Hafod Housing Association – Equality Impact Assessment · 2015-10-18 · Hafod Housing...

Hafod Housing Association – Equality Impact Assessment 2014

1 Lucy Ambrozejczyk, Service Improvement Officer

General Policies – Full Equality Impact Assessment – Summary and Action Plan

23rd October 2014

Assessment Team present:

Lucy Ambrozejczyk, Service Improvement Officer

Corinna Mantle, Head of Service Improvement

*Tenant Representatives*

Malcolm Phillips (Rhondda Cynon Taff)

Graham Robinson (Merthyr Tydfil)

Shirley Sansom (Penarth)

Outcome, Reporting and Action Plan

Name of what has been/or been considered for Assessment

General suite of policies that have a capability to touch every service area throughout the Association;

Complaints Policy

Data Protection, Confidentiality and Access to Information Policy

Environmental Policy

Home Ownership Policy



Making Compensation Payments Policy

Support Needs Policy

Targeted Services Policy

Brief Aims and Objectives of the Policies

The purpose of the assessment is to identify if the general polices indicated above provide fair and equal opportunities for all tenants and residents with protected characteristics. The aims of these policies are;

Provide tenants with services which are tailored to their individual needs

Help service users access support needs packages

To provide reasonable compensation in such cases that lead to inconvenience or financial loss to tenants when standards have not been met.

To treat home-ownership as a form of tenure that is available to all protected groups and can satisfy housing needs and expectations.

Establishing and maintaining an environmentally sustainable approach across our business activities

Make sure that all information obtained and held and disclosed, fully adheres to the eight principles of the Data Protection Act 1998

Help people exercise their right to complain

Help to understand tenant dissatisfaction and look at ways to turn dissatisfaction to satisfaction

Help create equal opportunities

Help employees



Improve services

Did assessing the screening for relevancy (Part A) lead to the Equality Impact Assessment (Part B) being carried out?

Yes/No Record reason for decision Yes The General policies and procedures indicate that there is potential for discriminatory behaviour and/or barriers to be created toward tenants. The need for the full Equality Impact Assessment on this service area is clear in order to remove the potential for discriminatory behaviour and barriers for the Association to comply with its own Equality Strategy and the Public Sector Duty within the Equality Act 2010. See section 14 of screening form for further details.

If no are there any issues to be addressed?

n/a

If yes and Part B was completed what was the outcome of the Equality Impact Assessment?

The full impact assessment used the data document and completed screening sheet for General suite of policies area to highlight areas for improvement with policies and procedures, highlight any negative or adverse impact that the service may or may not currently have for staff and service users. The themes highlighted from the screening session were as follows:

Communication and wording of policies and services available

Ensuring that information related to services are accessible to all protected



characteristic groups

Encouraging reporting of issues from all protected characteristic groups and ensuring that the Association responds appropriately

How lifestyle requirements of protected characteristic groups impact the policies within service area

Portrayal of protected characteristic groups in the media and how this can impact Protected Characteristics groups use of the services and policies

Making reporting and communication methods accessible for all protected characteristic groups if policies are ever needed to be used

Ensuring all different stages of the process are accessible and the need to use customer profiling to tailor services appropriately

Addressing general policies in different settings e.g. sheltered accommodation

Increasing awareness and tolerance in communities (in order to promote full use of the services available)

Behaviour of staff and external contractors to be able to respond appropriately when dealing with tenants from protected characteristic groups

Lifestyle and cultural issues that may impact on the delivery of services

Perception of services amongst protected characteristic groups and impact of previous experiences

Each theme’s impact was discussed to highlight what current impacts or barriers there may be within these policies and what changes/amendments may be required. A summary of the discussion for each protected characteristic can be



found below; Age - Policy and procedure documents should be available in formats that will suit the preferences of the tenant population regardless of age. Should a tenant need to contact the Association then the reporting methods available should be not be restricted in order to suit the preferences of tenants regardless of age. When the Association has received a communication from a tenant the acknowledgement should also be in a format of choice in order to suit the needs of a tenant – as it has been shown that tenants in different age groups prefer different forms of communication. If it is identified that permission or alternative contact is required for a nominated third party to discuss issues then this avenue should be opened up as there may be situations that tenants of different age groups may require an advocate to make decisions on their behalf. The accessibility of communication and advertising of these policies to tenants is another area of improvement. For tenants that live in homes and have access to communal notice boards then these need to be used in order to promote what to do if problems arise, who to contact, methods of contact and also if services have been delivered to that site who delivered them and when. The use of other mediums such as social media, tenant newsletter and site walkabouts are other methods that may appeal to tenants of different age groups. A zero tolerance attitude to discrimination of any kind should be re iterated through all publications and other documents. Community Development work to help foster better relations between tenants of different age groups. Portrayals through the media can taint people’s vision of different age groups and their actions which could lead to other problems so using community development work to ease tensions and change perceptions should be seen as a



valuable tool. When positive work or lessons have been learned through issues highlighted to the Association from tenants of any age not only improve the image to tenants of all ages but maybe give clearer understanding of these polices to all tenants. Adapting the Association’s booklets that are available for tenants to include more diverse imagery helps foster better relations with communities. Disability – Policy and procedure documents should be available in formats that will suit the preferences of the tenant population regardless of disability or impairment. Should a tenant need to report any concerns or problems to the Association then the reporting methods available should be not be restricted in order to suit the preferences of tenants regardless of disability or impairment. Community development work to help improve tolerance of those with disability or impairments. Signposting to relevant external partners/agencies is another avenue in order to help tenants that have disabilities or impairments to report concerns. Ensuring that these links and referrals remain up to date will be key to success of opening up opportunities for tenants in this protected characteristic group to feel that they have parity in the services available. Publicising the options available for tenants with disabilities to help proactively promote reporting of complaints or specific service needs (alternative contact, adaptations, support, mobility needs etc.). Better promotion through the Association’s literature and other communication platforms will help to increase the accessibility of these policies. Empowering staff through education and greater understanding of how our services can impact those with a disability will be important to breaking barriers in accessibility. If staff are aware of how to handle tenants concerns who may be suffering from a disability or impairment and be able to provide a service



or have knowledge of another part of the Association that will ease barriers that may be in place due to in accessibility. If tenants provide us with instructions of how/when/what to respond then the Association must adhere to this as failure to this could lead to increased frustration, stress and complications. Furthermore by not listening to a tenant’s request no matter how small this can have a bearing on whether they use services in future. When positive work or lessons have been learned through issues highlighted to the Association from tenants with a disability or impairment, this will not only improve the image to tenants of all ages but maybe give clearer understanding of these polices to all tenants. A zero tolerance attitude to discrimination of any kind should be re iterated through all publications and other documents. Community Development work to help foster better relations between tenants with or without disabilities. Portrayals through the media can taint people’s vision of different disabilities and subsequently their actions which could lead to other problems so using community development work to ease tensions and change perceptions should be seen as a valuable tool. Adapting the Association’s booklets that are available for tenants to include more diverse imagery to help foster better relations with communities. When positive work or lessons have been learned through issues highlighted to the Association from tenants with or without a disability, this can only improve the image to tenants with or without disabilities and give clearer understanding of these polices to all tenants. Gender Reassignment - A zero tolerance attitude to discrimination of any kind should be re iterated through all publications and other documents. Community Development work to help foster better relations between tenants who have



transitioned or are transitioning. Portrayals through the media can taint people’s vision of transgender people and subsequently their actions could lead to other problems so using community development work to ease tensions and change perceptions should be seen as a valuable tool. The use of signposting and external agencies (working in partnership with the Association) will also allow “trans” tenants to feel more comfortable in using the services available to them as tenants instead of fearing that communication with the Association will “out” their identity and perceptions of potential discriminatory treatment. Investing in staff training and education on how to handle issues with tenants in this protected characteristic so they achieve parity in the service that they receive. Adapting the Association’s booklets that are available for tenants to include more diverse imagery to help foster better relations with communities. When positive work or lessons have been learned through issues highlighted to the Association from tenants who have transitioned or are transitioning, this can only improve the image to tenants regardless of reassignment stage and give clearer understanding of these polices to all tenants. Providing tenants with the opportunity to tailor the service within appropriate boundaries to suit their stage of transition will also help to build confidence and trust in the services available and that their requests will be taken seriously as any other protected characteristic. Gender (sex) - Policy and procedure documents should be available in formats that will suit the preferences of the tenant population regardless of gender. Should a tenant need to report and concerns or problems to the Association then the reporting methods available should be not be restricted in order to suit the preferences of tenants regardless of gender. A zero tolerance attitude to



discrimination of any kind should be re iterated through all publications and other documents. Adapting the Association’s booklets that are available for tenants to include more diverse imagery to help foster better relations with communities. When positive work or lessons have been learned through issues highlighted to the Association from tenants of any gender, this can only improve the image to tenants regardless of gender and give clearer understanding of these polices to all tenants. Providing tenants with the opportunity to tailor the service within appropriate boundaries regardless of gender will also help to build confidence and trust in the services available and that their requests will be taken seriously as any other protected characteristic. Engaging with external support providers and agencies will help to provide tenants with other outlets regardless of gender to build confidence in using the policies and services available by gaining information that is relevant to them. Ensuring that these links are maintained and information is regularly updated is important to their success. The Association can use a number of different outlets to promote these services to tenants of both genders; social media, tenant newsletters, using communal notice boards (if appropriate), staff supplying information on site walkabouts etc. Using these outlets to promote how the service works and what outcomes that have been achieved for tenants can give tenants of both genders confidence that any requests or concerns will be taken seriously. Pregnancy and Maternity – All policies and procedure document should highlight any health and safety concerns for pregnant women. When services are tailored or support is provided the Association must ensure that this is communicated explicitly to all staff that may have to provide a service to any tenants that fall



under this protected group. Ensuring that links with support providers and external agencies must be maintained and updated regularly to ensure that if a tenant who is pregnant has concerns but feels they cannot tell the Association, these support providers can assist in delivering a service. A zero tolerance attitude to discrimination of any kind should be re iterated through all publications and other documents. Adapting the Association’s booklets that are available for tenants to include more diverse imagery to help foster better relations with communities. Providing staff with awareness education on how to provide services to tenants of this characteristic group. Policy and procedure documents should be available in a number of formats. If appointments are needed when using these services then attention must be paid to the location in order for them to be appropriate to the tenant and allow us to receive the full information required. Other lifestyle factors such as appointment times will also need to be taken into consideration. Marriage and Civil Partnerships – Ensure that all policies and procedure documents are available in all formats that will suit preferences of the tenant population regardless of marriage or civil partnership status. Accessibility of the service should be in formats that suit all tenants regardless of marriage or civil partnership status as tenants may wish to communicate and contact the Association differently. Utilising tools that we have available when working in partnership with external agencies should be able to provide support to tenants in heterosexual or same sex marriages and civil partnerships to ensure equal access to services. This approach can also help tenants who belong to more than one protected characteristic feel that they will receive fair treatment and not to “out”



their characteristic if they contact the Association. Community development work will also help to supplement this approach. The Association must be sensitive to the different cultures and their behaviour within marriages or civil partnerships. Certain cultures may have traditions or practices that restricts one member of the relationship from reporting concerns. The literature and booklets that the Association uses can benefit from more diverse imagery in order to reflect the communities that we serve. Increasing staff awareness on how to manage situations with tenants within this protected characteristic. Ensuring that communication is shared between all staff that may be involved in this situation is another factor to take into account when altering the working processes. Continued monitoring of what services are accessed by tenants of this characteristic and if any help or additional support can be provided to these tenants. Ensuring that correct permissions are granted in order for tenants in marriages and civil partnerships to deal with affairs and communicate with the Association appropriately. A zero tolerance attitude to discrimination of any kind should be re iterated through all publications and other documents. Race (including Nationality and Ethnicity) – Ensure that all policies and procedures are available in formats and languages that will suit the preferences of the tenant population regardless of race, ethnicity and nationality. Methods of reporting or contacting the Association should not be restricted as tenants may wish to communicate in different languages and this consideration needs to be recognised. A zero tolerance attitude to discrimination of any kind should be re iterated through all publications and other documents. Community development work needs to be used in order to promote tolerance and awareness and provide



to support to tenants regardless of race, ethnicity and nationality should they need to use one of these services. Investment in staff training to help promote awareness and understanding should tenants need a tailored service or additional support regardless of race, ethnicity and nationality. This training should provide staff with the tools to be sensitive to tenants needs and understand any lifestyle requirements that could have an impact on using the service or having to provide a service that is tailored to suit. The literature and booklets that the Association uses could benefit from more diverse imagery to help foster better relations and represent the communities that we serve. Continued monitoring will need to take place to analyse if any service areas are inaccessible from this protected characteristic and what can be done to improve this. The portrayal of race groups within the media could also have an impact on how other tenants react to minority race groups and the confidence that minority race groups have in using the services available to them. Ensuring that any requests are or concerns raise by tenants of minority groups are taken seriously and treated the same as others will help to promote trust in the Association’s ability to provide parity of service to all tenants. Religion (including Belief) - Ensure that all policies and procedures are available in formats and languages that will suit the preferences of the tenant population regardless of religious belief. Methods of reporting or contacting the Association should not be restricted as tenants may wish to communicate in different languages and this consideration needs to be recognised. A zero tolerance attitude to discrimination of any kind should be re iterated through all publications and other documents. Community development work needs to be used in order to



promote tolerance and awareness and provide to support to tenants regardless of religious belief should they need to use one of these services. The portrayal of religious groups within the media could also have an impact on how other tenants react to minority religious groups and the confidence that minority religious groups have in using the services available to them. Ensuring that any requests or concerns raised by tenants of minority groups are taken seriously and treated the same as others will help to promote trust in the Association’s ability to provide parity of service to all tenants. Investing in staff training to highlight the lifestyle impacts of religious beliefs on using these services is important so that staff can respond appropriately to any requests that are made. Community Development work to help foster good relations and improve perceptions of religious groups within the communities that we serve. Services should continue to be monitored as this can identify which religious groups are accessing the services and if there are any trends that can lead to further improvement initiatives. Sexual Orientation - Ensure that all policies and procedures are available in formats and languages that will suit the preferences of the tenant population regardless of sexual orientation. Methods of reporting or contacting the Association should not be restricted as tenants may wish to communicate in a number of different ways. A zero tolerance attitude to discrimination of any kind should be re iterated through all publications and other documents. Community development work needs to be used in order to promote tolerance and awareness and provide to support to tenants regardless of sexual orientation should they need to use one of these services. Using partnership working and multi-agencies to help promote reporting and full use of the policies if the tenant feels contact



with the Association would “out” their sexual orientation in fear of discriminatory treatment. Investing in staff training to help handle different situations and concerns with LGB tenants and how best to provide services to these tenants. The literature and booklets that the Association uses can benefit from more diverse imagery as this can foster better relations and reflect the communities that we serve.

Describe any mitigating actions taken to reduce negative/adverse impact

It was highlighted that tenants that work “night shifts” may be adversely affected should they want to contact the Association as contacting them may prove difficult. It was discussed by the assessment team that all would be done to identify suitable times for contact or look into alternative types or people to contact with the tenant’s consent in order to provide services as requested.

Is there a strategy for dealing with the unavoidable but not unlawful negative impacts that cannot be mitigated?

n/a

Describe any actions taken to maximise the opportunity to promote equality i.e. changes to the policy, guidance, communication, monitoring or review

Ensure that all policies and procedures are explicit in terms of reporting methods available

Ensure that all policies and procedures are explicit in terms of how the Association will respond (e.g. preferred format of communication) and the timescales for provided responses or updates.

Educational Awareness training for staff and tenants (if required) to create a better understanding of the services available and what is expected

Community development work to help promote the accessibility of these services and how tenants can use them



Develop a zero tolerance statement to discrimination of any kind (staff and tenants) in order to include in all policies and procedures

Look at signposting to external agencies if relevant to the service request

Make use of communal areas to promote service delivery and to give tenants more chances to make services accountable

If there is an issue reported regardless how serious is should be dealt with the same level of service

Improve how communication is provided to all to promote success stories and also lessons that have been learned

What changes have been made to what has been assessed as a result of conducting the EIA?

See Action Plan below

Is what has been assessed lawful?

Yes

Will what has been assessed be adopted?

Yes If no, please record the reason and any further action required:

Are any monitoring arrangements in place?

In line with service review action plans there will be continued monitoring of accessibility of services through equality monitoring reports conducted by the Service Improvement Team. Results gained from the annual STAR survey will also help to identify areas of potential weakness or drive areas of improvement.



Who is the lead officer for the assessment?

Name Lucy Ambrozejczyk

Job Title Service Improvement Officer Department Service Improvement

Review date of policy 2017 Approval Required by Name Title Approval Gained

Corinna Mantle Head of Service Improvement

Alan Morgan Managing Director

Action Plan for General Policies

Outlined below are the actions that are planned following the completion of the Equality Impact Assessment. This will

include any changes that have been made to reduce or eliminate the effects of any potential or actual negative impact

within the service area, as well as any arrangements to collect data or to carry out further research. These actions should

be mainstreamed into previously agreed action plans of other service areas.

Action Lead Completion Date Comment Ensure that all policies and procedures are explicit in terms of

Service Improvement Team

February 2015 Update all documents to highlight the reporting methods to the Association. Make it clear that all types of communication are treated with the



reporting methods available

same weighting and one communication will NOT be preferred to another.

Ensure that all policies and procedures are explicit in terms of how the Association will respond (e.g. preferred format of communication) and the timescales for provided responses or updates.


January 2015 Update all policy and procedure documents with information on formats that are available upon request. Indicate when dealing with tenants what format of communication they would prefer and adhere to it by recording this information for all staff to see. If timescales for responses are indicated then this information should be provided to all staff that may touch the case and records of all contact should be recorded appropriately.

Educational Awareness training for staff and tenants (if required) to create a better understanding of the services available and what is expected

Service Improvement Team, Heads of Service and HR

March 2015 and ongoing

Staff to be given additional training on the impact of our service provision to tenants of protected characteristics. This training will encompass different elements on how services be tailored appropriately and should be aligned to the Association’s corporate values in providing equal and fair treatment.

Community development work to help promote the accessibility of these services and how

Service Improvement Team, Community Investment

Ongoing Community Development team to work on promoting services available to tenants within the general suite of policies. This can include promotional materials, community events etc.



tenants can use them Team

Develop a zero tolerance statement to discrimination of any kind (staff and tenants) in order to include in all policies and procedures


January 2015 Statement to be developed that can be applied to all documents outlining the Association’s stance on discrimination in any form. Statement to also outline action that will be taken should discrimination happen.

Look at signposting to external agencies should this be relevant to the service request


Ongoing If external referrals are going to be used then relationships with agencies need to be maintained and updated on a regular basis. A nominated officer should be responsible for this.

Make use of communal areas to promote service delivery and to give tenants more chances to make services accountable

Service Improvement Team, Housing Officers, Service Contracts team

Ongoing Look into the production of relevant documentation to display. This documentation should be updated regularly. There should be contact information should tenants wish to query.

Improve how communication is provided to all to promote success stories and also lessons that have been learned


Ongoing Association to look into publishing regular case studies – “you said…we did” to show tenants what the Association has done in response to complaints and other queries. This should be published through every communication medium that is available.

If there is an issue Service January 2015 A commitment should be drafted by the



reported regardless how serious is should be dealt with the same level of service

Improvement Team

Association and this should sit within the corporate values and illustrate to tenants that this is the level of service the Association is aiming to achieve, how it will be achieved and monitored.

Hafod Housing Association – Equality Impact Assessment · 2015-10-18 · Hafod Housing...

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