Equality Impact Assessment (EIA)
What is an Equality Impact Assessment (EIA)?
An Equality Impact Assessment (EIA) is a thorough and systematic analysis of a policy, whether that policy is written or unwritten, formal or informal, and irrespective of the scope of that policy.
The primary function of the EIA should be to determine the extent of differential impact upon the relevant groups and in turn whether that impact is adverse, that is whether it has a negative impact on groups or individuals in relation to one or more of the equality categories (gender, disability, sexual orientation, age, religious belief, offending past, transgender and transsexual people, people with dependants). In the light of this assessment, if it is decided that the policy has an adverse impact, the Service must consider alternative policies which more effectively achieve the promotion of equality of opportunity or measures which might be employed to reduce or remove the adverse impact.
The processes involved in conducting an EIA should not be looked on as an end in themselves. Instead, it should be borne in mind that the aim of the assessment is the promotion of equality of opportunity and thus the outcomes of the EIA are of primary concern.
In conducting an EIA there are certain methods and procedures that must be considered:
- Assessing how the proposed policies are likely to affect people from relevant groups; this should include collecting and analysing relevant data;
- Consulting people who are likely to be affected by our proposed policies;
- Reviewing and revising the proposed policies in light of the assessment and consultation
Relevant Data & Research
To assess the impact of a proposed policy it is important to have as much knowledge as possible about how the proposed policy will affect people. How this is assessed will depend on the nature of the policy itself but will include
some of the following:
- Demographic data and other statistics, including census findings
- Available Research findings
- Survey data
- Equality monitoring data
- One off data gathering exercises
- Specially commissioned research
Types of Impact Assessment
A full assessment may not be necessary in every case, nor may it be appropriate to conduct a full assessment initially. This guidance suggests Equality Impact Assessments can be split into three categories; The Initial Assessment, the Partial Assessment and the Full Impact Assessment.
A Full EIA has 8 key stages, incorporating both the Initial and Partial Assessments, which are listed below:
- What are the aims of the policy and how is it to be implemented
- Consideration of relevant data and research
- Assessment of impacts
- Consideration of alternatives
- Formal consultation on the actual impact of existing policies and the likely impact of proposed policies
- Monitoring for adverse impact in the future and publication of the results of such monitoring
- Publication of results of the Equality Impact Assessments
The Initial Assessment or Screening (Stage 1)
This will play a valuable role in new policy formulation, or when considering changes to an existing policy, and will be carried out in all cases.
Before embarking on an EIA, it is important to determine the aims of the policy. From this point it is possible to determine the EIA’s terms of reference and whether a partial or full assessment is necessary.
The following questions may help to provide an early steer for an EIA:
- What is the aim, objective or purpose of the policy?
- Who is intended to benefit from this policy and in what way?
- What outcomes are desirable from this policy and for whom?
- What factors/forces could contribute/detract from the outcomes?
- Who are the main stakeholders in relation to this policy?
- Who implements the policy and who is responsible for the policy including:
- the responsibilities which the Service holds in relation to this policy; and
- the responsibilities held by other bodies (including other public authorities).
- Are there concerns that the policy/service has a differential impact on the equality strands?
On those occasions where one or more public authorities share responsibility for a policy then necessary arrangements should be put in place and they should then co-operate in carrying out an EIA. As an EIA proceeds it may become apparent that certain policies are associated. Where this is the case then it may be appropriate to link the EIA's of these policies.
If the Initial Assessment points to the possibility of unjustifiable differential impact on relevant groups, it will be necessary to proceed to a Partial Assessment.
The Partial Impact Assessment (Stages 2 and 3)
A Partial Impact Assessment will build on an Initial Assessment, will outline risks and benefits, and will include the advice of experts and interested groups.
The Partial Impact Assessment is very similar to the Initial Assessment and will be undertaken if the Initial Assessment points to the possibility of unjustifiable differential impact on relevant groups. The Partial Impact Assessment will build on the Initial Assessment and explore the risks and benefits of the policy taking into account the advice of experts or interested groups.
The Partial Impact Assessment will have to clearly state the risks associated with the policy in relation to differential impact and weigh these against the benefits that the policy may have.
Should the Partial Impact Assessment point to a real concern about the policy in terms of differential impact which is echoed by the views of the experts/relevant groups, then it will be necessary to undertake a Full EIA.
The Full Equality Impact Assessment (Stages 4 to 8)
Following an Initial Assessment and a Partial Assessment a Full EIA should be undertaken as outlined below:
4. Consideration of Alternatives:
The consideration of alternatives and other measures is a critical element of the impact assessment process. Options must be developed which reflect alternative methods of delivering the policy outcome. Methods which have a less adverse impact on the relevant group, or which better promote equality of opportunity for the relevant groups, must in particular be considered.
The following also need consideration:
- How does the option further or hinder equality of opportunity?
- How does each option reinforce or challenge stereotypes whichconstitute or influence equality of opportunity?
- What are the costs of implementing each option?
- What are the consequences for the group concerned and for the organisation of not adopting an option more favourable to equality of opportunity?
- How will the relevant group be advised of the new or changed policy or service?
Steps must be taken to reverse any adverse impact, without also impacting upon any other groups in an indirect and adverse way. For example:
- If the policy is unlawful it should be withdrawn and actions or measures to reverse or reduce the adverse impact should be identified
- Identifying resources required to implement the change effectively
- Consulting partner organisations and other public authorities to enlist their help and experience to address the adverse impact
Sources of data might include:
- existing data from within the department/Section
- new data gathered via staff or policy/function user surveys
- existing data from partner organisations
- existing data from expert groups
Consideration of the most appropriate methodology to be used should take account of the equality strands. It may be necessary to make reasonable adjustments in order to gather meaningful data. Suggested methods could
- Written surveys, via letter, email or intranet
- Face to face meetings, telephone interviews
- Workshops and forums
Methods of feeding back the data should also be considered.
6. Formal Consultation:
When consulting, the following questions may assist:
- Who is directly affected by the function/policy?
- Which groups have an interest in the policy or service function?
- What methods of consultation will be used?
- What resources are available?
- How will the information be available to those consulted?
- Have previous attempts to consult with a group been unsuccessful? If so, what has been done to overcome any obstacles?
- Can partner organisations be utilised?
Following the consultation, a decision will need to be made about which alternatives or other measures are being implemented.
7. Monitoring for Adverse Impact:
Monitoring consists of continuous scrutinising, follow up and evaluation of policies. It is not an end in itself but provides the data for the next cycle of policy review. The following steps should be taken:
- monitoring data on the equality strands is collected for all relevant functions and policies in employment and service delivery
- monitoring data is analysed
- action is taken to address the issues raised from monitoring data
- the results of monitoring are published
Each department is responsible for collating the data relevant to the policy or procedure it has responsibility for.
In addition to conventional monitoring, at times the following may also be used:
- Employee cultural audits
- Research in the form of surveys (qualitative and quantitative) for example stakeholder surveys
- Public consultation meetings and focus groups
All monitoring data will be analysed and interpreted to identify trends and consider findings for possible implications on policy. The results will be reported to the Equalities Steering Group. Where a review highlights that a policy has adverse impact on any of the three parts of the general duty, a full impact assessment will be carried out and alternatives or measures to address the impact will be considered.
8. Publication of Results:
Completed Equality Impact Assessments are published on the Essex County Fire and Rescue Service website. An annual paper will also go to the Fire Authority and Strategic Management Board.
The paper will include information on:
- policies that have been assessed for their impact on equality
- actions that have been taken to rectify potential adverse impact of new policies
- consultation that has taken place regarding policies
- results of monitoring those policies identified as having adverse impact
- why the consultation took place and how it was carried out
- a summary of the responses or views it produced
- an assessment of the policy options and what Essex County Fire and Rescue Service is proposing to do following the consultation
Reviewing Policies for Adverse Impact
It is the responsibility for the department heads to ensure that policies in their departments are reviewed at regular intervals, and no less frequently than every 3 years in line with the Single Equality Scheme, for evidence of adverse
impact. All policies are listed in the matrix contained in the Equality Scheme along with a priority - high, medium or low - indicating the timescale in which the assessment needs to be completed.
To maintain consistency, the Equalities Steering Group receives copies of all assessments, a few of which will be audited from each department. The policies are then returned to the relevant departments either accompanied with recommended changes or no further action required until the next scheduled review.
When a policy is in need of being changed, the department continues to use the current policy whilst the review is being carried out. Monitoring of the policy for any adverse impact on the equality strands in employment and service delivery is carried out as part of the review.