Equality Impact Assessments – Getting it right

However much the UK might like to see itself as a liberal, progressive society, persistent disadvantage has not gone away. It is demonstrably bad for all of us, resulting in a wide range of social and economic evils. It hits children hardest of all. And it is, in a fundamentally British sense, deeply unfair, aligning with factors such as ethnicity and disability, characteristics over which individuals have no control.

Who is responsible for making it better? Who should be ensuring that future generations are not cursed by their inheritance? The primary responsibility for child rearing has to remain with the family, but it is also true, as the African proverb has it, that “it takes a village to bring up a child”. We are all responsible. And the public sector is responsible, on all behalf of all the members of the UK village, for the essential support services.

This is not a new issue. It is, however, difficult for the managers of public services to address. The answer, enshrined in current equalities legislation, requires that all public service activities – that is, functions and policies, whether existing or proposed – go through an equalities impact assessment (EIA). The EIA should identify the extent to which an activity might have a positive or negative differential impact on individual members of specific groups. As a result, action can be planned to correct any deficiencies. The problem is that EIAs can be resource intensive, inconsistent and cumbersome. They can become a further bureaucratic overhead on already overstretched managers. They can be a distraction from proper performance management, placing unwarranted emphasis on a paper compliance process. They can hold back the mainstreaming of equalities, by turning the Equality function into a police force and the service manager into the potential wrongdoer. They can completely fail to do what they are supposed to do.

Earlier this year, Black Radley commissioned research into the Equality Impact Assessment process amongst local authorities. 75% of respondents said that their organisation’s EIA support for mainstreaming of equalities was not good. 60% believed that their EIA process was not good in supporting legislative compliance. And 70% believed that their EIA approach was neither cost nor time efficient. In short, the vast majority of council respondents believe that the way they do equality impact assessment is not fully supportive of service performance nor legislative compliance.”

So how do we get EIA right?

The first thing to recognise is that EIA is about service performance. It is not  about a perceived “politically correct”, aggressive equalities agenda – it is about making sure that customers and clients get good service. To do that, we need to know, and respond to, their different needs: that’s what performance management is. And, as a flavour of performance, it’s a task that belongs to line management and follows the normal planning and performance management process.

Recognise that EIA is also about proportionality: you need only pursue the EIA process as far as the activity in question warrants. It is simply ludicrous to put all services through a detailed EIA process: indeed, most services need only a limited degree of examination or none at all. So proportionality requires judgment, management judgment – consistent and informed management judgment.

Build EIA conformance into the internal audit process, leaving the Equalities function as internal support, conscience and service for front line managers; as an information resource and source of expertise on different groups and their needs; as the team with responsibility for the continuous improvement (but not management) of a streamlined and consistent EIA process.

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