nominations Policy EIA and the Housing Options EIA, we need to improve the equality data we collect in order to have a fuller picture of housing need in the borough. Improving the equality data collected by the Housing Service is an objective of our Function Plan for the year 2012-13. How is this data used? The Housing team will continue to engage with Registered Providers as their tenancy policies are developed, with the aim of ensuring that tenancies are of an appropriate length and that social housing in the borough remains affordable to meet local housing need. Equality data collected in the coming year will also be used to gain insight into our Housing Register and Housing Options services and how they might be improved (see separate equality impact assessments) If there is no data, explain how you intend to continue monitoring the impact of this strategy: Please send a copy of the completed form to the Equalities Steering Group, via Esther Lear, at [email protected] Page 7 of 7
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