Is this the end of Equality Impact
Assessment?
Maybe Wave-length can offer your
organisation a different approach
A personal viewpoint from Ann Johnson of Wave-length CIC – March 2013
Back in November 2012 David Cameron stated that Equality Impact Assessments would be
scrapped and that organisations would simply do the right thing to ensure there was no
discrimination.
Women’s group, Fawcett Society, attacked this approach the next day saying this would
setback women’s rights in the workplace, stating that this move was irresponsible and
retrograde.
Equality South West were another group publicly against the decision stating that “Equality
impact assessments have made a real and positive difference to people’s lives by making
sure local authorities have to think twice about how their policies will affect different sections
of society’
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But what exactly did David Cameron say and is it actually the end of Equality Impact
Assessments as a result?
"Consultations, impact assessments, audits, reviews, stakeholder management,
securing professional buy-in, complying with EU procurement rules, assessing sector
feedback … this is not how we became one of the most powerful, prosperous nations on
Earth. It's not how you get things done. As someone once said, if Christopher Columbus had
an advisory committee he would probably still be stuck in the dock. So I am determined to
change this."
Cameron said the Equality Act was "not a bad piece of legislation", it was just the
way it had been interpreted – with equality impact assessments on every policy, "way
beyond" what was required, he said.
He went on to say that "smart people in Whitehall" would consider equality issues
while making policies.
"Let me be very clear. I care about making sure that government policy never
marginalises or discriminates," he said. "I care about making sure we treat people equally.
But let's have the courage to say it – caring about these things does not have to mean
churning out reams of bureaucratic nonsense. We have smart people in Whitehall who
consider equalities issues while they're making the policy. We don't need all this extra tickbox stuff. So I can tell you today, we are calling time on equality impact assessments. You
no longer have to do them if these issues have been properly
considered."
So does this mean that there is no requirement to complete an
assessment? And if the answer is yes then is there an alternative?
If you now look again at the last line used by David Cameron
above you will that he said ‘You no longer have to do them if these
issues have been properly addressed’ so what does this suggest?
And how do you know that things have been properly addressed
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without having a process? It seems to me that whilst the Equality Impact Assessment Form
as we know it might not be an absolute tool there is still a requirement for public sector and
ALMO’s (Arm’s Length Management Organisations) to comply with the duties stated in the
Equality Duty.
In fact at Wave-length we go further and suggest to private sector
organisations that having an approach similar to the Equality Impact Assessment might help
them reduce the risk of discrimination in service delivery or employment.
So how can organisations be re-assured that such a requirement to have a due regard to the
Equality Duty is happening across their organisation? Should they just train staff on the duty
and then hope? Wait for someone to complain? Or at worst spend much valued funds only
to find that someone cannot access a service and claim discrimination. This might be a
financially costly approach and one that fails to truly provide equality of opportunity across
the community. For example recently I used a public toilet, whilst transferring back to my
wheelchair I used the grab rail for support, to my shock the whole rail came away from the
wall, luckily I was strong enough and physically able to grab something else quickly. This
incident left me completely shook up and on reflection I wondered what might have
happened had this been an elderly person unable to re balance and perhaps as a result hit
their head on the sink going down to the ground? It would be interesting to see if when
reviewing maintenance checks of the building an Equality Impact Assessment or even
Health and Safety Risk Assessment might have picked up that helping to avoid such an
incident would be best approach and that a decision would be made to test grab rails with an
agreed load bearing method would be an essential routine activity. I am sure the alternative
of just waiting until something happened would not have been the collective approach.
Whilst I am not advocating that we should return to bureaucratic methods of ticking boxes,
reams of paper and endless consultation there seems to be the need for something that
might encourage people who write policies, review policies or design new buildings or
working practices to stop, consider and deliver on an accessible service.
Wave-length has much evidence of organisations continuing to
work with Equality Impact Assessments for many reasons, perhaps
they have spent much time and money training managers already
to use them and therefore not wanting to once again change; they
feel they provide the security and assurance needed to provide the
right service either to the public their staff or to external regulatory
boards or they have been advised they are the best approach to
ensure compliance with the Equality Duty.
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But for those looking for change or simplification how do we meet this challenge? I think the
easiest might be to simplify the process and further mainstream where possible. So for
instance it might be easy where policies are routinely reviewed after an agreed period that
as part of the process the manager considers equality matters within them. Alternatively
reviewing equality impact forms part of a Health and Safety Risk Assessment by way of
bringing the two together.
This approach might mean amending existing policy review
guidance or adding a new short version checklist to current working practices.
Wave-length CIC has been looking at how such forms might be adapted, in fact we were
recently challenged to provide an alternative Equality Impact Assessment replacement form
and for it to be no more than one page long although we did seek agreement to provide a
brief flowchart on another page to accompany the form.
Below; we share the approach offered, you will note it removes the need for a two level
process and most importantly it seeks to soften the name of the assessments, choosing in
this case to use Equality Review Form, it is always interesting how just the name of a
working practice can mean that you put off the task.
We would be of course in agreement for you to adapt this approach to meet your own needs,
ensuring that it meets with your own internal regulatory controls and any external bodies that
might govern your sector.
However should this approach not be best suited for your
organisation you should perhaps take time to review your current practices is in order for you
continue to provide Equality Assurance that helps to ensure and evidence compliance
should you ever be challenged to provide it?
Wave-length
CIC
works
to
help
remove
inequalities we do this by working with those that
face challenges in their lives and those seeking to
reduce or eliminate such challenges, we would be
delighted to talk to you at any time on how this
might be achieved in your organisation.
We would also welcome your feedback to Wavelength’s Forum if you found the template below
useful to your organisation or in fact you have
designed a different approach and wish to share it
with others.
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Template for an EQUALITY IMPACT REVIEW FORM
Title of Document/function
Type of document/function: policy; procedure; protocol;
guideline; practice; project; strategy; other
Status of Document/work practice; Proposed; Draft; Existing;
other
Name of Person completing the Equality Impact Review Form
Please give details of the goals or purpose of this
document/work practice. Why we need to have this
document/work practice?
Impact review
In reviewing this document / work practice have you identified either a potential positive or negative impact on
any of the protective characteristics* or other disadvantaged groups? Yes/No
Have you acquired support or information in understanding the
impact/or ways of mitigating the impact please detail the
support sought?
If you felt there to be no requirement to seek additional support
please explain reasons for this
If an impact has been identified please detail
What actions are you taking to mitigate or remove the impact?
How do you intend to communicate and consult in relation to
the proposed actions for improvement, risk or changes to the
policy/function? Provide some direction here for the person
completing the form, who they might speak to
How will you monitor the outcomes of your actions so as to
ensure success? Again provide some direction perhaps on
how to gain data, or using satisfaction reports, client
responses etc.
Review date:
Signature of Manager completing form:
Date completed:
A copy of the Equality Review Form should be (explain here what happens next)
*Protective Characteristics: Religion, Race, Age, Gender, Sexual Orientation, Disability, Transgender,
Marriage and Civil Partnership, Pregnancy and Maternity.
Disadvantage groups will change according to the policy and would be best described as simply any
identified group disadvantaged by this policy, this might include those who work part-time, those
without internet, those who rely on rural transport etc.
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Equality Review Process
At any new, proposed change or review of a
document or function you need to complete
a form
Consider the Impact of the document
or function on those with protective
characteristics or disadvantaged
groups
If you need support in making this
decision you might contact the
Equality and Diversity Group,
Client Groups, HR or those that the
document/function impacts upon
Consider other
evidence, documents,
complaints, areas of
improvements etc
If no impact identified
then sign off form and
file as instructed
If impact identified
consider how it can be
removed or mitigated
Enter a date to further
reveiw the
document/function
Detail how you will
monitor any impact,
how you will
communicate any
change
Sign off the form and
file as instructed
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