Equality & Diversity

What is Equality Impact Assessment?

Equality impact assessment (EIA) is the term given to a review of an institution’s policies to ensure that the institution is not discriminating unlawfully – and that it is making a positive contribution to equality. It is the process of assessing the impact of existing or proposed policies and practices in relation to their consequences for equality. (HEFCE and the Equality Challenge Unit, 2007). 

HEFCE (2004) refer to EIA as ‘the thorough and systematic analysis of a policy or practice to determine whether it has a differential impact on a particular group’. The ‘particular groups’ referred to are the equality focused legally protected characteristics:

• Age
• Disability
• Gender/Sex
• Gender reassignment
• Pregnancy & Maternity
• Race/nationality/ethnic origin
• Religion/belief, and
• Sexual orientation

What are Keele’s commitments to EIA?

Keele University takes its responsibilities regarding equality and diversity very seriously, and this extends to EIA.  The University is committed to ensuring that EIAs are completed for all existing and future policies and practices, as agreed at Keele’s Equality & Diversity Committee of Council, October 2010.

What is Keele’s process for conducting EIAs?

The University’s approach is based on the principle that responsibility for assessing the effect on equality of its policies/practices lies with those within the organisation who ‘own’ those policies/practices and who are responsible for developing and implementing them.

Each Faculty and Directorate has a team of nominated EIA contacts who complete and coordinate EIA work within their area.  These contacts are registered to access the online EIA training and also the online EIA completion tool.

Each Faculty or Directorate has to undergo the following key steps:

• Conduct a scoping exercise to identify policies/practices (which may need an EIA) in that Faculty/Directorate.

• Pre-screen all identified policies/practices to anticipate numbers of high/medium/low impact EIAs to be conducted, and identify those policies/practices for which no EIA is required.

• Use the online completion tool to screen the policies/practices to identify whether there may be potential impact which would require further analysis through a full EIA.  If the screening is the end of the process for a particular policy/practice, this needs to be signed off at this point by the appropriate Dean or Director.

• Use the online completion tool to conduct a full EIA for those policies/practices which require one.

• Once the full EIA (or screening if this is the final stage required) has been completed and submitted for publication an automatic email is generated, contacting the EIA System Advisor in HR who will do an initial check of the EIA.

• The EIA System Advisor in HR will then e-mail the relevant Lead Contact asking them to check the EIA and notify the EIA System Advisor in HR once they have approved the final version.

• The relevant Dean/Director is then contacted by HR, informing them that they are responsible for the official final sign-off of that EIA and providing them with 21 working days to review the EIA.  A reminder will be sent after 14 working days.  In the absence of further comment from the Dean/Director after 21 working days, it will be assumed that the EIA has been approved.

• When screenings and full EIAs have been signed off by the relevant Dean or Director, HR will upload details of the completed screening/EIA onto the EIA webpages.

• Further agreed action arising from the EIA should be planned and conducted as outlined in the EIA, with timely review or monitoring as appropriate.

How will Keele monitor the implementation of the EIA system and the quality of the EIAs conducted?

The Equality & Diversity lead in HR will periodically review selected completed full EIAs and screening reports to monitor quality and consistency of approach to EIA completion across the University. If as a result of this review further support, guidance or training is needed in particular areas of the University this will be arranged.

The E&D Implementation Group will receive a summary report on progress across the University on a six-monthly basis for discussion and consideration of further action required at a University level in embedding the EIA system.  This will be combined and reported on an annual basis to the E&D Committee of Council for their formal approval.

What is the background to EIAs at Keele?

Keele University is bound by legal duties to ensure it is eliminating discrimination and producing positive outcomes for equality.  To achieve this, public sector organisations – including Higher Education Institutions – are required to assess the impact (in terms of equality) for all new and existing policies and practices.  This legal requirement is enforceable by the Equality and Human Rights Commission. 

Conducting EIAs and taking appropriate action in light of EIA outcomes enables the University to deliver against the General Duties of the Equality Act 2010, which require us to:

• eliminate unlawful discrimination, harassment and victimisation

• advance equality of opportunity between different groups; and

• foster good relations between different groups.

Why do we need to conduct EIAs?

Carrying out EIAs enables us to determine whether our policies or practices have an impact on a particular equality characteristic group.  EIAs are planning/development aides which help us to improve our policies and practices and ensure that they are transparent and fit for purpose. EIAs enable us to equality-audit our policies and practices to ensure that we are not discriminating against anyone, that we are providing equal opportunities to all and that we are promoting good relations between all our staff, students and other stakeholders.

By identifying and responding to impacts which a policy/practice has on equality grounds the University can make improvements or amendments which enable us to:

• eliminate discrimination

• tackle inequality

• improve communication and understanding between providers and users of services, be they staff, students or the general public

• target resources and support effectively

• adhere to the legal requirements upon us.

What should have an EIA?

EIAs should be conducted on all relevant existing and future policy and practices at Keele, whether formal or informal, written or unwritten. 

For the purposes of EIA, the Equality and Human Rights Commission (2009) define ‘policy’ as follows:

''Policy’ needs to be understood broadly to embrace the full range of functions, activities and decisions for which the organisation is responsible: essentially everything the authority does. This includes both current policies and new policies under development.’

Accordingly and in line with this broad definition of ‘policy’, the University requires any Keele document including but not limited to Strategic Plan, Policy, Procedure, Supporting Strategy, Code of Practice, or Guideline documentation to be Equality Impact Assessed, using agreed University procedure for completion of the EIA process. 

Formal, documented policy or practice issues are often the most significant areas to be EIA’d.  However it is important that in addition, Faculties and Directorates should also consider whether they have any unwritten or informal practices or processes which may required an EIA, as these are also subject to the requirement for EIA.

Policy or Procedure

A policy or procedure is any decision, principle, plan or set of procedures that influences and determines the way ain institution carries out its business (internally or externally).

Practice

A practice is more informal than a policy and refers to a customary way of operation or behaviour, perhaps built up over a number of years. It can be identified through being routinely performed, locally, regardless of any official requirements in policy.

Service

A service or provision is an activity which serves to provide for or meet the requirements or particular needs of people.

In order to assess whether your policy / procedure / practice / service requires an EIA please use the following Pre-Screening Equality Tool.

How to establish the right scope for an EIA?

Having identified which policies are relevant to the equality duty it is important to clarify the purpose of the EIA and identify which aspects of the policy / practice is most significant for equality and the protected groups. This should help set out the parameters for the EIA, and focus the direction of the EIA to the most important aspects.

To establish the right scope for your EIA you may consider asking the following questions:

• What are the aims of the policy / practice / service?
• Can the policy / practice / service be broken down into its main component parts and what is most important?
• What are the aspects of the policy / practice service you have influence over to make changes?
• Is there a key decision or change that needs testing within the policy / practice / service?

 For example:

The University highlight there is anecdotal evidence of bullying and harassment occurring between students on campus. The University wants to ensure all bullying incidents are captured and dealt with appropriately.

The scope of the EIA could be:

• Reporting processes
• Advice and support
• Monitoring of incidents

EIA Pre-Screening Tool  

When should an EIA be carried out?

The legal duty to carry out impact assessment applies to all existing and new policies/practices.  Carrying out EIAs as soon as possible will help to ensure that associated benefits are achieved as quickly as possible. Getting things right as early as possible can help save costs of correcting policies/practices in the future.

EIAs should be carried out whenever you plan, introduce, change or remove a service, policy or function, and should be an integral part of policy/practice development and review.

In practical terms, this means that, for the back catalogue, this should be timetabled to take place as soon as practical.  For existing policies or practices within a Faculty/Directorate, the nominated contacts for that area need to conduct a scoping exercise to identify and prioritise all policies/practice within that area for EIA so that EIAs can be conducted for these in a timely manner over a realistic period of time.

In the case of new policies/practices, EIA should take place during development – early enough to stop bad policy/practice being made, but late enough for a considered judgement to be reached. EIA should be an essential ingredient of all stages of policy development, from conception to implementation. This links in with the idea of impact assessment being a means of mainstreaming equality into an institution.  If you are developing a policy or practice which you think might or will need to be Equality Impact Assessed, get in touch early on with the EIA lead contact in your area (Faculty or Directorate) to ensure that this happens in a timely manner.

Who carries out EIAs?

Ownership and responsibility for an EIA sits with the area which developed the policy or practice.

Each Faculty and Directorate has agreed a nominated group of EIA contacts who will take responsibility for the Equality Impact Assessment process in their area.  Each Faculty and Directorate also has an agreed lead contact who acts as a coordinator for the EIA work within that area.

All EIAs completed within a Faculty or Directorate are subject to final sign-off by the relevant Dean or Director.

For further information about EIA within your Faculty or Directorate you can contact the lead EIA contact:

HR, Organisational Development & Student Support Directorate

Lindsay Fleetwood, Human Resources Officer, Phone: 33549 Email: l.fleetwood@per.keele.ac.uk

Finance & IT Directorate 

Lee Bestwick (Lead contact for Finance), Systems & Project Accountant, Phone: 34387  Email: l.a.bestwick@fin.keele.ac.uk

Norman Bridges (Lead contact for IT), Head of System,  Phone: 33073 Email: n.w.bridges@isc.keele.ac.uk

Planning and Academic Administration Directorate

Jen Paddison,  Governance Officer,  Phone: 33655  Email: j.a.paddison@uso.keele.ac.uk

Central Facilities Management Directorate

Natalie Simpson, HR and Training Manager, Phone: 34013  Email: n.c.simpson@kfm.keele.ac.uk

Marketing & Communications Directorate

Sue Jukes, PA to Director of Marketing & Communications, Phone: 33997  Email: s.d.jukes@acad.keele.ac.uk

Research Services

Nicola Leighton, Research Governance Officer,  Phone: 33306  Email: n.leighton@uso.keele.ac.uk

Library

Paul Reynolds, Librarian, Phone: 33238  Email: p.r.reynolds@lib.keele.ac.uk

Faculty of Health

Vanessa Hooper, Curriculum Project Officer, Phone: 34678  Email: v.a.hooper@hfac.keele.ac.uk

Faculty of Natural Sciences

Ximena Canter, Faculty Business Manager, Phone: 33344  Email: x.k.canter@natsci.keele.ac.uk

Faculty of Humanities & Social Sciences

Caroline Merritt, Senior School Manager, Phone: 33452  Email: c.merritt@pol.keele.ac.uk

What support is available to those carrying out EIAs?

To support staff around the University to complete EIAs, the University has developed a standardized on-line EIA completion process.  In addition, online training is provided to introduce the concept and application of EIA, and to give an overview to the legal context for this.  The online training and online completion tool are both available to agreed nominated contacts within each Faculty and Directorate.  Further EIA practice development workshops are available to all colleagues, including those who may not be registered for the online training. 

Introductory guidance has been produced on completing EIAs.  This is a good starting point for anyone leading or involved in conducting an EIA.  If you require this guidance please contact Colette Smallwood at c.a.smallwood@per.keele.ac.uk

Further information and support can also be obtained via the Resources section of this website:  These include:

• EIA Top Tips

• EIA Process and Outcome Flow Diagrams

• Screening Aides

• Completing an EIA: Frequently Asked Questions

If you require any of this information which is not downloadable from the website, please contact Claire Norris at c.h.norris@per.keele.ac.uk

The online completion tool also contains a number of further resources which may be of use to those completing the EIAs, including:

• EIA examples from other organisations

• Keele specific or sector related publications and

• Staff, student or sector related management information and data

All Faculties and Directorates have their own lead contact.  If you have a policy or practice which needs an EIA, this person should be informed of the required EIA, so that they can work with you to ensure this is completed as appropriate:

HR, Organisational Development & Student Support Directorate

Lindsay Fleetwood, Human Resources Officer, Phone: 33549 Email: l.fleetwood@per.keele.ac.uk

Finance & IT Directorate 

Lee Bestwick (Lead contact for Finance), Systems & Project Accountant, Phone: 34387  Email: l.a.bestwick@fin.keele.ac.uk

Norman Bridges (Lead contact for IT), Head of System,  Phone: 33073 Email: n.w.bridges@isc.keele.ac.uk

Planning and Academic Administration Directorate

Jen Paddison,  Governance Officer,  Phone: 33655  Email: j.a.paddison@uso.keele.ac.uk

Central Facilities Management Directorate

Natalie Simpson, HR and Training Manager, Phone: 34013  Email: n.c.simpson@kfm.keele.ac.uk

Marketing & Communications Directorate

Sue Jukes, PA to Director of Marketing & Communications, Phone: 33997  Email: s.d.jukes@acad.keele.ac.uk

Research Services

Nicola Leighton, Research Governance Officer,  Phone: 33306  Email: n.leighton@uso.keele.ac.uk

Library

Paul Reynolds, Librarian, Phone: 33238  Email: p.r.reynolds@lib.keele.ac.uk

Faculty of Health

Vanessa Hooper, Curriculum Project Officer, Phone: 34678  Email: v.a.hooper@hfac.keele.ac.uk

Faculty of Natural Sciences

Ximena Canter, Faculty Business Manager, Phone: 33344  Email: x.k.canter@natsci.keele.ac.uk

Faculty of Humanities & Social Sciences

Caroline Merritt, Senior School Manager, Phone: 33452  Email: c.merritt@pol.keele.ac.uk

What training is available?

EIA Training: Online

Online training is available to those staff who have been chosen and registered as agreed EIA contacts for that Faculty / Directorate.  The online training provides a clear but concise overview of the legislation behind EIAs, and the process itself, including why it is important and the key stages involved.  Typically it takes around 1 hour to complete this training.

Once HR have been notified of nominations, those nominated EIA contacts will automatically be registered for access to this training and will be notified via email.  Upon completion of the online training staff will be ready to start conducting an EIA.

EIA Training: Practice development workshops

Further practice development workshops are also available to all staff who want more practical hands-on experience following the on-line training, or for those staff who are not registered to access the on-line training.  These sessions last 2.5 hours and provide the opportunity to work through the EIA process using real policies/practices, as well providing the opportunity for trouble-shooting any practical issues people may be experiencing or anticipating in completing EIAs. 

Please see details of EIA Practice Development Workshops  for further information

Where can I get further information?

For further information about any aspect of the EIA process or the University’s approach to embedding EIA's, please contact either:-

Bal Everitt, Equality & Diversity lead, b.everitt@per.keele.ac.uk or on 01782 733807

Colette Smallwood, Equalities Administrator,s.s.hewawellalage@keele.ac.uk, or on 01782 733407