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Appendix 1
Equality Impact and Outcome Assessment
Title of EIA[1] |
Household Support Fund, Phase 3 (October 2022- March 2023), appendix to Household Support Fund and Cost of Living Update (CoL) P&R (recovery) Committee report |
ID No.[2] |
HSF 2022 |
Team/Department[3] |
Welfare, Revenues & Business Support (WRBS) |
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Focus of EIA[4] |
The following is adapted from an EIA that was drafted in 2020 for the Welfare Support and Financial Assistance (WSFA) Workstream, as part of the Covid 19 response. The contents have gone on to inform similar EIAs, for example concerning Household Support Fund (HSF) phase 1 and 2, Cost Of Living Report, review of the Council Tax Reduction Scheme and now has been updated with updated and new data from the Low Income Family Tracker and revisions to impacts and outcomes to reflect the end of COVID restrictions. This EIA now informs the Household Support Fund phase 3 and Cost of Living Report (Sep 2022).
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2. Update on previous EIA and outcomes of previous actions[5]
What actions did you plan last time? (List them from the previous EIA) |
What improved as a result? What outcomes have these actions achieved? |
What further actions do you need to take? (add these to the Action plan below) |
Not Applicable |
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3. Review of information, equality analysis and potential actions
Groups to assess |
What do you know[6]? Summary of data about your service-users and/or staff |
What do people tell you[7]? Summary of service-user and/or staff feedback |
What does this mean[8]? Impacts identified from data and feedback (actual and potential) |
What can you do[9]? All potential actions to: · advance equality of opportunity, · eliminate discrimination, and · foster good relations |
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Age[10] |
There is a limited set of current data available on the financial resilience of this characteristic group. Our assessment has mostly been based on face to face feedback from residents accessing third sector support and wider reports published since the onset of the pandemic.
Source: Mid Year Estimates ONS 2018
*Source: DWP Feb 2020
1https://www.ifs.org.uk/publications/14848
Data from LDSF applications delivered during Household Support Fund, phase one:
Low Income Family Tracker (LIFT) data, available pp23 and 24, shows that households where the main claimant is between 45 and 59 also have a higher incidence of being in a lower financial resilience category and therefore more likely to be in need of crisis support.
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· Cost of Living (CoL) crisis affecting all age groups, but increased fuel costs make older people more vulnerable to unaffordable fuel bills. Older people are on a fixed income and cannot increase this as needed, through work. They may require additional heating, due to health conditions. · Despite COVID restrictions have now eased, older people may still feel vulnerable to infection and are more likely to continue to shield. As such they may be limited in their ability to shop for their essential needs or socialise. · Young people, aged 18-25 less likely to secure employment and so more likely to be applying for Universal Credit. This age group also at high risk of contracting COVID-19 (C-19). · Mental Health issues are continuing to increase and demand has been identified in Youth Services such as Youth Advice Centre (YAC). · Children at risk of insufficient or inadequate diets during holiday and isolation periods, due to additional financial strains on the household. · Working age households more at risk of income reduction following impacts of C-19 restrictions on city employment levels. · Older people with limited mobility may be more reliant on public transport and therefore at greater risk of contracting C-19 · Older people more likely to have additional requirements for electronic equipment. · Older people more likely to have more expensive food costs due to specialist dietary needs.
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· Older people’s health is more at risk if they cannot afford to heat their homes or eat adequately. · Those shielding will be shopping less, shopping locally or not shopping in person at all. They may not have access to full variety of goods, or the best deals (if shopping locally). This could mean food costs rise. Older people may be more likely to be digitally excluded, therefore not accessing on-line shopping slots · Young people less financially independent as a result of decrease in employment opportunities. More likely to be on a fixed income. If they contract C-19, they will likely choose to shield, preventing others from accessing work, community, shops etc. · Households made redundant as a result of business closures or scaling back will need to adjust to lower income, regardless of pre-existing financial commitments based on their employed income – mortgage, rent, hire purchase, mobile phones, debt repayments. · Older people may make a choice of taking taxis as opposed to using the bus, to reduce risk of contracting Coronavirus. |
Ensure easy access to and smooth referrals into the advice sector for those identified as in need of financial support, including council’s own Welfare Support Hub.
Ensuring community organisations representing at-risk groups are funded in order to provide financial support outside of formal council protocol.
Information to be made clear and accessible for all and for all front-line services to be aware of support available and signpost accordingly.
Preventative work by Revenues and Benefits using LIFT dashboard to identify households who may be struggling with Council Tax debt and offering early intervention.
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Disability[11] |
There is a limited set of current data available on the financial resilience of this characteristic group. Our assessment has been based on face to face feedback from residents accessing third sector support and wider reports published since the onset of the pandemic.
Source: Department for Work and Pensions Feb-Jul 2020
Data from LDSF applications delivered during Household Support Fund, phase one shows 36% of claims came from a household with a Disabled person in the household.
Low Income Family Tracker (LIFT) data, available pp23 and 24, shows that in general households in receipt of Disability benefits are more likely to be in a higher financial resilience category (91%) than a household in receipt of benefits where disability components are not in payment. However, within this disability group, those aged between 45 and 60 have a higher incidence of being in a lower financial resilience category and therefore more likely to be in need of crisis support.
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· Disabled people more likely to be limited in their ability to be able to increase their income to afford additional costs, due to their health/disability needs. · Disabled people may be more likely to need to keep their homes warm for their health. · Disabled people more likely to have additional requirements for electronic equipment. · Disabled people more likely to have more expensive food costs due to specialist dietary needs. · In the event of increased rates or further restrictions, more likely to be shielding due to pre-existing health conditions. · More likely to be digitally excluded. · May be more reliant on public transport and therefore at greater risk of contracting C-19.
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· Increased fuel costs due to heating requirements and additional equipment for their accessibility and health needs. · Those digitally excluded may not be accessing cheaper deals on the internet · Those on a fixed income less likely to have savings or financial contingency for increased cost in food and other expenses
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Ensure easy access to and smooth referrals into the advice sector for those identified as in need of financial support, including council’s own Welfare Support Hub.
Ensuring community organisations representing at-risk groups are funded in order to provide financial support outside of formal council protocol.
Information to be made clear and accessible for all and for all front-line services to be aware of support available and signpost accordingly.
Preventative work by Revenues and Benefits using LIFT dashboard to identify households who may be struggling with Council Tax debt and offering early intervention.
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Gender reassignment[12] |
There is a limited set of current data available on the financial resilience of this characteristic group. Our assessment has been based on face to face feedback from residents accessing third sector support and wider reports published since the onset of the pandemic.
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· More likely to be financially disadvantaged or living on a fixed income.
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· Those on a fixed income less likely to have savings or financial contingency for increased cost in fuel and food expenses
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Ensure easy access to and smooth referrals into the advice sector for those identified as in need of financial support, including council’s own Welfare Support Hub.
Ensuring community organisations representing at-risk groups are funded in order to provide financial support outside of formal council protocol.
Information to be made clear and accessible for all and for all front-line services to be aware of support available and signpost accordingly.
Preventative work by Revenues and Benefits using LIFT dashboard to identify households who may be struggling with Council Tax debt and offering early intervention.
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Pregnancy and maternity[13] |
There is a limited set of current data available on the financial resilience of this characteristic group. Our assessment has been based on face to face feedback from residents accessing third sector support and wider reports published since the onset of the pandemic.
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· Already reduced income placed under greater pressure due to CoL
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· Reduced income risks deepening or newly establishing debt. Unable to comfortably adapt to additional costs associated with CoL, ie additional meals for the whole family, but specifically children of school age. Less able to buy in more food to manage isolation and holiday periods, as well as post-natal period when less able to get out.
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Ensuring community organisations representing at-risk groups are funded in order to provide financial support outside of formal council protocol.
Family Information Service, with links into Children’s Centres, Community Midwifery and Health Visiting service, are part of the WSFA board, so issues can be identified and considered strategically across the council.
Ensure easy access to and smooth referrals into the advice sector for those identified as in need of financial support, including council’s own Welfare Support Hub.
Information to be made clear and accessible for all and for all front-line services to be aware of support available and signpost accordingly.
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Race/ethnicity[14] Including migrants, refugees and asylum seekers |
There is a limited set of current data available on the financial resilience of this characteristic group. Our assessment has mostly been based on face to face feedback from residents accessing third sector support and wider reports published since the onset of the pandemic.
Source: Census 2011
Data from LDSF applications delivered during Household Support Fund, phase one:
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· More likely to be on a low or fixed income or having limited hours of work. · Residents with No Recourse to Public Funds including EU nationals without access to benefits in precarious employment or working in the black economy are already vulnerable to destitution if they lose employment. · Engagement issues with advice, stemming from a reported distrust with government and council departments. · Some communities will have specific dietary needs
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· Specific dietary needs may be impacted by food shortages or price rises on high demand products · Emergency food support available may not include items specific to dietary needs. · Due to distrust in official organisations, some groups may not be aware of support available through grants, additional benefit support or crisis intervention routes (eg food banks, Local Discretionary Social Fund (LDSF) etc · No Recourse to Public Funds (NRPF) households may be at particular financial risk if not eligible for all support mechanisms that have been put in place. · Residents with insecure immigration status may fear contacting the authorities in case their details are shared with the Home Office.
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Ensuring community organisations representing at-risk groups are funded in order to provide financial support outside of formal council protocol.
Ensure information about support is accessible to all groups and encourage this information to be distributed through community-based groups. Consider all options of how financial support can be devolved to community-based groups.
Ensure easy access to and smooth referrals into the advice sector for those identified as in need of financial support, including council’s own Welfare Support Hub
Information to be made clear and accessible for all, including translated materials in key languages for the city’s migrant populations, and for all front-line services to be aware of support available and signpost accordingly.
To ensure the needs and eligibility of NRPF households and EU nationals without access to benefits are considered within the allocation of temporary discretionary funds dispersed from central government to support households financially impacted by the pandemic. Each scheme deriving from these funds, in addition to all pre-existing discretionary funds administered by the council, should be inclusive by default.
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Religion or belief[15] |
There is a limited set of current data available on the financial resilience of this characteristic group. Our assessment has mostly been based on face to face feedback from residents accessing third sector support and wider reports published since the onset of the pandemic.
Source: Census 2011
Data from LDSF applications delivered during Household Support Fund, phase one:
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· Engagement issues with advice, stemming from a reported distrust with government and council departments. · Some religious groups will have specific dietary needs
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· Specific dietary needs may be impacted by food shortages or price rises on high demand products (like rice, for example). · Emergency food support available may not include items specific to dietary needs. · Due to distrust in official organisations, some groups may not be aware of support available through grants, additional benefit support or crisis intervention routes (eg food banks, LDSF etc
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Ensuring community organisations representing at-risk groups are funded in order to provide financial support outside of formal council protocol.
Ensure information about support is accessible to all groups and encourage this information to be distributed through community-based groups. Consider all options of how financial support can be devolved to community-based groups.
Ensure easy access to and smooth referrals into the advice sector for those identified as in need of financial support, including council’s own Welfare Support Hub.
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Sex/Gender[16] |
There is a limited set of current data available on the financial resilience of this characteristic group. Our assessment has mostly been based on face to face feedback from residents accessing third sector support and wider reports published since the onset of the pandemic.
Other data available:
95% of single parents with an open Housing Benefit claim are women. (Northgate report 15/10/2020)
Low Income Family Tracker (LIFT) data, available pp23 and 24, shows that single parent households (which are more likely to be women) have a higher incidence of being on a low financial resilience category than couples with children. Single parents are therefore more likely to be in need of crisis support than couples with children.
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· Women are more likely to be working part time, or on a fixed income, than men · Women more likely to be single parents. · Significant increase in reports of domestic abuse and violence throughout the pandemic, disproportionately affecting women. This results in women fleeing their homes and facing financial vulnerability through the homelessness process. |
· Additional burdens due to the cost of Living could have disproportionate impact on women due to the nature of their employment types and barriers to employment for those with sole childcare responsibilities |
Ensure easy access to and smooth referrals into the advice sector for those identified as in need of financial support, including council’s own Welfare Support Hub.
Ensuring community organisations representing at-risk groups are funded in order to provide financial support outside of formal council protocol.
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Sexual orientation[17] |
There is a limited set of current data available on the financial resilience of this characteristic group. Our assessment has mostly been based on face to face feedback from residents accessing third sector support and wider reports published since t the onset of the pandemic.
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No known issues reported to disproportionately affect this group |
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Ensure easy access to and smooth referrals into the advice sector for those identified as in need of financial support, including council’s own Welfare Support Hub.
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Marriage and civil partnership[18] |
There is a limited set of current data available on the financial resilience of this characteristic group. Our assessment has mostly been based on face to face feedback from residents accessing third sector support and wider reports published since the onset of the pandemic.
Source: Census 2011 |
· The strain of economic pressures and debt caused by an increase in the cost of living can impact on the relationships of householders and their Mental Health · Significant increase in reports of domestic abuse and violence throughout the pandemic, disproportionately affecting women. This results in women fleeing their homes and facing financial vulnerability through the homelessness process. · When fleeing DV, the family is often relocated away from their network of family and friends. |
· Homelessness places women at a significant financial disadvantage as well as impacting on their mental health and the wellbeing of the family, as a whole. · Without a network of support, increased expenses may follow due to a loss of informal childcare. Or hours of work may need to be reduced.
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Ensure easy access to and smooth referrals into the advice sector for those identified as in need of financial support, including council’s own Welfare Support Hub.
Ensuring community organisations representing at-risk groups are funded in order to provide financial support outside of formal council protocol.
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Community Cohesion[19] |
Low Income Family Tracker (LIFT) data, available pp23 and 24, shows that the financial resilience of households in different wards can vary, with some wards having a higher incidence of households in financial vulnerability than other wards. St Peter’s and North Laine and Regency wards are showing as having a higher proportion of households on the lower end of the financial resilience categories
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· There could be multiple factors that are affecting this affordability representation in central wards. This could include higher rents, a higher representation of one bed flats and studios (single income households), or a higher proportion of hostel and supported accommodation. More investigation and research needs to be undertaken in order to better understand this demographic representation. |
Ensure easy access to and smooth referrals into the advice sector for those identified as in need of financial support, including council’s own Welfare Support Hub.
Information to be made clear and accessible for all and for all front-line services to be aware of support available and signpost accordingly.
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Other relevant groups[20] |
Carers
Data from LDSF applications delivered during Household Support Fund, phase 1 showed 6% of claims came from a household in receipt of Carers Allowance.
Carers UK research March 2020, ‘Caring and the Cost of Living crisis’ Identified both formal and informal carers were disproportionately at risk by the Cost of Living Crisis.
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· More likely to be on a limited and fixed income due to caring requirements · More likely to have higher fuel costs due to health or disability requirements of the people they care for.
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· Increased fuel costs due to heating requirements and additional equipment for their accessibility and health needs. · Those on a fixed income less likely to have savings or financial contingency for increased cost in food and other expenses |
Ensure easy access to and smooth referrals into the advice sector for those identified as in need of financial support, including council’s own Welfare Support Hub.
Information to be made clear and accessible for all and for all front-line services to be aware of support available and signpost accordingly.
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Cumulative impact[21] |
No adverse impacts identified as yet, but this will be kept under review. |
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Assessment of overall impacts and any further recommendations[22] |
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4. List detailed data and/or community feedback that informed your EIA
Title (of data, research or engagement) |
Date |
Gaps in data |
Actions to fill these gaps: who else do you need to engage with? (add these to the Action Plan below, with a timeframe) |
LDSF systems reporting |
Ongoing |
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ONS data |
Ongoing |
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Housing Benefit data from Northgate (NEC) system |
Ongoing |
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LIFT Programme Data |
TBC |
Data in development |
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DWP Data |
Ongoing |
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EIA sign-off:
Staff member completing Equality Impact Assessment: Tabitha Cork Date: 28/04/2022
Directorate Management Team rep or Head of Service/Commissioning: Nigel Manvell Date: 29/04/2022
CCG or BHCC Equality lead: Janice Markey Date: 28/04/2022
References
[1] Title of EIA: This should clearly explain what service / policy / strategy / change you are assessing
[2] ID no: The unique reference for this EIA. If in doubt contact your CCG or BHCC equality lead (see page 1)
[3] Team/Department: Main team responsible for the policy, practice, service or function being assessed
[4] Focus of EIA: A member of the public should have a good understanding of the policy or service and any proposals after reading this section. Please use plain English and write any acronyms in full first time - eg: ‘Equality Impact Assessment (EIA)’
This section should explain what you are assessing:
[5] Previous actions: If there is no previous EIA or this assessment if of a new service, then simply write ‘not applicable’.
[6] Data: Make sure you have enough data to inform your EIA.
· What data relevant to the impact on specific groups of the policy/decision/service is available?[6]
· What further evidence is needed and how can you get it? (Eg: further research or engagement with the affected groups).
· What do you already know about needs, access and outcomes? Focus on each of the groups identified above in turn. Eg: who uses the service? Who doesn’t and why? Are there differences in outcomes? Why?
· Have there been any important demographic changes or trends locally? What might they mean for the service or function?
· Does data/monitoring show that any policies or practices create particular problems or difficulties for any groups?
· Do any equality objectives already exist? What is current performance like against them?
· Is the service having a positive or negative effect on particular people in the community, or particular groups or communities?
[7] Engagement: You must engage appropriately with those likely to be affected to fulfil the equality duty.
· What do people tell you about the services?
· Are there patterns or differences in what people from different groups tell you?
· What information or data will you need from communities?
· How should people be consulted? Consider:
(a) consult when proposals are still at a formative stage;
(b) explain what is proposed and why, to allow intelligent consideration and response;
(c) allow enough time for consultation;
(d) make sure what people tell you is properly considered in the final decision.
· Try to consult in ways that ensure all perspectives can be considered.
· Identify any gaps in who has been consulted and identify ways to address this.
[8] Your EIA must get to grips fully and properly with actual and potential impacts.
· The equality duty does not stop decisions or changes, but means we must conscientiously and deliberately confront the anticipated impacts on people.
· Be realistic: don’t exaggerate speculative risks and negative impacts.
· Be detailed and specific so decision-makers have a concrete sense of potential effects. Instead of “the policy is likely to disadvantage older women”, say how many or what percentage are likely to be affected, how, and to what extent.
· Questions to ask when assessing impacts depend on the context. Examples:
o Are one or more groups affected differently and/or disadvantaged? How, and to what extent?
o Is there evidence of higher/lower uptake among different groups? Which, and to what extent?
o If there are likely to be different impacts on different groups, is that consistent with the overall objective?
o If there is negative differential impact, how can you minimise that while taking into account your overall aims
o Do the effects amount to unlawful discrimination? If so the plan must be modified.
o Does the proposal advance equality of opportunity and/or foster good relations? If not, could it?
[9] Consider all three aims of the Act: removing barriers, and also identifying positive actions we can take.
· Where you have identified impacts you must state what actions will be taken to remove, reduce or avoid any negative impacts and maximise any positive impacts or advance equality of opportunity.
· Be specific and detailed and explain how far these actions are expected to improve the negative impacts.
· If mitigating measures are contemplated, explain clearly what the measures are, and the extent to which they can be expected to reduce / remove the adverse effects identified.
· An EIA which has attempted to airbrush the facts is an EIA that is vulnerable to challenge.
[10] Age: People of all ages
[11] Disability: A person is disabled if they have a physical or mental impairment which has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities. The definition includes: sensory impairments, impairments with fluctuating or recurring effects, progressive, organ specific, developmental, learning difficulties, mental health conditions and mental illnesses, produced by injury to the body or brain. Persons with cancer, multiple sclerosis or HIV infection are all now deemed to be disabled persons from the point of diagnosis.
[12] Gender Reassignment: A transgender person is someone who proposes to, starts or has completed a process to change their gender. A person does not need to be under medical supervision to be protected
[13] Pregnancy and Maternity: Protection is during pregnancy and any statutory maternity leave to which the woman is entitled.
[14] Race/Ethnicity: This includes ethnic or national origins, colour or nationality, and includes refugees and migrants, and Gypsies and Travellers. Refugees and migrants means people whose intention is to stay in the UK for at least twelve months (excluding visitors, short term students or tourists). This definition includes asylum seekers; voluntary and involuntary migrants; people who are undocumented; and the children of migrants, even if they were born in the UK.
[15] Religion and Belief: Religion includes any religion with a clear structure and belief system. Belief means any religious or philosophical belief. The Act also covers lack of religion or belief.
[16] Sex/Gender: Both men and women are covered under the Act.
[17] Sexual Orientation: The Act protects bisexual, gay, heterosexual and lesbian people
[18] Marriage and Civil Partnership: Only in relation to due regard to the need to eliminate discrimination.
[19] Community Cohesion: What must happen in all communities to enable different groups of people to get on well together.
[20] Other relevant groups: eg: Carers, people experiencing domestic and/or sexual violence, substance misusers, homeless people, looked after children, ex-armed forces personnel, people on the Autistic spectrum etc
[21] Cumulative Impact: This is an impact that appears when you consider services or activities together. A change or activity in one area may create an impact somewhere else
[22] Assessment of overall impacts and any further recommendations
Data taking from Low Income Family Tracker (LIFT), using our July 2022 data set (most recent refresh), representing available equalities groups by their financial resilience status.
NB: The Financial Resilience Metrics used in LIFT to create the financial status score is updated every 6 months. We are due a refresh in our October data set. This will then more accurately represent the current higher levels of inflation and affordability levels that we are seeing in this Cost of Living crisis. This may then affect the overall representation of financial resilience among low income households in the city.