General Equality Impact Assessment (EIA) Form

 

Support:

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 the Equality, Diversity, and Inclusion (EDI) team by emailing Equalities@Brighton-Hove.gov.uk. If your request is urgent, please mention this in the subject line of your email so we can support as required.  

 

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 Team. 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 the Equalities team by emailing the Equalities inbox and copying in your Head of Service, Business Improvement Manager (if one exists in your directorate), any other relevant service colleagues to enable EIA communication, tracking and saving.

·         Your EIA will be reviewed, discussed, and then approved by the assigned EDI Officer and after seeking additional approval as appropriate for your EIA.

·         Only approved EIAs are to be attached to Committee reports. Unapproved EIAs are invalid.

 

1.     Assessment details

Throughout this form, ‘activity’ is used to refer to many different types of proposals being assessed.

Read the EIA toolkit for more information.

Name of activity or proposal being assessed:

Suitability of Temporary Accommodation Policy

Directorate:

Homes and Adult Social Care

Service:

Housing People Services

Team:

Temporary and Supported Accommodation

Is this a new or existing activity?

Existing

Are there related EIAs that could help inform this EIA? Yes or No (If Yes, please use this to inform this assessment)

Yes, HNC Allocations Policy EIA 2024 and EIA-HASC-Homelessness-and-Rough-Sleeping-Strategy-2025-30

 

2.     Contributors to the assessment (Name and Job title)

Responsible Lead Officer:

Harry Williams, Director of Housing People Services

Accountable Manager:

Aaron Burns, Head of Housing People Services – Temporary & Supported Accommodation

Additional stakeholders collaborating or contributing to this assessment:

Luke Harris, Housing Options Manager

Louise Lowery, Temporary Accommodation Manager

Elizabeth Leach, Project Manager

Tom Matthews, Housing Performance Analyst

 

 

3.     About the activity

Briefly describe the purpose of the activity being assessed:

The purpose of the Suitability of Temporary Accommodation Policy is to provide a clear and consistent framework for assessing the suitability of temporary accommodation for homeless households. The policy ensures that individual needs and circumstances are considered, supporting fair, lawful, and equitable decision-making.

 

What are the desired outcomes of the activity?

The policy aims to allocate scarce temporary accommodation resources to those most in need, ensuring that temporary accommodation placements are suitable, safe, and responsive to the needs of individual households. It promotes consistent and equitable decision-making, supports compliance with statutory duties, and helps to minimise any disproportionate impact on people with protected characteristics or other vulnerabilities.

 

Which key groups of people do you think are likely to be affected by the activity?

The policy is likely to have the greatest impact on people who are homeless or threatened with homelessness and require temporary accommodation, as it directly determines how the suitability of accommodation is assessed and the factors that are considered in placement decisions.

Disabled people may be particularly affected because their accommodation needs may include accessibility requirements, adaptations, proximity to healthcare services, or support networks. Failure to take these needs into account could affect their ability to live independently and safely.

Families with children, pregnant women, and new parents may be affected because accommodation location, size, safety, and access to schools, childcare, healthcare, and family support networks can have a significant impact on household wellbeing and child development.

Older people may have mobility issues, health conditions, or support needs that make the location and physical characteristics of accommodation particularly important to its suitability.

Victims and survivors of domestic abuse may be affected because accommodation decisions must take account of safety considerations, risk management, confidentiality, and access to specialist support services.

People from minority ethnic communities and those whose first language is not English may experience barriers in accessing housing services and information, and may rely on community networks, faith groups, or local services when temporary accommodation is being considered.

LGBTQ+ individuals may have specific safety, wellbeing, or support needs which could influence the suitability of accommodation and location.

People with mental health conditions, substance misuse issues, or other complex support needs may require accommodation that enables access to treatment, support services, and established support networks to promote stability and wellbeing.

The policy seeks to mitigate potential negative impacts on these groups by requiring a thorough assessment of individual circumstances and ensuring that accommodation decisions are made fairly, consistently, and in accordance with legal and statutory requirements. There are also programmes in place to increase the supply of temporary accommodation and therefore support more individuals across the area.

 

4.     Consultation and engagement

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.

Formal consultation is being considered at present, with decisions on the scale and method of consultation under discussion. The policy has been developed through engagement with Housing Options and Temporary Accommodation managers with operational responsibility for homelessness and temporary accommodation services. It has also been informed by analysis of temporary accommodation client data, other equality impact assessments, such as for the homelessness and rough sleeping strategy and the housing allocations policy, as well as relevant legislation and statutory guidance.

The introduction of a Suitability of Temporary Accommodation Policy is consistent with expectations within the statutory homelessness framework and supports the Council in demonstrating how it meets its legal duties to ensure that accommodation provided to households is suitable for their individual needs and circumstances. The primary purpose of the policy is to provide a clear and consistent framework for assessing suitability and to ensure that households are placed in accommodation that appropriately reflects their health needs, accessibility requirements, safeguarding considerations, family circumstances, support networks, education, and employment needs wherever reasonably practicable.

This evidence and operational experience have been used to identify groups that may be disproportionately affected and to ensure that individual needs and circumstances remain central to accommodation decisions. Any future consultation undertaken will be used to further inform the policy and Equality Impact Assessment and identify any additional impacts or mitigations.

 

5.     Current data and impact monitoring

Do you currently collect and analyse the following data to enable monitoring of the impact of this activity? Consider all possible intersections.

(State Yes, No, Not Applicable as appropriate)

Age

YES

Disability and inclusive adjustments, coverage under equality act and not

YES

Ethnicity, ‘Race’, ethnic heritage (including Gypsy, Roma, Travellers)

YES

Religion, Belief, Spirituality, Faith, or Atheism

YES

Sex

YES

Gender (including non-binary and Intersex people)

YES

Gender Reassignment

YES

Sexual Orientation

YES

Marriage and Civil Partnership

NO

Pregnant people, Maternity, Paternity, Adoption, Menopause, (In)fertility (across the gender spectrum)

NO

Armed Forces Personnel, their families, and Veterans

YES

Expatriates, Migrants, Asylum Seekers, and Refugees

YES

Carers

NO

Looked after children, Care Leavers, Care and fostering experienced people

YES

Domestic and/or Sexual Abuse and Violence Survivors, and   people in vulnerable situations (All aspects and intersections)

YES

Socio-economic Disadvantage

YES

Homelessness and associated risk and vulnerability

YES

Human Rights

YES

Another relevant group (please specify here and add additional rows as needed)

YES

Households with children

YES

People placed outside Brighton & Hove

YES

 

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, numeracy and /or digital 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?

Not all protected characteristics are captured within the data about households in TA available from Home Connections and NEC Housing. Some characteristics are not routinely collected through homelessness and temporary accommodation processes, while others may be under-reported where residents choose not to disclose personal information.

 

What are the arrangements you and your service have for monitoring, and reviewing the impact of this activity?

Monitoring arrangements:

·         Regular monitoring of temporary accommodation placements by protected characteristic by the Temporary Accommodation Team with support from Housing Data Analysts where needed.

·         Monitoring of out-of-borough placements, complaints and suitability review requests by the Temporary Accommodation Team with support from Housing Data Analysts where needed.

·         Analysis of outcomes for disabled applicants and other vulnerable groups by the Temporary Accommodation Team with support from Housing Data Analysts where needed.

·         Review of customer feedback and safeguarding concerns by the Temporary Accommodation Team.

·         Annual review of the EIA and policy, or earlier if significant issues are identified, conducted as part of the overarching Homelessness and Rough Sleeping Strategy Action Plan review cycle.

 

6.     Impacts

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)

·         Cumulative Assessment: If there is impact on all groups equally, complete only the cumulative assessment section.

·         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):

§  Population and population groups

·         Census 2021 population groups Infogram: Brighton & Hove by Brighton and Hove City Council 

§  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

§  Health Inequalities 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.

 

6.1 Age

Does your analysis indicate a disproportionate impact relating to any particular Age group? For example: older people, people who may be housebound, 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.

The data indicates that people in temporary accommodation are disproportionately concentrated in the 30 to 59 age range and are less likely to be aged 60 and over than the wider Brighton & Hove population. This is likely because households with dependent children are more likely to be owed the main housing duty and therefore require temporary accommodation. Older people may be less affected overall because they are more likely to be owner occupiers or already living in settled social housing. However, where older people are placed in temporary accommodation, suitability decisions may have a greater impact because of potential mobility, health and support needs.

 

(NEC Housing (NECH) and Home Connections (HC))

 

6.2 Disability:

Does your analysis indicate a disproportionate impact relating to Disability, considering our anticipatory duty?

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.

The available data suggests that disabled people are likely to be disproportionately affected by the policy. Home Connections data indicates that a higher proportion of temporary accommodation clients are recorded as having a long-term health condition or disability than the wider Brighton & Hove population. Disabled households may be more affected by decisions regarding property accessibility, proximity to healthcare, support networks and transport links. The suitability assessment process is therefore particularly important in mitigating potential adverse impacts for this group. Reasonable and inclusive adjustments will be made to the suitability assessment and communication process where required, including accessible information, interpretation or other communication support, so households can understand decisions and communicate relevant needs.

 

(NEC Housing (NECH) and Home Connections (HC))

 

What inclusive adjustments are you making for diverse disabled people impacted? For example: those who are housebound due to disability or disabling circumstances, 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).

A household’s individual circumstances will be taken into account when allocating temporary accommodation, which includes physical access to and around the accommodation, space to mobilise, the accessibility of bathroom and kitchen facilities, and modifications to assist people with needs arising from sensory loss as well as mobility needs 

 

 

6.3 Ethnicity, ‘Race’, ethnic heritage (including Gypsy, Roma, Travellers):

Does your analysis indicate a disproportionate impact relating to ethnicity?

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.

The analysis identifies that Black and Racially Minoritised (BRM) households are overrepresented within the temporary accommodation population when compared with the city population. The evidence suggests this may be linked to higher levels of private rented sector occupation, greater exposure to tenancy loss and some homelessness triggers such as domestic abuse and asylum-related accommodation changes. As a result, decisions relating to suitability, location and access to services may have a greater impact on some ethnic minority households, particularly where placements are away from established community and support networks.

 

(NEC Housing (NECH) and Home Connections (HC))

 

 

6.4 Religion, Belief, Spirituality, Faith, or Atheism:

Does your analysis indicate a disproportionate impact relating to Religion, Belief, Spirituality, Faith, or Atheism?

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.

 

 

6.5 Sex:

Does your analysis indicate a disproportionate impact relating to Sex

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.

Women are overrepresented amongst temporary accommodation households compared with the general population. The analysis suggests this is linked to the higher proportion of women acting as the main applicant in households with dependent children, who are more likely to be in priority need under homelessness legislation. Consequently, decisions about accommodation size, location, schools and support networks may have a greater impact on women, particularly lone-parent households.

 

(NEC Housing (NECH) and Home Connections (HC))

 

6.6 Gender and Gender Reassignment:

Does your analysis indicate a disproportionate impact relating to Gender Identity  (including non-binary and intersex people)?

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.

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.

 

 

 

6.7 Sexual Orientation:

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.

 

 

 

6.8 Marriage and Civil Partnership:

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.

 

 

 

6.9 Pregnant people, Maternity, Paternity, Adoption, Menopause, (In)fertility (across the gender spectrum):

Does your analysis indicate a disproportionate impact relating to Pregnant people, Maternity, Paternity, Adoption, Menopause, (In)fertility (across the gender spectrum)?

 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.

Pregnant people and households with new babies may have additional health, accessibility and support needs, including access to maternity and healthcare services, which will be considered as part of the individual suitability assessment where relevant.

 

 

6.10 Armed Forces Personnel, their families, and Veterans:

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.

 

 

 

6.11 Expatriates, Migrants, Asylum Seekers, and Refugees:

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)

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.

The wider analysis identified a disproportionately high proportion of Black and Racially Minoritised households amongst those leaving Home Office asylum accommodation. This suggests some migrant and refugee groups may be more likely to experience homelessness and require temporary accommodation. Suitability decisions may have a greater impact where households require access to specialist support services, legal advice, interpreters, education and community networks.

 

(NEC Housing (NECH) and Home Connections (HC))

 

 

6.12 Carers:

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.

 

 

 

6.13 Looked after children, Care Leavers, Care and fostering experienced people:

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.

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.

The available data records care leaver status. Care leavers are recognised as a vulnerable group and may lack wider family support networks available to other households. Consequently, accommodation location, accessibility of support services and proximity to professional networks may have a more significant impact on this group than on other temporary accommodation residents.

 

(NEC Housing (NECH) and Home Connections (HC))

 

 

6.14 Homelessness:

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)

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.

The policy provides a structured framework for ensuring that temporary accommodation is suitable for the individual needs and circumstances of homeless households. This can have positive impacts by promoting access to safe and appropriate accommodation, taking account of factors such as disability, health needs, safeguarding concerns, children's education, caring responsibilities, employment and support networks. The policy also supports consistency and transparency in decision-making and, alongside ongoing work to increase the supply and range of temporary accommodation, should improve the Council's ability to match households with accommodation that best meets their needs.

 

Despite these safeguards, homeless households may still experience negative impacts where there is limited accommodation supply, particularly for larger households, disabled people requiring adapted accommodation, or households needing accommodation in specific locations. In some cases, suitable accommodation may only be available outside a household's preferred area, which can affect access to schools, employment, healthcare, support networks and community connections. While the policy seeks to minimise these impacts through individual suitability assessments, they cannot always be eliminated where accommodation availability is constrained.

 

(NEC Housing (NECH) and Home Connections (HC))

 

 

6.15 Domestic and/or Sexual Abuse and Violence Survivors, people in vulnerable situations:

Does your analysis indicate a disproportionate impact relating to Domestic Abuse and Violence Survivors, and people in vulnerable situations (All aspects and 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.

The data identifies domestic abuse as a significant factor amongst households in temporary accommodation, particularly for women and some Black and Racially Minoritised households. Survivors may be disproportionately affected by suitability decisions because location, security measures and confidentiality are critical to their safety. The policy is therefore likely to have a greater impact on this group than on the general temporary accommodation population.

 

(NEC Housing (NECH) and Home Connections (HC))

 

 

6.16 Socio-economic Disadvantage:

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)

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.

The data includes deprivation indicators and relates to households experiencing homelessness and housing need. People experiencing socio-economic disadvantage are therefore likely to be disproportionately affected by the policy. Suitability decisions concerning location, transport costs, access to employment and access to essential services may have a greater impact on households with fewer financial resources.

 

(NEC Housing (NECH) and Home Connections (HC))

 

 

6.17 Human Rights:

Will your activity have a disproportionate impact relating to Human Rights?

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.

The policy directly affects access to suitable accommodation and therefore engages rights relating to private and family life, safety, dignity and non-discrimination. The policy is intended to mitigate potential impacts through the requirement to assess individual circumstances and determine suitability on a case-by-case basis. The greatest impacts are likely to be experienced by vulnerable households where accommodation decisions affect access to support networks, education, healthcare or safeguarding arrangements.

 

(NEC Housing (NECH) and Home Connections (HC))

 

 

 

6.18 Cumulative, multiple intersectional, and complex impacts (including on additional relevant groups):

 

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 being housebound due to disabilities or disabling circumstances

o   Environmental barriers or mobility barriers impacting those with sight loss, D/deafness, sensory requirements, neurodivergence, various complex disabilities

o   People experiencing homelessness

o   People on a low income and people living in the most deprived areas

o   People facing literacy, numeracy and/or digital 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

Potential cumulative impacts may arise where individuals belong to more than one minoritised group. For example, disabled people, Black and Racially Minoritised households, women fleeing domestic abuse, care leavers, and households with children may experience compounded impacts if accommodation is unsuitable, inaccessible or located away from support networks. The policy seeks to mitigate these risks by requiring household circumstances and individual support needs to be considered when assessing suitability. Where households have multiple needs, particularly where an out-of-area placement is being considered, the cumulative effects on disability or health needs, safety, children's education, caring responsibilities, affordability and access to support networks will be considered together within the individual suitability assessment.

 

Households with children are likely to experience some of the greatest impacts from accommodation location decisions due to potential effects on schooling, childcare arrangements and support networks.

 

 

 

7.     Action planning

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)

1.    Ensure accommodation remains suitable to individual household needs

·         Continue to undertake and record individual suitability assessments for all temporary accommodation placements, ensuring consideration is given to disability, health needs, safeguarding concerns, children's education, caring responsibilities, employment and access to support networks so that 100% of placements are subject to a suitability assessment in line with policy requirements which will be ongoing and will be owned by the Temporary Accommodation Team

·         Monitor suitability reviews, complaints and customer feedback to identify any emerging disproportionate impacts on protected groups and make service improvements where required, which will be measured through an annual review of equality impacts and identified actions incorporated into service improvement plans and will be owned by the Temporary Accommodation and Housing Options Teams

2.    Increase the supply, quality and range of temporary accommodation

·         Continue delivery of programmes and projects to increase the supply of temporary accommodation, including the acquisition, leasing and development of additional accommodation to reduce reliance on unsuitable or less suitable placements which will be measured by an increase in available temporary accommodation units and reduction in the use of accommodation that is further from household support networks. This will be ongoing and will be owned by the Housing Directorate.

·         Continue programmes to improve the quality, suitability and diversity of temporary accommodation provision, increasing the availability of accommodation types that meet a wider range of household needs, including families, disabled people and households with specific support requirements which will be measured by an increased proportion of households accommodation in accommodation assessed as meeting their identified needs.

 

Which action plans will the identified actions be transferred to?

·         For example: Team or Service Plan, Local Implementation Plan, a project plan related to this EIA, 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.

These will be managed through the Homelessness and Rough Sleeping Action Plan as they support the priorities outlined in the strategy.

 

8.     Outcome of your assessment

What decision have you reached upon completing this Equality Impact Assessment? (Mark ‘X’ for any ONE option below)

Stop or pause the activity due to unmitigable disproportionate impacts because the evidence shows bias towards one or more groups.

 

Adapt or change the activity to eliminate or mitigate disproportionate impacts and/or bias.

 

Proceed with the activity as currently planned – no disproportionate impacts have been identified, or impacts will be mitigated by specified SMART actions.

X

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.

 

 

If your decision is to “Proceed with caution”, please provide a reasoning for this:

 

 

Summarise your overall equality impact assessment recommendations to include in any committee papers to help guide and support councillor decision-making:

The assessment has identified that the Suitability of Temporary Accommodation Policy is likely to have a greater impact on some groups than others, particularly disabled people, women, Black and Racially Minoritised households, households with children, domestic abuse survivors and other vulnerable households who are disproportionately represented within temporary accommodation. However, these impacts are largely mitigated by the policy's requirement to assess the suitability of accommodation on an individual household basis, taking account of specific needs and circumstances, including health, disability, education, safeguarding concerns, support networks and access to services.

The policy should proceed, subject to ongoing monitoring of outcomes and continued work to increase the supply, quality and range of temporary accommodation available. Increasing the availability of suitable accommodation will further strengthen the Council's ability to meet diverse household needs and reduce the likelihood of disproportionate impacts arising from limited accommodation options.

 

9.     Publication

All Equality Impact Assessments will be published. If you are recommending, and choosing not to publish your EIA, please provide a reason:

N/A

 

10.  Directorate and Service Approval

Signatory:

Name and Job Title:

Date: DD-MMM-YY

Responsible Lead Officer:

Harry Williams, Director Housing People Services

04/09/26

Accountable Manager:

Aaron Burns, Head of Temporary & Supported Accommodation:

2//9/26

 

Notes, relevant information, and requests (if any) from Responsible Lead Officer and Accountable Manager submitting this assessment:

 

 

EDI Review, Actions, and Approval:

 

Equality Impact Assessment sign-off

EDI Officer to cross-check against aims of the equality duty, public sector duty and our civic responsibilities the activity considers and refer to relevant internal checklists and guidance prior to recommending sign-off.

 

Once the EDI Officer has considered the equalities impact to provide approval for by those submitting the EIA, they will get the EIA signed off and sent to the requester copying the Head of Service, Business Improvement Manager, Equalities inbox, any other service colleagues as appropriate to enable EIA tracking, accountability, and saving for publishing. Budget and Staffing EIAs secure approval via different templates.

 

Signatory:

Name:

Date: DD-MMM-YY

EDI Business Partner:

Eric Page

01-10-2026

EDI Manager:

Lindsey Pearce

06-Oct-2026

 

 

Notes and recommendations from EDI Business Partner reviewing this assessment:

This is a comprehensive and proportionate , strong EIA, three small targeted improvements, no need for substantial reworking or additional evidence gathering.

 

 

Notes and recommendations (if any) from EDI Manager reviewing this assessment: