Equality Impact and Outcome Assessment (EIA) Template - 2019

EIAs make services better for everyone and support value for money by getting services right first time.

EIAs enable us to consider all the information about a service, policy, or strategy from an equalities perspective and then action plan to get the best outcomes for staff and service-users^{^[1]}.They analyse how all our work as a council might impact differently on different groups^{^[2]}. They help us make good decisions and evidence how we have reached these decisions^{^[3]}.

See end notes for full guidance. Either hover the mouse over the end note link (eg: Age¹³) or use the hyperlinks (‘Ctrl’ key and left click).

For further support or advice please contact:

BHCC: Communities, Equality and Third Sector Service, EDI Team – email: Equalities@Brighton-Hove.gov.uk
CCG: Engagement and Equalities team (Jane Lodge/Debbie Ludlam)

1. Equality Impact and Outcomes Assessment (EIA) Template

First, consider whether you need to complete an EIA, or if there is another way to evidence assessment of impacts, or that an EIA is not needed^{^[4]}.

Title of EIA^{^[5]}

Proposal for commission new After School Clubs

ID No.^{^[6]}

FCL28

Team/Department^{^[7]}

Health, SEN, and Disability: Families, Children and Learning

Focus of EIA^{^[8]}

The Council has commissioned Extratime to run the after school clubs for children and young people with a disability. However, Extratime is winding up at their organisation and the after school club element of the contract ceased at the end of the Summer term. The two special schools have offered to run the after school clubs in the future and this EIA is part of the supporting documentation for the new model that is being proposed to the Children, Families and Schools committee on the 15 September 2023.

The previous number of places commissioned were 20 per week over five school days during term time. The new model offers 78 places over three days Tuesday, Wednesday, and Thursday during term time.

Initially, the clubs will be for the children and young people attending the special schools and the two children attending mainstream schools who already had places with Extratime. Consideration will then be given to offering children with the same profile of need based in local mainstream schools once the clubs are established.

The impact is that we are increasing the places by 58 per week due to this change. Therefore, more disabled children should be able to access this. All parents and carers who have children attending Hill Park and Downs View special schools have been invited to complete a survey to express their views on the changes. The results of the surveys are appendices to the committee report. The action plan identified mitigating solutions for any data gaps and ensures monitoring and evaluation is in plan for this proposal and post implementation.

2. Update on previous EIA and outcomes of previous actions^{^[9]}

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)

N/A – This is the 1^st EIA.

N/A

3. Review of information, equality analysis and potential actions

Groups to assess	What do you know^{^[10]}? Summary of data about your service-users and/or staff	What do people tell you^{^[11]}? Summary of service-user and/or staff feedback	What does this mean^{^[12]}? Impacts identified from data and feedback (actual and potential)	What can you do^{^[13]}? All potential actions to: · advance equality of opportunity, · eliminate discrimination, and · foster good relations
Age^{^[14]}	The after school clubs are for children and young people between the ages of 4 and 16.	Parents/carers through the recent special school surveys have reported that after school clubs are needed for school age children do that families are able to work and thrive.	All children of school age who are attending either Hill Park or Downs View can apply for a place at the respective school’s club. Once the club is established consideration will be extended to those children of school age in mainstream schools.	Monitor and evaluate experience of and impact on both children within this age group and their families due to this change over the course of the service level agreement.
Disability^{^[15]}	The clubs will be fully accessible to those children and young people with a disability who currently attend either Downs View or Hill Park special schools. Once the after school clubs are established consideration will be given to opening up the clubs to those children with a disability who attend mainstream schools.	Play and leisure opportunities help improve the cognitive, physical, social, and emotional well-being of children and young people. Children and young people with SEND can be very isolated and after school club opportunities offer them a chance to learn through social activities. Parents/ carers have fed back that after school clubs were needed for families to be able to work and thrive.	There will be a positive impact on children and young people’s cognitive, physical, social and emotional well-being if they have an opportunity to attend an after school club at their special school. There will also be a positive impact on their family as this will provide them with respite from their caring duties to enable them to work or spend time with family, or engage in leisure activities.	Monitor and evaluate experience of and impact on both children and parents due to this change over the course of the service level agreement. Once established consideration will be given to extend the offer to other disabled children and young people who currently attend mainstream schools.
Gender reassignment^{^[16]}	There are currently no disproportionate impacts identified for this group.	Schools in the city work closely with Allsorts to understand the complex needs of gender diverse young people.	If impacts are identified the schools will refer to policy and the Trans Toolkit. This will need to be adapted to meet the needs of this cohort.	Both schools hold current data for their pupils on the school SIMS system. Once the pupils attending the clubs has been confirmed this data can be provided and used to inform the planning of any activities to ensure that adjustments are made to reflect any protected characteristics. If this arises there will be package of support provided by the schools through Brighton and Hove’s Trans Toolkit, which will be adapted to meet the individual needs of the young person.
Pregnancy and maternity^{^[17]}	There are no disproportionate impacts identified for this group at this time. All of the children and young people attending these clubs are between the ages of 4 and 16. Therefore we would not expect this to apply.	The impacted group are children aged between 4 to 16 years of age and this is not applicable to them.	The impacted group are children aged between 4 to 16 years of age and this is not applicable to them.	The impacted group are children aged between 4 to 16 years of age and therefore this is not applicable to them.
Race/ethnicity^{^[18]} Including migrants, refugees, and asylum seekers	The January 2023 School Census statistics state that 30.9% identify as BAME in the city compared to an average of 29.5% across the two special schools. As all children and young people attending the special schools can apply for a place at the after school club, we would expect to see a similar % in those attending the provision. We know the impacts of poverty and the cost-of-living crisis impacts more severely on our diverse and ethnic communities.	The special schools hold current data on race and ethnicity through their SIMS system. They will use this to inform their planning and to ensure there is proportionate representation from those pupils who identify as Black and/or from the Global Majority at the clubs. The schools will also be undertaking termly surveys with parents and carers, race and ethnicity will be recorded as part of these surveys. The schools will work closely with their communities to ensure that the languages, accessibility, and time consideration are included. This is to reflect the different pressures on families from different ethnic backgrounds.	We need to ensure that the profile of pupils accessing the after school clubs reflect the proportion of the school (29.5%) population that identifies as being Black and/or part of the Global Majority. The extra contribution requested of parents to support their child may be difficult for certain communities to find from their weekly budget. This is a particular concern for refugee families who work within extremely tight budgets.	Further work needs to be undertaken into the ethnicity of those pupils who will be attending the after school clubs to ensure that there is at least proportionate representation and equity of access of those pupils who identify as Black or Racially Minoritised. If there is not proportionate representation, then an action plan needs to be implemented to ensure that we are supporting children and young people from these communities to attend. The schools have committed to ensure that extra support will be provided to those families who are unable to fund the additional contribution so that their child can attend the club.
Religion or belief^{^[19]}	The schools hold the data on their pupils in terms of their religion or belief. It is likely their will be range of religions and belief systems within the cohort who may attend the clubs. The schools actively engage and celebrate religious and faith celebrated days to affirm children to engage further with the communities.	The clubs are run by the special schools, they will hold this data. The schools will also be undertaking further surveys with parents and carers and ethnicity will be recorded as part of these surveys.	Some religious groups will have specific days which means that they may not be able to facilitate their children or young people attending. 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.	We do not currently have confirmation of those pupils who will be attending the clubs. However, these pupils are known to the schools and any adjustments that may be required to ensure observance of their religion or belief system will be sensitively and inclusively incorporated into the activities. This includes dietary, spiritual and/or attire. Ensure information about support is accessible to all groups and that this information is widely distributed through all communities of identity through diverse and inclusive community engagement.
Sex/Gender^{^[20]}	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. 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: Total Population 290,395 Female 145,778 Male 144,616 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. The gender split of children and young people attending the special schools is approximately 74.5% male and 25.5% female. We would therefore expect to see a similar proportionate gender split in those children and young people attending the clubs.	Women are more likely to be working part time, or on a fixed income, than men. Women more likely to be single parents.	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. We need to ensure that the profile of pupils accessing the after school clubs reflect approximately the proportional gender split of the schools.	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. The schools have committed to ensure that extra support will be provided to those families who are unable to fund the additional contribution so that their child can attend the club. If there is not proportionate representation, then further work will be undertaken to understand why that might be the case and if necessary, an action plan will be implemented to support more female children into after school clubs (ensuring intersectional considerations are made).
Sexual orientation^{^[21]}	Same sex parent/carers couples or LGBTQ single parents are part of the demographic. There is likely to be young people attending the clubs who identify as LGBTQ at we have a high demographic in the city.	We have a high demographic of LGBTQ people in the city. Schools in the city work closely with Allsorts to understand the needs of those young people identifying as LGBTQ.	Ensure materials aimed at parents/carers reflect the diversity in the city.	Ensure that parents/carers and their children are referred to and treated with respect reflecting their family situations. Schools will work with Allsorts to support any young people who identify as LGBTQ and adapt any material to ensure it meets their individual needs.
Marriage and civil partnership^{^[22]}	All of the children and young people attending these clubs are between the ages of 4 and 16. Therefore we would not expect this to apply.	The impacted group are children aged between 4 to 16 years of age and this is not applicable to them.	The impacted group are children aged between 4 to 16 years of age and this is not applicable to them.	No relevant actions identified in this regard at this time.
Community Cohesion^{^[23]}	Different wards have different levels of financial resilience and diverse demographics.	Access to after school clubs is dependent on time, parental responsibilities, and financial means.	We want to ensure that all families have fair access to the after school clubs.	The schools have committed to ensure that extra support will be provided to those families who are unable to fund the additional contribution so that their child can attend the club.
Other relevant groups^{^[24]}	No other impacted groups identified at this time.	No relevant information of any other relevant impacted groups available at this time.	No relevant information in this context available at this time.	No relevant actions identified in this regard at this time.
Cumulative impact^{^[25]}	Make sure that all diverse communities have access to the after-school clubs.	No relevant information in this context available at this time.	No relevant information in this context available at this time.	Ensure that over time the level of access is maintained. This will be monitored and if we identify any issues not considered or unidentified affects we will review the EIA and address them directly with co-produced actions with impacted groups.
Assessment of overall impacts and any further recommendations^{^[26]}
Overall, a positive impact is expected for impacted children across communities of identity. Data gaps have been identified and the action plan notes potential mitigating solutions to address these with appropriate monitoring and evaluation in plan.

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)

Survey of parents/carers undertaken by the special schools on the provision of after school clubs.

Summer Term 2023

Race and ethnicity, Religion and Belief, Sex and Gender, Gender reassignment, Sexual Orientation

Both schools hold current data for their pupils on the school SIMS system. Once the pupils attending the clubs has been confirmed this data can be provided and used to inform the planning of any activities to ensure that adjustments are made to reflect any protected characteristics.

If the proposal is agreed, we will have the relevant data by the end of September and any adjustments necessary will be implemented before the start of the after school clubs.

January 2023 School Census re: BAME

January 2023

Race and ethnicity data was only provided.

See above

5. Prioritised Action Plan^{^[27]}

Impact identified and group(s) affected	Action planned	Expected outcome	Measure of success	Timeframe
NB: These actions must now be transferred to service or business plans and monitored to ensure they achieve the outcomes identified.
All (except marital status/ pregnancy/ maternity), specifically disabled children across impacted age groups (intersectionally)	Monitor and evaluate experience of and impact on both children within this age group and their families due to this change over the course of the service level agreement. Once established consideration will be given to extend the offer to other disabled children and young people who currently attend mainstream schools.	The level of access is maintained over time, equity of access is ensured, and opportunities to extend offer are explored. Monitoring ensured, identified issues not considered addressed and unidentified impacts explored and addressed upon future reviews of the EIA and addressed directly through co-produced actions with impacted groups.	EIA review completed within a year post implementation. Monitoring and evaluation reports, speaking to outcomes, access, impact, and opportunities are produced and progress is communicated appropriately.	Duration of proposal and within 1 year of proposal post implementation.
All (except marital status/ pregnancy/ maternity), specifically disabled LGBTQIA+ and non-binary children across impacted age groups (intersectionally)	Intersectional data-informed, inclusive, and accessible provision provided, with more work carried out to understand and mitigate the impact of marginalisation due to ethnicity, religion, sexual orientation, gender identity. Develop insights of impacted children and families to implement appropriate solutions and any required adjustments.	Both schools hold current data for their pupils on the school SIMS system. Once the pupils attending the clubs has been confirmed this Data held by schools for impacted students provided and used to inform the planning of any activities to ensure that appropriate adjustments are made to reflect any protected characteristics. Appropriate packages of support provided by the schools through Brighton and Hove’s Trans Toolkit, which are adapted to meet the individual needs of the young person. Further intersectional data insights work undertaken into the ethnicity of those pupils who will be attending the after-school clubs to ensure that there is at least proportionate representation and equity of access of those pupils who identify as Black or Racially Minoritised. Appropriate action plan developed and implemented to ensure support provided for disproportionately and under-represented children and young people from communities of identity have equal access, information, and opportunity to attend. Additional burdens due to the cost of Living and disproportionate impacts on families with impacted children reviewed, especially for those facing disproportionate barriers to employment for those with sole childcare responsibilities and in LGBTQIA+, disabled, and Black and Racially Minoritised families. Schools meet their commitments to ensure that extra support is provided to families who are unable to fund the additional contribution so that their child can attend the club. Required inclusive adjustments are made for disabled and LGBTQIA+ children, including observance of cultural, religious or belief systems are sensitively and inclusively provided and incorporated into activities. This includes dietary, spiritual and/or attire requirements. Information about support is accessible to all groups and is widely distributed through all communities of identity through diverse and inclusive community engagement.	Data gathering improved, and intersectional insights developed. Learning from data implemented through appropriate practice changes. Expected outcomes are successfully met. Culturally sensitive and inclusive provisions in activities and schools engagement and treatment are successfully delivered and evaluated through feedback from families and children. Disproportionately impacted and under-represented children, young people, and families are provided equitable access, information, and opportunity to attend. Cost of living burdens, and disproportionate impacts due to protected characteristics are considered in provision and access. Schools promised commitments successfully met, and where unmet, appropriate actions taken, and issues are addressed. Inclusive adjustments identified and provided appropriately, mechanisms to report issues and raise concerns created and implemented successfully. Information widely distributed and communities of identity are widely engaged with demonstrable engagement data and outcomes that are reported on.	Duration of proposal and within year-on-year post implementation.

EIA sign-off: (for the EIA to be final an email must be sent from the relevant people agreeing it or this section must be signed)

Staff member completing Equality Impact Assessment Approval:

Name & Job-title of responsible lead officer

Georgina Clarke-Green, Assistant Director, Health, SEN & Disability

Date:

31-Aug-2023

Directorate Management Team rep or Head of Service/Commissioning Approval:

Name & Job-title of responsible Director/ Head of Service/ Commissioning:

Deb Austin, Executive Director – Families, Children, & Learning

Date:

31-Aug-2023

CCG or BHCC Equality lead Approval:

Name & Job-title of responsible Director/ Head of Service/ Commissioning:

Sabah Holmes, Equality, Diversity, and Inclusion Manager

Approved with action plan and on the understanding that identified mitigating actions and gap fulfilment will be monitored through the directorate’s Fair and Inclusive Action Plan and internal performance reporting and auditing process.

Date:

01-Sep-2023

Guidance end-notes

[1] The following principles, drawn from case law, explain what we must do to fulfil our duties under the Equality Act:

· Knowledge: everyone working for the council must be aware of our equality duties and apply them appropriately in their work.

· Timeliness: the duty applies at the time of considering policy options and/or before a final decision is taken – not afterwards.

· Real Consideration: the duty must be an integral and rigorous part of your decision-making and influence the process.

· Sufficient Information: you must assess what information you have and what is needed to give proper consideration.

· No delegation: the council is responsible for ensuring that any contracted services which provide services on our behalf can comply with the duty, are required in contracts to comply with it, and do comply in practice. It is a duty that cannot be delegated.

· Review: the equality duty is a continuing duty. It applies when a policy is developed/agreed, and when it is implemented/reviewed.

· Proper Record Keeping: to show that we have fulfilled our duties we must keep records of the process and the impacts identified.

NB: Filling out this EIA in itself does not meet the requirements of the equality duty. All the requirements above must be fulfilled or the EIA (and any decision based on it) may be open to challenge. Properly used, an EIA can be a tool to help us comply with our equality duty and as a record that to demonstrate that we have done so.

[2] Our duties in the Equality Act 2010

As a public sector organisation, we have a legal duty (under the Equality Act 2010) to show that we have identified and considered the impact and potential impact of our activities on all people in relation to their ‘protected characteristics’ (age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, sexual orientation, and marriage and civil partnership).

This applies to policies, services (including commissioned services), and our employees. The level of detail of this consideration will depend on what you are assessing, who it might affect, those groups’ vulnerability, and how serious any potential impacts might be. We use this EIA template to complete this process and evidence our consideration.

The following are the duties in the Act. You must give ‘due regard’ (pay conscious attention) to the need to:

avoid, reduce or minimise negative impact (if you identify unlawful discrimination, including victimisation and harassment, you must stop the action and take advice immediately).
advance equality of opportunity. This means the need to:

- Remove or minimise disadvantages suffered by people due to their protected characteristics

- Taking steps to meet the needs of people from protected groups where these are different from the needs of other people

- Encouraging people from protected groups to participate in public life or in other activities where their participation is disproportionately low

- Consider if there is a need to treat disabled people differently, including more favourable treatment where necessary

foster good relations between people who share a protected characteristic and those who do not. This means:

- Tackle prejudice

- Promote understanding

[3] EIAs are always proportionate to:

The size of the service or scope of the policy/strategy
The resources involved
The numbers of people affected
The size of the likely impact
The vulnerability of the people affected within the context

The greater the impacts, the more thorough and demanding the process required by the Act will be.

[4] When to complete an EIA:

When planning or developing a new service, policy or strategy
When reviewing an existing service, policy or strategy
When ending or substantially changing a service, policy or strategy
When there is an important change in the service, policy or strategy, or in the city (eg: a change in population), or at a national level (eg: a change of legislation)

Assessment of equality impact can be evidenced as part of the process of reviewing or needs assessment or strategy development or consultation or planning. It does not have to be on this template, but must be documented. Wherever possible, build the EIA into your usual planning/review processes.

Do you need to complete an EIA? Consider:

Is the policy, decision or service likely to be relevant to a specific group or groups (eg: older people)?
How many people is it likely to affect?
How significant are its impacts?
Does it relate to an area where there are known inequalities?
How vulnerable are the people (potentially) affected?

If there are potential impacts on people but you decide not to complete an EIA it is usually sensible to document why.

[5] Title of EIA: This should clearly explain what service / policy / strategy / change you are assessing

[6] ID no: The unique reference for this EIA. If in doubt contact your CCG or BHCC equality lead (see page 1)

[7] Team/Department: Main team responsible for the policy, practice, service or function being assessed

[8] 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:

What are the main aims or purpose of the policy, practice, service or function?
Who implements, carries out or delivers the policy, practice, service or function? Please state where this is more than one person/team/body and where other organisations deliver under procurement or partnership arrangements.
How does it fit with other services?
Who is affected by the policy, practice, service or function, or by how it is delivered? Who are the external and internal service-users, groups, or communities?
What outcomes do you want to achieve, why and for whom? Eg: what do you want to provide, what changes or improvements, and what should the benefits be?
What do existing or previous inspections of the policy, practice, service or function tell you?
What is the reason for the proposal or change (financial, service, legal etc)? The Act requires us to make these clear.

[9] Previous actions: If there is no previous EIA or this assessment if of a new service, then simply write ‘not applicable’.

[10] 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?[10]

· 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?

Use local sources of data (eg: JSNA: http://www.bhconnected.org.uk/content/needs-assessments and Community Insight: http://brighton-hove.communityinsight.org/# ) and national ones where they are relevant.

[11] 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;

(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.

[12] 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?

[13] 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.

[14] Age: People of all ages

[15] 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.

[16] 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

[17] Pregnancy and Maternity: Protection is during pregnancy and any statutory maternity leave to which the woman is entitled.

[18] 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.

[19] 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.

[20] Sex/Gender: Both men and women are covered under the Act.

[21] Sexual Orientation: The Act protects bisexual, gay, heterosexual and lesbian people

[22] Marriage and Civil Partnership: Only in relation to due regard to the need to eliminate discrimination.

[23] Community Cohesion: What must happen in all communities to enable different groups of people to get on well together.

[24] 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

[25] 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

[26] Assessment of overall impacts and any further recommendations

Make a frank and realistic assessment of the overall extent to which the negative impacts can be reduced or avoided by the mitigating measures. Explain what positive impacts will result from the actions and how you can make the most of these.
Countervailing considerations: These may include the reasons behind the formulation of the policy, the benefits it is expected to deliver, budget reductions, the need to avert a graver crisis by introducing a policy now and not later, and so on. The weight of these factors in favour of implementing the policy must then be measured against the weight of any evidence as to the potential negative equality impacts of the policy.
Are there any further recommendations? Is further engagement needed? Is more research or monitoring needed? Does there need to be a change in the proposal itself?

[27] Action Planning: The Equality Duty is an ongoing duty: policies must be kept under review, continuing to give ‘due regard’ to the duty. If an assessment of a broad proposal leads to more specific proposals, then further equality assessment and consultation are needed.