An EIA toolkit, workshop content, and guidance for completing an Equality Impact Assessment (EIA) form are available on the EIA page of the EDI Internal Hub. Please read these before completing this form.
For enquiries and further support if the toolkit and guidance do not answer your questions, contact your Equality, Diversity, and Inclusion (EDI) Business Partneras follows:
· Economy, Environment and Culture (EEC) – Chris Brown,
· Families, Children, and Learning (FCL) – Jamarl Billy,
· Governance, People, and Resources (GPR) – Eric Page.
· Health and Adult Social Care (HASC) – Zofia Danin,
· Housing, Neighbourhoods, and Communities (HNC) – Jamarl Billy
Processing Time:
· EIAs can take up to 10 business days to approve after a completed EIA of a good standard is submitted to the EDI Business Partner. This is not considering unknown and unplanned impacts of capacity, resource constraints, and work pressures on the EDI team at the time your EIA is submitted.
· If your request is urgent, we can explore support exceptionally on request.
· We encourage improved planning and thinking around EIAs to avoid urgent turnarounds as these make EIAs riskier, limiting, and blind spots may remain unaddressed for the ‘activity’ you are assessing.
Process:
· Once fully completed, submit your EIA to your EDI Business Partner, copying in your Head of Service, Business Improvement Manager (if one exists in your directorate), Equalities inbox, and any other relevant service colleagues to enable EIA communication, tracking and saving.
· When your EIA is reviewed, discussed, and then approved, the EDI Business Partner will assign a reference to it and send the approved EIA form back to you with the EDI Manager or Head of Communities, Equality, and Third Sector (CETS) Service’s approval as appropriate.
· Only approved EIAs are to be attached to Committee reports. Unapproved EIAs are invalid.
Throughout this form, ‘activity’ is used to refer to many different types of proposals being assessed.
Read the EIA toolkit for more information.
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New Housing Adaptations Framework Contract (2024) |
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Directorate: |
Housing |
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Service: |
Adaptations |
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Team: |
Housing Adaptations |
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Is this a new or existing activity? |
It is a renewal of an existing contract |
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Are there related EIAs that could help inform this EIA? Yes or No (If Yes, please use this to inform this assessment) |
Yes. There should be an EIA on file for the existing framework |
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Responsible Lead Officer: |
Spencer Ede – Project Manager |
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Accountable Manager: |
Alex Dickie – Operations Manager |
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Additional stakeholders collaborating or contributing to this assessment: |
Procurement, Data Protection and the Contract Legal Team. |
Briefly describe the purpose of the activity being assessed:
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Housing adaptations for people with an assessed long-term and substantial disability. This EIA presented here focuses solely on the building works activity and its building contract. |
What are the desired outcomes of the activity?
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To provide fair and considerate adaptations for independent living and to improve quality of life. |
Which key groups of people do you think are likely to be affected by the activity?
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All disabled adults and children, intersectionally |
What consultations or engagement activities have already happened that you can use to inform this assessment?
· For example, relevant stakeholders, groups, people from within the council and externally consulted and engaged on this assessment. If no consultation has been done or it is not enough or in process – state this and describe your plans to address any gaps.
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Constant contact with our client base and various Housing groups and Associations, Occupational Therapists in our team and in Children’s Services. We have developed links with Possibility People who helped write and improve our guide to ‘Adapting your home’ for private sector residents, and we continue work with groups aligned with them through the Keeping People Well programme on befriending and community navigators projects, tackling/preventing social isolation. We are in contact with the Community Safety team to review our role and response to incidents of disability hate crime, plus Age UK & other voluntary organisations for older people e.g. the ‘Older People’s Council’ Our Occupational Therapists (OTs) have promoted awareness of our service with a presentation to the Older People’s Council and have developed links internally with diverse groups including Black & Racially Minoritised & LGBT groups to promote awareness of the adapts service. Plus, promoted awareness of our service by contacting the BME Community Partnership, LGBT Health & inclusion Project, LGBT switchboard, LGBT Workers Forum, Disabled Workers & Carers Partnership & BME Workers Forum. We have also reached out to the Carers centre & also young carers group with a presentation to Carers forum and improved information about the assessment of Carer’s needs in our published guides and on the Adaptations pages on the council website. |
Do you currently collect and analyse the following data to enable monitoring of the impact of this activity? Consider all possible intersections.
(Delete and indicate as applicable from the options Yes, No, Not Applicable)
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Age |
YES |
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Disability and inclusive adjustments, coverage under equality act and not |
YES |
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Ethnicity, ‘Race’, ethnic heritage (including Gypsy, Roma, Travellers) |
NO |
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Religion, Belief, Spirituality, Faith, or Atheism |
NO |
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Gender Identity and Sex (including non-binary and Intersex people) |
NO |
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Gender Reassignment |
NO |
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Sexual Orientation |
NO |
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Marriage and Civil Partnership |
NO |
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Pregnant people, Maternity, Paternity, Adoption, Menopause, (In)fertility (across the gender spectrum) |
NO |
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Armed Forces Personnel, their families, and Veterans |
NO |
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Expatriates, Migrants, Asylum Seekers, and Refugees |
NO |
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Carers |
NO |
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Looked after children, Care Leavers, Care and fostering experienced people |
NO |
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Domestic and/or Sexual Abuse and Violence Survivors, and people in vulnerable situations (All aspects and intersections) |
NO |
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Socio-economic Disadvantage |
NO |
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Homelessness and associated risk and vulnerability |
NO |
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Human Rights |
NO |
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Another relevant group (please specify here and add additional rows as needed) |
Not applicable |
Additional relevant groups that may be widely disadvantaged and have intersecting experiences that create exclusion and systemic barriers may include:
· Ex-offenders and people with unrelated convictions
· Lone parents
· People experiencing homelessness
· People facing literacy and numeracy barriers
· People on a low income and people living in the most deprived areas
· People who have experienced female genital mutilation (FGM)
· People who have experienced human trafficking or modern slavery
· People with experience of or living with addiction and/ or a substance use disorder (SUD)
· Sex workers
If you answered “NO” to any of the above, how will you gather this data to enable improved monitoring of impact for this activity?
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As a wider team (including our Occupational Therapists) we gather knowledge of individuals within the categories above, but this EIA is limited to the instruction of building work following those detailed, medical assessments. However, housing adaptations require sensitivity and awareness of these issues, but we do not gather this data directly for this purpose.
This EIA focuses only on the delivery of repairs to specific groups of people that have already been determined by the time of delivery. All data relevant for this EIA is taken from information received from OTs. However, we likely need to improve our awareness of intersectionality and barriers due to layers of identities around which today we do not gather or analyse data. Data gathering needs improvement and some of these gaps may be addressed in an updated Allocations Framework EIA, a wider Housing Strategy and EIA actions that result when this strategy is created. |
What are the arrangements you and your service have for monitoring, and reviewing the impact of this activity?
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We gather feedback from clients after work is complete and give contact details on all correspondence so they might inform us at any time, with clear routes to complaints including easy methods for taking complaints higher, before and during the adaptation process. We will also make sure Key Performance Indicators (KPIs) are met including 95%+ customer satisfied with the service & delivery. |
Advisory Note:
· Impact:
o Assessing disproportionate impact means understanding potential negative impact (that may cause direct or indirect discrimination), and then assessing the relevance (that is: the potential effect of your activity on people with protected characteristics) and proportionality (that is: how strong the effect is).
o These impacts should be identified in the EIA and then re-visited regularly as you review the EIA every 12 to 18 months as applicable to the duration of your activity.
· SMART Actions mean: Actions that are (SMART = Specific, Measurable, Achievable, Realistic, T = Time-bound)
· Data analysis and Insights:
o In each protected characteristic or group, in answer to the question ‘If “YES”, what are the positive and negative disproportionate impacts?’, describe what you have learnt from your data analysis about disproportionate impacts, stating relevant insights and data sources.
o Find and use contextual and wide ranges of data analysis (including community feedback) to describe what the disproportionate positive and negative impacts are on different, and intersecting populations impacted by your activity, especially considering for Health inequalities, review guidance and inter-related impacts, and the impact of various identities.
o For example: If you are doing road works or closures in a particular street or ward – look at a variety of data and do so from various protected characteristic lenses. Understand and analyse what that means for your project and its impact on different types of people, residents, family types and so on. State your understanding of impact in both effect of impact and strength of that effect on those impacted.
· Data Sources:
o Consider a wide range (including but not limited to):
§ Census and local intelligence data
§ Service specific data
§ Community consultations
§ Insights from customer feedback including complaints and survey results
§ Lived experiences and qualitative data
§ Joint Strategic Needs Assessment (JSNA) data
§ Good practice research
§ National data and reports relevant to the service
§ Workforce, leaver, and recruitment data, surveys, insights
§ Feedback from internal ‘staff as residents’ consultations
§ Insights, gaps, and data analyses on intersectionality, accessibility, sustainability requirements, and impacts.
§ Insights, gaps, and data analyses on ‘who’ the most intersectionally marginalised and excluded under-represented people and communities are in the context of this EIA.
· Learn more about the Equality Act 2010 and about our Public Sector Equality Duty.
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Does your analysis indicate a disproportionate impact relating to any particular Age group? For example: those under 16, young adults, with other intersections. |
Yes |
If “YES”, what are the positive and negative disproportionate impacts?
Please share relevant insights from data and engagement to show how conclusions about impact have been shaped. Include relevant data sources or references.
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53% of service users are aged over 64. There is a strong link between older age and disability. Disabled Facilities Grant (DFG) equalities monitoring returns: 13% < 45 31% 45 – 64 28% 65 – 74 18% 75 – 84
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Does your analysis indicate a disproportionate impact relating to Disability, considering our anticipatory duty? |
Yes, as all clients of our service are disabled. Impact expected to be positive. |
If “YES”, what are the positive and negative disproportionate impacts?
Please share relevant insights from data and engagement to show how conclusions about impact have been shaped. Include relevant data sources or references.
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100% of our clients have a long-term & substantial disability. Any changes to the property are likely to have an overall positive impact on disabled customers. This is because every single person has a tailored, in-depth assessment of their clinical need. Occupational Therapists do this assessment. |
What inclusive adjustments are you making for diverse disabled people impacted? For example: D/deaf, deafened, hard of hearing, blind, neurodivergent people, those with non-visible disabilities, and with access requirements that may not identify as disabled or meet the legal definition of disability, and have various intersections (Black and disabled, LGBTQIA+ and disabled).
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We approach our caseloads on an individual basis, which involves assessing the individual requirements of disabled residents to improve their living conditions by adapting their home - we consider all the adjustments mentioned above for that reason. This approach should and does include considerations for the people carrying out those assessments and the work itself, either directly or indirectly working for BHCC. |
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Does your analysis indicate a disproportionate impact relating to ethnicity? |
NO |
If “YES”, what are the positive and negative disproportionate impacts?
Please share relevant insights from data and engagement to show how conclusions about impact have been shaped. Include relevant data sources or references.
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Does your analysis indicate a disproportionate impact relating to Religion, Belief, Spirituality, Faith, or Atheism? |
YES
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If “YES”, what are the positive and negative disproportionate impacts?
Please share relevant insights from data and engagement to show how conclusions about impact have been shaped. Include relevant data sources or references.
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Cultural considerations might arise such as dates of significance limiting customer’s availability or conservative household systems that need culturally sensitive engagement and management. Contractors to seek customers availability and enquire about any culturally specific requirements and support. |
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Does your analysis indicate a disproportionate impact relating to Gender Identity and Sex (including non-binary and intersex people)? |
NO
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If “YES”, what are the positive and negative disproportionate impacts?
Please share relevant insights from data and engagement to show how conclusions about impact have been shaped. Include relevant data sources or references.
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Does your analysis indicate a disproportionate impact relating to Gender Reassignment? |
NO |
If “YES”, what are the positive and negative disproportionate impacts?
Please share relevant insights from data and engagement to show how conclusions about impact have been shaped. Include relevant data sources or references.
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Does your analysis indicate a disproportionate impact relating to Sexual Orientation? |
NO |
If “YES”, what are the positive and negative disproportionate impacts?
Please share relevant insights from data and engagement to show how conclusions about impact have been shaped. Include relevant data sources or references.
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Does your analysis indicate a disproportionate impact relating to Marriage and Civil Partnership? |
NO |
If “YES”, what are the positive and negative disproportionate impacts?
Please share relevant insights from data and engagement to show how conclusions about impact have been shaped. Include relevant data sources or references.
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Does your analysis indicate a disproportionate impact relating to Pregnant people, Maternity, Paternity, Adoption, Menopause, (In)fertility (across the gender spectrum)? |
NO |
If “YES”, what are the positive and negative disproportionate impacts?
Please share relevant insights from data and engagement to show how conclusions about impact have been shaped. Include relevant data sources or references.
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Does your analysis indicate a disproportionate impact relating to Armed Forces Members and Veterans? |
NO |
If “YES”, what are the positive and negative disproportionate impacts?
Please share relevant insights from data and engagement to show how conclusions about impact have been shaped. Include relevant data sources or references.
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Does your analysis indicate a disproportionate impact relating to Expatriates, Migrants, Asylum seekers, Refugees, those New to the UK, and UK visa or assigned legal status? (Especially considering for age, ethnicity, language, and various intersections) |
NO |
If “YES”, what are the positive and negative disproportionate impacts?
Please share relevant insights from data and engagement to show how conclusions about impact have been shaped. Include relevant data sources or references.
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Does your analysis indicate a disproportionate impact relating to Carers (Especially considering for age, ethnicity, language, and various intersections). |
NO |
If “YES”, what are the positive and negative disproportionate impacts?
Please share relevant insights from data and engagement to show how conclusions about impact have been shaped. Include relevant data sources or references.
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Does your analysis indicate a disproportionate impact relating to Looked after children, Care Leavers, Care and fostering experienced children and adults (Especially considering for age, ethnicity, language, and various intersections). Also consider our Corporate Parenting Responsibility in connection to your activity. |
NO |
If “YES”, what are the positive and negative disproportionate impacts?
Please share relevant insights from data and engagement to show how conclusions about impact have been shaped. Include relevant data sources or references.
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Does your analysis indicate a disproportionate impact relating to people experiencing homelessness, and associated risk and vulnerability? (Especially considering for age, veteran, ethnicity, language, and various intersections) |
NO |
If “YES”, what are the positive and negative disproportionate impacts?
Please share relevant insights from data and engagement to show how conclusions about impact have been shaped. Include relevant data sources or references.
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Does your analysis indicate a disproportionate impact relating to Domestic Abuse and Violence Survivors, and people in vulnerable situations (All aspects and intersections)? |
NO |
If “YES”, what are the positive and negative disproportionate impacts?
Please share relevant insights from data and engagement to show how conclusions about impact have been shaped. Include relevant data sources or references.
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Does your analysis indicate a disproportionate impact relating to Socio-economic Disadvantage? (Especially considering for age, disability, D/deaf/ blind, ethnicity, expatriate background, and various intersections) |
NO |
If “YES”, what are the positive and negative disproportionate impacts?
Please share relevant insights from data and engagement to show how conclusions about impact have been shaped. Include relevant data sources or references.
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Will your activity have a disproportionate impact relating to Human Rights? |
NO |
If “YES”, what are the positive and negative disproportionate impacts?
Please share relevant insights from data and engagement to show how conclusions about impact have been shaped. Include relevant data sources or references.
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What cumulative or complex impacts might the activity have on people who are members of multiple Minoritised groups?
· For example: people belonging to the Gypsy, Roma, and/or Traveller community who are also disabled, LGBTQIA+, older disabled trans and non-binary people, older Black and Racially Minoritised disabled people of faith, young autistic people.
· Also consider wider disadvantaged and intersecting experiences that create exclusion and systemic barriers:
o People experiencing homelessness
o People on a low income and people living in the most deprived areas
o People facing literacy and numeracy barriers
o Lone parents
o People with experience of or living with addiction and/ or a substance use disorder (SUD)
o Sex workers
o Ex-offenders and people with unrelated convictions
o People who have experienced female genital mutilation (FGM)
o People who have experienced human trafficking or modern slavery
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There is a particular need to consider the complex issues and life-conditions of our clients and it is how they arrive at our services in the first place. Our OTs carry out in-depth assessments of each person based on physical and mental health barriers, and opportunities. The scope of the contractual work that ensues is informed by that initial work. However, this EIA is concentrated on how we deliver that work in their homes. This would include considerations for members of the household with anxiety or breathing issues, or who are disturbed by loud noises such as waste pumps etc, including culturally sensitive and specific requirements. It is important we develop strong accountability with contractors chosen, ensuring they abide by the high standards set by the legal equality duty BHCC is bound to. This will include the consideration of ways to report hate-crime and discrimination that may occur during the engagement and installations. This will also include the communication style of suppliers, their equalities training and equality expertise across all protected characteristics, how they handle circumstances of miscommunication, language barriers or accent difference, faith/religion, belief based cultural differences, same sex families and any other equality related differences that could hinder communication. We do not fully understand any disproportionate intersectional impacts of age with disability, ethnicity, single or same-sex households, migrant and expatriate households, or households in deprived areas. We anticipate there will be some impact intersectionally that the repairs being made to the properties should have an overall positive impact on. Further intersectional impacts will be addressed in the update of the Housing Adaptions EIA.
We are developing our consideration of repercussions and consequences for future suppliers that fall below the equality standard. All this can be embedded into the KPIs of the contract at time of procurement, which we will take care to do. We will provide a clear contact route for our suppliers if/when customers disclose discrimination to contractors, e.g. – domestic violence, sexual abuse, FGM, racism, homophobia. We will also signpost customers to the appropriate resources and support on a case-by-case basis. Overall, the activity proposed will have a positive impact because they are being carried out as instructed by OTs who have made assessment. Considerations will be made for all customers on a case by case basis.
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Which action plans have the actions identified in the previous section been transferred to?
· For example: FIAP (Fair and Inclusive Action Plan) – mandatory noting of the EIA on the Directorate EIA Tracker to enable monitoring of all equalities related actions identified in this EIA. This is done as part of FIAP performance reporting and auditing. Speak to your Directorate’s Business Improvement Manager (if one exists for your Directorate) or to the Head of Service/ lead who enters actions and performance updates on FIAP and seek support from your Directorate’s EDI Business Partner.
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FIAP, relevant team plans and project management/ implementation monitoring plans as appropriate. |
What SMART actions will be taken to address the disproportionate and cumulative impacts you have identified?
· Summarise relevant SMART actions from your data insights and disproportionate impacts below for this assessment, listing appropriate activities per action as bullets. (This will help your Business Manager or Fair and Inclusive Action Plan (FIAP) Service representative to add these to the Directorate FIAP, discuss success measures and timelines with you, and monitor this EIA’s progress as part of quarterly and regular internal and external auditing and monitoring)
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1. Contract monitoring – KPIs & Procurement process · Monitoring timely contact & completion of inclusive and necessary intersectionally and culturally sensitive individualised adaptations – for each protected characteristic · Rights of complaint offered to customer with open & anonymous methods to feedback. · Monitoring progress of staffing among contractors throughout the contract-term as per KPIs noted within the contract. · Screening of contractors at pre-tender stage and stating equalities and inclusion expectations and penalties for failure, support and guidance available, reporting mechanisms for contractors to adhere to in procurement and contract · Power BI reports from different-controlled datasets (To be confirmed) |
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2. Project staff training · The use of CPDs and training for our Occupational Therapists to ensure intersectional, inclusive, accessibility-informed, culturally sensitive, and anti-racist assessment and service provision · Training on equality and equity issues to be included in essential training for our Technical Officers who oversee adaptation projects. · Offer free training to our contractors on EDI and intersectionality, among other appropriate provisions to ensure accessible, inclusive and equitable service delivery and experiences. |
What decision have you reached upon completing this Equality Impact Assessment? (Mark ‘X’ for any ONE option below)
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Stop or pause the activity due to unmitigable disproportionate impacts because the evidence shows bias towards one or more groups. |
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Adapt or change the activity to eliminate or mitigate disproportionate impacts and/or bias. |
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Proceed with the activity as currently planned – no disproportionate impacts have been identified, or impacts will be mitigated by specified SMART actions. |
X |
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Proceed with caution – disproportionate impacts have been identified but having considered all available options there are no other or proportionate ways to achieve the aim of the activity (for example, in extreme cases or where positive action is taken). Therefore, you are going to proceed with caution with this policy or practice knowing that it may favour some people less than others, providing justification for this decision. |
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If your decision is to “Proceed with caution”, please provide a reasoning for this:
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Summarise your overall equality impact assessment recommendations to include in any committee papers to help guide and support councillor decision-making:
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We effectively screen and carefully assess each client’s needs case-by-case, possibility in more depth than other ways to consider these characteristics, culminating in a plan of action guided by lawful execution of these works. The delivery of the building work itself follows that holistic approach to clients and their household. The instructions for the work itself (through this renewed Adaptations Framework contract) will be managed by internal Technical Staff trained in equality, diversity, and inclusion considerations and issues and will follow our corporate policies regarding this. |
All Equality Impact Assessments will be published. If you are recommending, and choosing not to publish your EIA, please provide a reason:
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Not appliable – ok to publish. |
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Signatory: |
Name and Job Title: |
Date: DD-MMM-YY |
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Responsible Lead Officer: |
Spencer Ede – Project Manager |
17-Nov-23 |
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Accountable Manager: |
Alex Dickie – Operations Manager |
17-Nov-23 |
Notes, relevant information, and requests (if any) from Responsible Lead Officer and Accountable Manager submitting this assessment:
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Spencer.Ede@brighton-hove.gov.uk Alex.Dickie@brighton-hove.gov.uk |
EDI Business Partner to cross-check and indicate which aims of the equality duty, public sector duty and our civic responsibilities the EIA activity meets (enter Y for all applicable options):
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Y |
Eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Equality Act. (i.e., the activity removes or minimises disadvantages suffered by different people due to their protected characteristics under the Act and beyond) |
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Y |
Advance equality of access, opportunity, and representation of voice between those who share a protected characteristic and those who do not. (i.e., the activity takes steps to meet the needs of different people from protected groups under the Equality Act (and beyond) where these are different from the needs of other people) |
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Y |
Creating community cohesion - Foster good relations between people who share a protected characteristic and those who do not. (i.e., the activity encourages different people from protected groups under the Equality Act (and beyond) to participate in public life or in other activities where their participation is disproportionately low) |
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N/A |
Sustainability checklist elements and supporting pragmatic achievement of Carbon Neutral goals. Refer to the sustainability checklist. |
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Y |
Addressing and providing inclusive and reasonable adjustments, and/ or meeting our anticipatory duties as a public sector provider, employer, and local authority. |
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Y |
Addressing and removing health inequalities. Meeting the BHCC Joint Health and Wellbeing Strategy. |
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N/A |
Consider if any corporate parental responsibilities are impacted, for example for care experienced people. |
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Y |
Creating social value and community wealth. |
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Y |
Creates and proactively considers for more inclusive and diverse suppliers, commissioned providers, procured service providers and/ or another procurement and commissioning outcome. Refer to our social value framework guidance and guidance around procurement and commissioning. |
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Y |
Meeting our core priority actions, strategic themes of engagement, data, policy, and procedure and workstream activities in the Fair & Inclusive Action Plan (FIAP), Our council plan, Our strategic approach, Workforce Equality reports, Performance Management Framework, and Council-wide Equality Strategies such as Anti-Racism, Accessible City, Gender and more. Also refer to the EDI Internal Hub. |
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N/A |
Creates efficiencies, savings, improves public spending, and has other positive budgetary outcomes or impacts in the public interest and/ or for our people. |
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Y |
Improves our people and/ or user experience, creating equity of access, opportunity, experiential, and wellbeing outcomes. |
EIA Reference number assigned: HNC-101-Dec-23-HousingAdaptationsFramework24
Once the EDI Business Partner has checked the above have been considered for by those submitting the EIA for approval, they will get the EIA signed off and send to the requester copying the Head of Service, Business Improvement Manager, Equalities inbox, any other service colleagues as appropriate to enable EIA tracking and saving.
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Signatory: |
Name: |
Date: DD-MMM-YY |
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EDI Business Partner: |
Jamarl Billy |
12-Dec-23 |
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EDI Manager: |
Sabah Holmes |
15-Dec-23 |
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Head of Communities, Equality, and Third Sector (CETS) Service: (For Budget EIAs/ in absence of EDI Manager/ as final approver) |
N/A (Emma McDermott) |
N/A |
Notes and recommendations from EDI Business Partner reviewing this assessment:
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Recommend conducting a fresh EIA on the Housing Adaptations Policy as the last EIA was in 2017. |
Notes and recommendations (if any) from EDI Manager reviewing this assessment:
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FIAP action to be added and assigned to appropriate Head of Service for monitoring and reporting on. |
Notes and recommendations (if any) from Head of CETS Service reviewing this assessment:
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N/A |