Q&A: Equality Impact Assessments

I am a Facilities Manager for a large public sector organisation. As part of the organisation’s drive to reduce emissions and to help the environment we have decided to limit the number of lifts that we operate by only using the ones at the front of the building.

A colleague has told me that I will need to do an Equality Impact Assessment to ensure that disabled people and others aren't adversely affected by the policy.

1.    What is an Equality Impact Assessment and why do I have to do one?

Equality Impact Assessments (EIA) are a way assessing the impact (or likely impact) that a particular function, activity or decision will have on different groups of people.  They can help an organisation ensure that the way it carries out its functions works for everyone, including disabled people.

EIAs can help public sector organisations meet their obligations under the public sector duty and they are also an effective tool for private sector companies who want to ensure equality is factored into everything they do for example when creating a new product or service such as online booking.

Carrying out EIAs may also help all organisations avoid claims of indirect discrimination as they provide a framework for assessing whether seemingly neutral provisions, criterion, practices that apply to everyone place disabled people (or a group of people who have the same type of impairment) at a particular disadvantage.

2.    How do I carry out an EIA, and what do I need to consider?

EIAs must be both systematic and proportionate to the organisation, they have 4 possible outcomes:

• No change needed to what you are planning,

• The policy needs adjustment to remove barriers,

• Continue the policy, but this must be justified within the EIA, and it must show how due regard to protected groups has been demonstrated, and

• Stop and remove the policy because of the potential for discrimination.

There are lots of ways to approach carrying out an EIA, but it’s important to follow a consistent and systematic approach.  Check with your colleagues in your Equality and Diversity department to see if there is an existing template that you can follow and follow good practice guidance issued by the EHRC.

As the person responsible for the new policy you may be best placed to conduct the EIA but you will also need to consider who else should be involved for example:

• Key decision makers.
• Disabled employee network or disabled customer focus group (depending on relevance to the policy).
• Frontline staff.
• Regular building users.

It is important to start the EIA early, as this will give you plenty of time to act on any findings.  It is also good practice to screen first, to see if a full EIA needs to be carried out.  If you do end up undertaking a full EIA, you will want to plan to repeat the process again later, to make sure that the outcome was as you had intended.

You will need to decide at this early stage how relevant this particular policy is to equality. Its relevance will determine how much time and energy is you dedicate to it. As disabled people are likely to have different needs with regards to moving round the building your policy of reducing lift access is likely to be relevant to disability equality.

Any decisions you make will need to be evidenced-based so it is important that you gather information to support your work.  The evidence you gather might include:

• Diversity monitoring data.
• Local and national statistics.
• Comparison with similar policies in other organisations.
• Recommendations from any previous physical access audits.
• Information from activities that involve and consult disabled employees and service users and groups that work with disabled people.

The information you collect during this process is likely to indicate that the policy may adversely impact on people with mobility impairments or health conditions such heart conditions or asthma who need to use the lift to move around the building.

Having considered the impact you will then need to decide what to action to take.  It should be possible to adjust the policy so that the impact is removed, for example instead of closing down all of the lifts at one end of the building you might run one lift at each end.  This would allow you to meet your targets on energy reduction whilst ensuring that disabled people have lift access at both ends of the building.

It is important that an action plan is drawn up that includes a process for monitoring and reviewing the action taken.

EIAs are normally published online, so you will also want to make sure that your EIA is published on your organisation’s website.