now - Reigate and Banstead

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.
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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.
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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
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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
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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
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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.
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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]
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