If you are developing or reviewing a policy, procedure, change to a service or strategy which relates to customers or colleagues, you must carry out an EIA.
What is it?
An Equality impact assessment (EIA) is a risk assessment which focuses on fairness, access and inclusion.
We carry out EIAs early in the planning, development or review of any activity – policies, procedures, changes to services. This helps ensure that we place equality at the heart of everything we do.
An EIA considers a policy, service or process in terms of how it might impact differently on different groups protected in law (known as protected groups/ characteristics) protected against discrimination under the Equality Act 2010.
You will use data and evidence from engagement with diverse customers (and colleagues) to identify the impact of the policy, procedure, strategy, change in service and decide what you will do about it. Identifying impact means checking whether:
- they have experienced any problems as a result of how we work (policies, practices etc)
- they may experience any problems as a result of any changes
- you could advance equality for some disadvantaged groups even if you haven’t identified problems caused specifically by what you do.
Why it matters?
In an ideal world, we wouldn’t need to do EIAs because everyone would consider the following when developing or reviewing policies, procedures, strategies, decisions and service areas:
- Barriers and specific needs of people across the different protected characteristics
- Internal and external data
- Feedback and additional engagement with customer and colleagues across protected characteristics
- Best practice and legislative requirements
However, this rarely happens in reality, so EIAs offer an evidence based approach that can ensure that these considerations are taken into account in practice. They:
- make services better for everyone and support value for money by getting services right first time. They enable you to consider all the information about a service, policy, procedure, project or strategy from an equalities perspective and then action plan to get the best outcomes for customers and colleagues.
- help us make good decisions and evidence how we have reached these decisions. They enable SMT, SLG, Board and Committees to see how decisions might impact on particular protected groups. They can ensure actions are put in place where necessary to overcome negative impacts and barriers that have been identified.
- help us to provide evidence to support regulatory requirements concerning fairness, respect and understanding and tailoring services to meet the different needs of customers and colleagues.
Justifying a decision not to proceed with an EIA
If you decide that an EIA is not needed, you will need to justify your decision. You will need to explain, why you think:
- it is unlikely that (some or all) protected groups will experience barriers because of your policy/practice etc. It is a common mistake to think this might be the case.
- there is no real opportunity to advance equality (e.g. by removing barriers not necessarily created by us).
This is often due to lack of awareness of potential barriers or an assumption that policies/practices etc treat people equally by design. If you are unsure, contact your Equality & Diversity Partner.
To justify your decision not to proceed with an EIA, complete this form.
Top tips
- Consider grouping policies and procedures together for EIA’s.
- EIA’s should be carried out in a group as it helps to capture different perspectives. As a result, any assessment is likely to be more effective. Involve colleagues with practical knowledge of how the policy/practice operates – customer hub, community housing officer, direct services, tenancy support, Equality, Diversity & Inclusion Partner and customers.
- Use the provided EIA form. This provides evidence of the information considered, the impacts and outcomes as part of the process. When using the form, its important to make sure that the process doesn’t become a tick box exercise.
- Think about what internal data you have available. For example, equality monitoring or customer profiling information and how this can be cross referenced to data about the service area. External data can include relevant statistics from Infobase Cymru, Census 2021, relevant research, guidance and good practice from sources such as the Joseph Rowntree Foundation, Stonewall Cymru, Shelter Cymru and the Bevan Foundation, amongst others. It is also useful to keep a record of organisations you find which produce useful research.
- Remember the key is not how much data you collect, but how relevant it is and what it tells you in terms of what is being assessed.
- Engagement with protected groups is a key part of the process. This is where Customer Voice comes in.
- As part of assessing impact you will need to identify actions to overcome any negative impacts.
- The outcomes of EIA should be detailed in reports received by SLG, People and Governance Committee and Board. The enables them to see the potential impact on equality and challenge, scrutinise and ensure mitigating actions are put in place where necessary.
Now you’re ready to carry out the EIA. The EIA toolkit explains what you need to do next.
For any queries, contact your ED&I partner.