University of Portsmouth Equality Impact Assessment Handbook
Ten Things Everyone Should Know About Equality Impact Assessment
- All public bodies have to do it.
- Its purpose is to eliminate unfair discrimination and improve equality of opportunity.
- It focuses on “equality target groups” based on race, disability, gender, age, sexual orientation and religion/belief.
- It has to involve members of the equality target groups.
- It means looking at all the University’s policies, practices, provisions and criteria to see which ones are relevant to its purpose.
- It means assessing the adverse and beneficial effects of relevant policies, practices, provisions and criteria.
- It means making changes that eliminate unfair discrimination and improve equality of opportunity.
- It means monitoring changes to see how effective they are.
- It is not difficult to do.
- It will make the University a better place.
3 © University of Portsmouth July 2007
University of Portsmouth Equality Impact Assessment Handbook
CONTENTS
SECTION PAGE
About This Handbook 7
About Equality Impact Assessment 8
How to Do Equality Impact Assessments 9
PRELIMINARY ASSESSMENT
Step 1 - Make a List of All Items 10
Step 2 - Identify Relevant Items 11
Step 3 - Prioritise Items 13
Step 4 - Plan for Action 14
FULL ASSESSMENT
Step 5 - Assess Impact 16
Step 6 - Propose Adjustments 18
Step 7 - Report Assessment and Proposals 20
Step 8 - Monitor the Effect of Change 21
Co-ordination and Involvement 22
APPENDICES
1 System Flowchart 24
2 Sample Report Forms 25
3 Guidance and Good Practice 30
4 Assessment Information and Benchmarks 33
5 Contact and Communication 37
5 © University of Portsmouth July 2007
University of Portsmouth Equality Impact Assessment Handbook
ABOUT THIS HANDBOOK
· It is designed to help the University to fulfil its statutory duty to carry out Equality Impact Assessments
· It has been written for the people who will carry out Equality Impact Assessments
· It should be read by all people involved in the Equality Impact Assessment process
· It refers to useful advice and resources
· It is based on official guidance and examples of practice
· It will be supplemented by further material as determined by developments in legislation and practice
· It was created by John Fielding and is maintained by the University’s Equality and Diversity Unit
· The main changes between the second edition and this third edition are in the Co-ordination and Involvement section. They mainly explain arrangements for publicity and inspection. There are consequential changes to the advice in the sample report forms in Appendix 2. Other minor changes update or improve the text.
· There is an electronic version that has navigation links to sections of the document and to publications and websites mentioned in the text (to download a copy, go to: www.port.ac.uk/departments/services/vice-chancellorsoffice/EqualityandDiversity/equalitimpactassessment/
ABOUT EQUALITY IMPACT ASSESSMENT
We all make impact assessments. We think about the effect of doing something. Sometimes we think about the effect on other people. If the effect is not what we intended, we usually think about doing things differently.
Equality Impact Assessments are not much different from our everyday impact assessments. For the University of Portsmouth, Equality Impact Assessment means:
· looking at what the University does and how it does it[1]
· considering how this affects, or could affect, “equality target groups” defined by race, disability, gender, age, sexual orientation and religion/belief
· trying to prevent unfair discrimination and promote equality of opportunity[2]
· fulfilling the requirements of equality law[3]
· using formal procedures
HOW TO DO EQUALITY IMPACT ASSESSMENTS
There is no prescribed method for doing Equality Impact Assessments. Several official organisations have produced guidance to try to help us to do them[4]. Some public bodies have already done them.
Official guidance stresses the importance of a formal, structured and documented process for Equality Impact Assessment. This is not just to make sure that it is done properly but so that it can be seen to have been done properly.
The main purpose of Equality Impact Assessment is to try to prevent unfair discrimination against, and promote equality of opportunity for, groups of people defined by race, disability, gender, age, sexual orientation and religion/belief[5].
There are eight steps in the Equality Impact Assessment process:
Step 1 Make a list of all policies, practices, provisions or criteria
Step 2 Identify relevant policies, practices, provisions or criteria
Step 3 Prioritise items
Step 4 Plan for action
Step 5 Assess impact
Step 6 Propose adjustments
Step 7 Report assessment and proposals
Step 8 Monitor the effect of adjustments
These steps are explained in the following sections.
New policies, practices, provisions and criteria should be assessed as part of their development process.
STEP 1 - MAKE A LIST OF ALL ITEMS
The aim of this step is to identify all policies, practices, provisions and criteria.
Start the Equality Impact Assessment process by preparing a list of all policies, practices, provisions and criteria, even those that seem irrelevant to the purpose of the assessment.
“A policy is any decision, principle, plan or set of procedures that influences and determines the way an institution carries out its business (externally or internally)” - e.g. student admissions policy, staff recruitment policy
“A practice is more informal than a policy and refers to a customary way of operation or behaviour, perhaps built up over a number of years. It can be identified through being routinely performed, locally, regardless of any official requirements in policy” - e.g. teaching methods, assessment schemes[6]
“A provision is an action which serves to provide for, or meet the requirements or particular needs of people” - e.g. library facilities, study space
“A criterion is the basis by which comparisons or judgements are made, often against particular reference points” - e.g. admissions and assessment criteria
From Conducting Impact Assessments for Equal Opportunities in Higher Education - A Guide to Good Practice, The Higher Education Funding Council for England (HEFCE)
There will be a hierarchy of lists based on the levels of organisation and responsibility in the University - corporate, faculty, department etc.
Step 1 Output
STEP 2 - IDENTIFY RELEVANT ITEMS
The aim of this step is to identify those policies, practices, provisions or criteria that are relevant to the purpose of Equality Impact Assessment.
It is not possible to be certain that a policy, practice, provision or criterion is relevant without asking members of the equality target groups (see page 22)
The following information will help to identify the relevance of each policy, practice, provision or criterion in the list prepared in Step 1:
- Its purpose[7]
- Who owns it (who created it or has the authority to change it)
- Who is expected to implement it
- Who is affected by it
- Any evidence that it actually or potentially affects members of one of the equality target groups in a different way to others[8].
- The extent to which it contributes to, or hinders, equality of opportunity or has the potential to do so[9]
- Its potential to contribute to the achievement of a specific duty in equality law (see footnote 2 on page 8)
The decision as to whether a policy, practice, provision or criterion is, or is not, relevant to Equality Impact Assessment should be made by its “owner”. This decision should take account of the information gathered under points 5, 6 and 7 above.
A policy, practice, provision or criterion is generally not relevant to Equality Impact Assessment if:
(a) there is no evidence that it affects or could affect members of one of the equality target groups in a different way to others and;
(b) it does not actually or potentially help or hinder equal opportunity and;
(c) it has no potential to contribute to achieving a specific equality law duty.
A policy might not be relevant but the practices, provisions or criteria that are used to implement it may be.
It is important to make a formal record of the reasons to support the decision that a policy, practice, provision or criterion is or is not relevant to Equality Impact Assessment[10].
Policies, practices, provisions or criteria that are not relevant to Equality Impact Assessment need not be considered further.
STEP 3 - PRIORITISE ITEMS
The purpose of this step is to help to make sure that each policy, practice, provision or criterion gets the attention it deserves.
The more significant a policy, practice, provision or criterion is for Equality Impact Assessment purposes, the more attention it should get. Prioritising them helps to do this. It will help in the next step of the Equality Impact Assessment process.
The priority of a policy, practice, provision or criterion cannot be calculated. It has to be judged.
The judgement of priority should be made by the “owner” of the policy, practice, provision or criterion [11]. Official guidance suggests they should be designated as high, medium or low priority. Prioritisation is relative, imprecise and subjective. It follows an assessment of the potential effect of one policy, practice, provision or criterion compared to that of another. This assessment should take account of:
· The number of people affected
· The significance of the effect
Clearly, a policy, practice, provision or criterion that could profoundly affect a large number of people should have higher priority than one that only slightly affects very few people. Many priority judgements will not be so easy.
Step 3 Output
STEP 4 - PLAN FOR ACTION
The aim of this step is to prepare a plan to guide the full Equality Impact Assessment process (Step 5).
The Equality Impact Assessment process is a cycle of activity. Official guidance recommends that:
· New policies, practices, provisions and criteria should be assessed as part of their development process, usually before they are introduced[12]
· Current policies, practices, provisions and criteria should be re-assessed periodically[13]
The Planning Period
The University has decided to follow the recommendation in official guidance that there should be a three-year Equality Impact Assessment cycle. Plans must cover a three-year period starting in 2006/07[14].
Planning Objectives
The plan should provide a timetable for the full Equality Impact Assessment process. It should say what outputs from the process will be produced by a specified calendar date.
Planning Priorities
Plans should clearly state what Equality Impact Assessment activity will be carried out in each of the three years. This will reflect the priorities determined in Step 3[15]. A logical arrangement would be:
Year 1 - Assess High Priority items
Year 2 - Assess Medium Priority items
Year 3 - Assess Low Priority items
Planning Resources
The plans should be based on an assessment of:
· The resources that might be needed to carry out the Equality Impact Assessment activity[16]
· The current availability of those resources
· The need for additional resources
Plan Responsibilities
The plan should be clear about who does what by when. As far as possible, responsibilities should be assigned to named people.
No-one knows for sure what effort and resources the Equality Impact Assessment process will require. The plans should help to cope with this uncertainty. They should help to direct effort and distribute resources. They should also help to re-direct effort and re-distribute resources to try to achieve the Equality Impact Assessment objectives.
Step 4 Output
STEP 5 - ASSESS IMPACT
The aim of this step is to assess the actual and potential impact of a policy, practice, provision or criterion on members of equality target groups.
Equality Impact Assessment looks for negative (adverse) effects and positive (beneficial) effects. Its ultimate aim is to change what we do so that possible adverse effects are minimised and possible beneficial effects are maximised.
Assessment is carried out on every policy, practice, provision and criterion identified as relevant in Step 2. There should be a separate assessment for each item. The starting point is to look at the preliminary assessment report for the item. The report should say why the item is being fully assessed. Although this should give a good indication of the adverse and/or beneficial effects of the item, a more intensive analysis is necessary.
Assessing the effect of an item may not be easy:
· The effect may be potential rather than actual
· Even an actual effect may not be obvious
· It may be difficult to tell what is causing even an obvious actual effect[17]
· A beneficial effect for one person may be an adverse effect for another[18]
Try to identify all the potential effects of the policy, practice, provision or criterion on each equality target group. Involving members of each equality target group will almost always be the best way of doing this. It may be the only way of doing it.
The results of an Equality Impact Assessment are unlikely to be acceptable to the enforcement bodies if members of the appropriate equality target groups were not involved in this part of the process.
(The Co-ordination and Involvement section on page 22 explains how equality target groups will be involved in Equality Impact Assessment)
Once potential effects have been identified, examine evidence to see if any of them are actual effects[19]. The answer to the question, “How could someone tell if this is really having an effect?” should indicate the evidence needed. This evidence may be difficult to find or inconclusive. For policies, practices, provisions or criteria judged to be high priority in Step 3, it may be necessary to carry out a special evidence gathering exercise, like a survey.
Some sources of evidence are set out in Appendix 4 Assessment Information and Benchmarks.