The Equality Act 2010 (the Act) replaces the previous anti-discrimination laws with a single Act

3. Review of information, equality analysis and potential actions

Groups to assess	What do you know[9]? Summary of data about your service-users and/or staff	What do people tell you[10]? Summary of service-user and/or staff feedback	What does this mean[11]? Impacts identified from data and feedback (actual and potential)	What can you do[12]? All potential actions to: · advance equality of opportunity, · eliminate discrimination, and · foster good relations
Age[13]	Parents of children between the age of 2-18 need to be consulted. Changes will affect parents of children born between 1/09/2020 and 31/08/2021 who are due to start school in September 2025. There are projected to be 2177 children in this age bracket, and it is estimated 1959 will require a mainstream school place. When applying for a first school place between 95% and 98% did so online each year from 2021.	The consultation in 2021 received 451 responses through the consultation portal. 79% of responders provided their age with the youngest being 20 and the oldest over 79. Out of the responses in 2021 where age was provided 3% were under 30. 30% were aged between 30-39; 39% aged between 40-49; 5% were aged between 50-59 and 2% were 60 or older. The consultation in 2020 received 802 responses in total however only 15% of responders provided their age with the youngest being 18 and the oldest over 70. Out of the responses in 2020 where age was provided 14% were under 30. 12% were aged between 30-39; 29% aged between 40-49; 22% were aged between 50-59 and 14% were 60 or older.	When considering the responders who provided an age, there was a decrease in the percentage of younger parents responding to the consultation in 2021 compared to previous years. Respondents aged between 30 and 49 accounted for about 60% of the responses. Younger parents are increasingly using the online system to apply for school places.	Further engagement with childcare providers and nurseries in the city to continue to engage younger parents and parents of younger children. Liaise with support services such as Parenting Team, Family Coaches and Youth Employment Service to continue encouraging participation from younger parents. Greater use of social medial platforms and online promotion to reach younger parents in conjunction with traditional methods of promotion. Consideration of timing of any public consultation events so parents with young families can attend.
Disability[14]	Children with Special Educational Needs and Disabilities (SEND) who have an Education, Health & Care Plan would be placed in school under the SEND code of Practice by the SEN team and normal admission arrangements and PANs would not apply.	Consultation in 2021, 8% identified as having a disability. Nearly 68% did not consider themselves to have a disability and 24% did not provide an answer to this question. Consultation in 2020, less than 1% identified as having a disability. 11.5% did not consider themselves to have a disability and 87.7% did not provide an answer to this question. There were no requests last year for consultation documentation in alternative formats and all responses were submitted online or by email.	Parents of children with a disability may be more interested in SEND processes than mainstream school admission arrangements. Disabled parents could find it harder to respond through the online consultation portal or attend an event in person. Parents with children who have a disability may not be able to attend a consultation event in person. Parents with disabled children or who have a disability themselves may not be able to travel a distance to take their child to a school place.	Consultation documentation should be available in other accessible formats, and this should be advertised more widely. Parents who are unable to attend a public meeting will be able to access information online or over the telephone or attend a virtual meeting. If consultation events are held online relevant information should be available to be viewed after the event. Nurseries will be encouraged to identify families who need additional support to access the information materials. The council will also liaise with PaCC and Amaze and any adult/parent disability groups. There needs to be sufficient school places within a reasonable distance of families including those families who have someone with a disability living with them.
Gender reassignment[15]	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 children and young people.	The needs of any impacted within this cohort will be taken into consideration using policy and the Trans Toolkit.	A package of support is provided to the schools via Brighton & Hove’s Trans Toolkit which will be adapted to meet the individual needs of children and young people.
Pregnancy and maternity[16]		Parents who are pregnant or on maternity leave may find it difficult to get older children to school.	There needs to be sufficient places within a reasonable distance from families where there is a pregnant adult or an adult on maternity leave. Pregnant people could find it harder to attend an event in person.	Consideration needs to be given to ensuring that there are enough school places within a reasonable distance from families where there is a pregnant adult or an adult on maternity leave.
Race/ethnicity[17] Including migrants, refugees and asylum seekers	The data available for pre-school pupils indicates an increasing percentage of ethnic minority children for the city in general. There is no comprehensive race/ethnicity data available for the cohort due to start school in September 2024. In 2021 allocation year 27.8% of all applications were from ethnic minority families and there is no ethnicity information for a further 11% of applicants. 33% of late school applications were submitted by ethnic minority families and for a further 19% there is no ethnicity information. 76.4% of ethnic minority families who applied received their first preference school compared to 82% of white British families.	Consultation on admission arrangements conducted in 2021, 18% out of the 451 respondents identified as other than white British. 17% of respondents did not answer this question or did not want to specify their ethnicity. For the consultation in 2020, 3% identified as other than white British and 9% identified as white British. 88% of respondents did not answer this question or did not want to specify their ethnicity Feedback from the Ethnic Minority Achievement Service (EMAS) in relation to the 2020 consultation indicated that many parents from ethnic minorities or with English as an additional language found the consultation confusing even with assistance. There was a reluctance to participate from some groups as they felt that it didn’t affect them partly due to the uncertainty of the housing situations so children may have to move schools anyway and they trust that whatever school parents get it will be a good school. The difficulty of not being able to attend a local school was however identified as a potential problem.	In some allocation years a higher percentage of pupils from ethnic minorities apply late or are directed to a school that was not a preference. There was an increased percentage of ethnic minority respondents for last year’s consultation process compared to previous years. Interested parties from other race/ethnic groups could find it harder to respond through the online consultation portal or attend an event in person.	Important to ensure that there are some surplus places in each planning area so there are local school places available for any late applicants. Explore further other methods of engagement with ethnic minority communities to further increase responses to the consultation. Continue Including the use of the EMAS service to reach out to communities to communicate the proposals in the consultation and the potential impact on their community. Highlight that there is a translation function on the council’s website so that consultation information can be viewed in different languages. Hard copy consultation materials to be made available in different languages as required.
Religion or belief[18]	There are only Church of England and Catholic faith schools within the city. These schools can prioritise children of the faith above other children. A number of these schools do prioritise children of other faiths above children of no faith. None of the faith schools are proposing a reduction in PAN for September 2025. 22% of first preference applications for September 2023 were for church aided schools and 78% expressed a first preference for secular schools.	There is little information on this. Some parents will seek a secular education for their child whilst others will want their children taught in line with their religious belief. 79% of responders to the consultation in 2021 indicated they have no particular religious belief, did not answer the question or preferred not to say.	All schools identified for a reduction in PAN are community schools and this could potentially have a disproportionate impact on pupils with no faith.	Faith schools in the city are responsible for their own admission arrangements and the council cannot consult on changes to their PAN. The council will need to ensure that there are sufficient secular school places available for all residents who require one within a reasonable distance. Consultation events will take place in secular buildings wherever possible.
Sex/Gender[19]	There are no single sex, maintained schools in the city. Admission arrangements do not take into consideration the gender of the child.	61% of responses to the 2021 consultation were submitted by females and 19% by males. 20% did not answer or preferred not to say. 10% of responses to the 2020 consultation were submitted by females and 3% by males. 87% did not answer or preferred not to say.
Sexual orientation[20]	n/a
Marriage and civil partnership[21]	n/a
Community Cohesion[22]	The schools identified in the consultation are in different planning areas and serve different communities within in the city. Brunswick Primary School has 2% of pupils within the 10% most deprived areas of Britain and 4% of pupils within the 20% most deprived areas of Britain. Goldstone Primary School has 1% of pupils within the 10% most deprived areas of Britain and 13% of pupils within the 20% most deprived areas of Britain. Patcham Infant School & Stanford Infant Schools have 1% of pupils within the 10% most deprived areas of Britain and 2% of pupils within the 20% most deprived areas of Britain. Queens Park Primary School has 21% of pupils within the 10% most deprived areas of Britain and 30% of pupils within the 20% most deprived areas of Britain. Rudyard Kipling Primary School has 30% of pupils within the 10% most deprived areas of Britain and 31% of pupils within the 20% most deprived areas of Britain. Saltdean Primary School has 0.3% of pupils within the 10% most deprived areas of Britain and 2% of pupils within the 20% most deprived areas of Britain. St Lukes Primary School has 14% of pupils within the 10% most deprived areas of Britain and 20% of pupils within the 20% most deprived areas of Britain. Woodingdean Primary School has 16% of pupils within the 10% most deprived areas of Britain and 16% of pupils within the 20% most deprived areas of Britain.	House prices surrounding popular schools can be inflated, due to increased demand on accommodation close to popular schools. Parents from some socio-economic groups are better able to lobby and to instigate a cohesive community response to the proposals that may disproportionately influence the decision making about which schools will have their PAN reduced. Some communities may not be adequately represented in public meetings or in the responses to the consultation.	Can have an implication on the pupils offered a place at these schools as families who cannot afford to move close to oversubscribed schools are unable to obtain a place there. Responses to this consultation need to be considered based on the content not just quantity of replies as some areas in the city due to the nature of the community will provide significantly more replies and in a variety of ways.	Consideration of admission arrangements and tie break to remove advantage to families who are in the financial position to move close to popular schools in order to increase chance of obtaining a place. Encourage communities in all areas of the city to engage in the consultation process and provide alternative methods for them to respond. Take consideration of the impact of any change in PAN may have on a school in relation to the composition of pupil cohorts and their families to promote a comprehensive education offer.
Families with English as additional language	The percentage of pupils with English as an additional language varies across primary schools and planning areas from 6.7% in Patcham to 21.3% in West Blatchington & North Hangleton planning areas. Brunswick Primary School have 29.8% of pupils and Queens Park Primary school has 28.9% of pupils where English is an additional language. Patcham Infant School have the lowest with 4.6% of pupils where English is an additional language.	There is little information on this. However we are aware of the level of consultation responses of those who are identified as other than white British. It is also considered likely that families with English as an additional language may struggle to understand the detail and implication of the proposed changes to the admission arrangements in the city. Information that interpreters could be available for public meetings for particular languages with a high prevalence in the community would help encourage participation from these families.	Families with pupils who have English as an additional language are proportionally more likely to apply late which significantly reduces their change of being offered a place at an oversubscribed school. The higher number of families with English as an additional language applying late could be contributed to a number of factors such as these families moving into the city outside the cut off dates for the main admission rounds. This could be due to these families are not being aware of when to apply for school places as they are less likely to understand the promotional information distributed for parents. Families may not comprehend the implication of the proposals or which year they take effect and be able to relate this to their own circumstances. Families with English as an additional language could find it harder to respond through the online consultation portal or attend an event in person.	Important to ensure that there are still surplus places in each planning area so late applicants and pupils moving mid-year can be offered a place at a local school. Greater emphasis needs to be made in future to reach these families and make them aware of the school admissions applications process. If this group are unaware of the school admissions timescale it is also likely that they would be less aware of the consultation process. Additional steps should be taken to engage these families with this consultation. Advice and support shall need to be sought from the EMAS team and others with links to various communities where there are a number of families with English as an additional language. For public meetings with a focus on a particular community, explore with individual schools the languages spoken and benefit of providing interpreters. Highlight that there is a translation function on the council’s website so that consultation information can be viewed in different languages.
Other relevant groups[23] Children in Care and Care Experienced Young People	That Children in Care and Care Experienced Young People are likely to face discrimination. There are 332 children and young people in care, and 381 children and young people previously in care. 41% of 19-21 year old care leavers are not in education, employment or training, compared to 12% of other young people the same age. There are 66% with SEND and 35% have an EHCP, compared to 12% of the general population. 50% of children and young people in care have a diagnosable mental health condition.	Brighton & Hove City Council have adopted Children in Care and Care Experienced Young People as a protected characteristic. As Corporate Parent, there is a collective responsibility and demonstrable commitment to ensure that children and young people with care experience are enabled to have the same opportunities as any other child or young person.	We need to ensure that the profile of children and young people accessing school places are not discriminated against and have the opportunity to access school provision.	Brighton & Hove City Council have adopted Children in Care and Care Experienced as a protected characteristic and will demonstrate commitment to ensure that this group are not discriminated against within the short break and school holiday activities programme. If there is not proportionate representation, then an action plan will be implemented to ensure that we are supporting children and young people from this cohort to attend. Children in care and previously looked after children have the top admission priority when applying for school places.
Cumulative impact[24]
Assessment of overall impacts and any further recommendations[25]
Reducing the number of surplus school places is necessary to safeguard the whole family of schools in the city and to protect schools from financial difficulties as pupil numbers reduce. Without a reduction in school places there is the real possibility that some schools become unable to operate in a financially efficient way with implications for the quality of education provided and the council’s own budget. A higher percentage of late applications are for children from ethnic minorities and children with English as an additional language although the numbers are small. Late applications for oversubscribed schools are less likely to be offered a place. To minimise the impact on these families of applying late more needs to be done to reach these families when reminding parents to apply for their child’s school place. The consultation process must be as accessible as possible for all residents to respond to and that events are held at a variety of times and in locations which allow interested residents to participate and the process of receiving responses is also available to all.

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)
January 2022 & January 2023 school census	January 2022 & 2023
Admissions consultation sought views through the council’s consultation portal and themes identified in series of virtual public meetings.	15/11/21- 2/01/22	Equalities monitoring questions in the consultation portal were not answered by 12% of respondents.
Admissions consultation sought views through the council’s consultation portal	14/11/22-31/12/22	Equalities monitoring questions were not asked of respondents
Infant & Primary school allocation data	September 2023

5. Prioritised Action Plan[26]

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.
Disabled parents and parents with children who have a disability may find it more difficult to participate in the consultation process	Consultation documentation made available in accessible formats and this should be advertised more widely. Parents who are unable to attend a public meeting will be able to access information online or over the telephone Nurseries will be encouraged to identify families who need additional support to access the information materials. The council will also liaise with PaCC and Amaze and any adult/parent disability groups.	Greater participation in the consultation by disabled parents and parents whose children have a disability.	Increased proportion of responses to consultation made by parents with a disability	Before and during consultation period
Previous consultation processes either did not sufficiently engage with ethnic minority families or those who did provide a response were unwilling to divulge their ethnicity however there was an increased percentage of ethnic minority families responding to recent consultations.	Continue to explore other methods of engagement with ethnic minority communities in order to continue increasing responses to the consultation, including the use of the EMAS service to reach out to communities to communicate the proposals in the consultation and the potential impact on their community. Highlight that there is a translation function on the council’s website so that consultation information can be available in different languages. Hard copy consultation materials to be made available in different languages as required.	Greater participation in the consultation by parents from ethnic minority families.	Increased proportion of responses to consultation made by parents from ethnic minorities.	Before and during consultation period
Some communities may not be adequately represented in public meetings or in the responses to the consultation.	Encourage communities in all areas of the city to engage in the consultation process and provide alternative methods for them to respond.	Increased participation in the consultation from communities less likely to participate in the past.	Responses received to the consolation from parents living in all areas in the city.	Before and during consultation period
Ensure that families with English as an additional language are aware of the consultation and are able to participate.	Advice and support sought from the EMAS team and others with links to various communities where there are a number of families with English as an additional language. Highlight that there is a translation function on the council’s website so that consultation information can be available in different languages. Hard copy consultation materials to be made available in different languages as required.	More Families with English as an additional language aware of the consultation and able to participate.	Greater number of responses to consultation from this group.	Before and during consultation period

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

Staff member completing Equality Impact Assessment: Richard Barker Date: 31.10.23

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

CCG or BHCC Equality lead: Date:

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] 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?[9]

· 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.

[10] 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.

[11] 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?

[12] 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.

[13] Age: People of all ages

[14] 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.

[15] 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

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

[17] 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.

[18] 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.

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

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

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

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

[23] 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

[24] 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

[25] 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?

[26] 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.