Equality Impact Assessment Debt Management Policy

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1 Equality Impact Assessment Debt Management Policy 1 State which function you are assessing and identify who should be involved in the equality impact analysis Policy/Service Area Selected The Policy to be assessed is the Council s Debt Management Policy This sets out the Council s approach to the management of debt owed to the Council It sets out how the Council will work with its customers to raise and collect debt What function, policy, procedure or practice is being assessed? The Corporate Debt Management Policy Who is responsible for it? Council or Other Organisation/Partnership? The Council is responsible for implementing the policy What are the aims and objectives of the function, policy, procedure or practice? There are many different Services collecting income from the public for a variety of reasons This policy was developed to facilitate a more efficient and holistic approach to debt recovery It outlines the Council s approach to the billing, collection and recovery of monies due to the Council The functions involved include: Council Tax - the charge payable on all domestic properties in the borough Business Rates - the charge payable on all commercial properties in the borough Sundry Debts - the fees and charges made for a wide and varying range of Council services Housing Benefit overpayments - occurs when the benefit paid and the claimant is not entitled to some or all of it The objectives of the policy are:- To provide a consistent, corporate approach to the pursuance of debt owed by a customer to the Council; To imp improve the levels of income collected by the Council and reduce levels of debt; To understand and consider the customers circumstances and ability to pay and make repayment arrangements which help them to pay the amounts they owe in a timely manner

2 Who are the key stakeholders? The key stakeholders are:- Officers and elected members of Rochdale MBC This will include staff within Revenues & Benefits, Economic Affairs and Social Care; Residents of the borough who may be in debt to the Council; Other members of the public who may be in debt to the Council; Organisations who may be in debt to the Council; Organisations, such as the Citizens Advice Bureau, who are involved in working with individuals in the community who may be facing financial difficulties Lead Officer for this analysis (ie service manager who will co-ordinate the EIA) This EIA has been completed by with the actual policy developed by Sarah Tonge Others consulted and involved in the analysis (ie colleagues/peers/key internal and external stakeholders) A formal consultation exercise was undertaken, which allowed all interested parties the opportunity to share their views on the policy and its appropriateness Various council services were consulted in drafting the policy with each Service having an idea of the customers who are subject to recovery proceedings Services consulted included Adult Care, Children s Social Care, Revenues & Benefits, Finance and Legal In addition and to inform this assessment a number of external organisations were given the opportunity to consult on the policy These included the Citizens Advice Bureau and Metro Moneywise Other consultees within the Council included Economic Affairs and Community Safety Best Practice within other authorities was also considered 2 Identify the scope of the equality impact assessment Please provide a summary of: What is to be included in this impact assessment/what issues will you consider? ie are all aspects of the policy/service to be covered or is it confined to a limited area? Please explain This is likely to reflect the relevance to equality of different aspects Does this service/policy have link to other service areas, or other Equality Impact Assessments?

3 All aspects of the policy will be considered with each of the protected groups set out below being considered in terms of the polices impact on them The Debt Management Policy will impact on those Services which work closely with the most financially vulnerable From a Rochdale MBC perspective, this will relate primarily to Adult and Social Care The Policy links to the Financial Inclusion Policy and the Child Poverty Strategy In general terms the Welfare Reform changes may impact on individuals ability to pay their debts As such, the policy cannot be considered in isolation from this 3State the data that you have considered for this assessment and any gaps in data identified What action will be taken to close any data gaps? 1) Census Data This data was published in July 2012 and represents the most up-to-date snapshot of the Borough s population 2) Research into Financial Exclusion in Rochdale Rochdale MBC had commissioned Community Finance Solutions to look into the extent of financial exclusion within Rochdale MBC and they produced a report in March 2011 Financial exclusion leads to those households being at risk of over indebtedness and potentially reduces their disposable income The report estimated that 60% of residents within the borough have no savings It also highlighted that that more than one in three (36%) had fallen behind with the payment in one or more bill in the past two years The report recommended that RMBC developed a corporate debt policy that takes all the debt owed to council into account It added that this should include a clear and explicit recognition of the importance of facilitating access to advice whilst being sensitive to the needs of the debtor 3) An Introduction to Welfare Reform and the Impacts on Rochdale Borough This document was compiled in November 2012 by Rochdale MBC and gives a detailed assessment of the likely impact of changes to the local communities brought on by the Welfare Reform agenda It identifies the following 3 groups as being most at risk from the imminent changes: Mosaic Type I42 south Asian communities experiencing social deprivation; Mosaic Type O67: Older tenants on low rise social housing estates where jobs are scarce; and Mosaic Type O69: Vulnerable young parents needing substantial state support

4 4 Assess the impact the policy/service has on equality will reference to different groups or communities To do this, consider the questions on page 5 of the guidance, which relate to unequal outcomes or disadvantage; access barriers; unmet needs; encouraging participation; fostering good relations The Equality Impact Assessment Checklist may also be helpful at this stage Race Equality In relation to Rochdale Borough, the 2011 Census confirms the following data on ethnicity The overall population of Rochdale Borough is 211, 699 Of these, 166, 481 are classified as white British (79%); and 45,218 (21%) as BME BME groups now account for a greater proportion of the population than was the case in 2001 Pakistani is the largest population among the BME groups and now accounts for 105% (22,265) of the total population in 2011, having grown by over 40% over the past decade The largest mosaic group currently claiming Council Tax and Housing Benefits is I42 (south Asian communities experiencing social deprivation); this group accounts for 15% of claimants of these benefits It could be assumed that this group may then experience difficulties in paying debt However, the Financial Exclusion Report identified that Asian Households tended to be less financially excluded than other groups All members of the community will need to have the same access and understanding of the debt management policy Some customers may have English as a second language so there is a need to ensure that all written communication should be in plain English The council does provide a translation service for those in need and the policy can be provided in other formats/languages as required Disabled People In relation to Rochdale Borough, the 2011 identified that 44,359 (21%) of the overall population stated that they are disabled or their activities are limited due to a healthrelated issue This represents an increase of 48% from 2001 Rochdale Borough has higher rates of residents noting a long-term health problem or disability when compared to Greater Manchester or England and Wales In general terms, therefore, the levels of disability and associated health issues are acknowledged to be of relevance to this Borough The Financial Exclusion review identified that in the last two years 51% of disabled people had fallen behind in making payments against their bills 22% of disabled people problems with managing money and debts have caused problems with finding or keeping a job It is also acknowledged that disabled people will be impacted by changes to the Welfare Reform agenda Projected spending on working age Disability Living Allowance in the Borough is to be cut by 20% by 2015/16 Up to 3,139 claimants may

5 be moved onto Job Seekers Allowance as a result of the Work Capability Assessments; the amount lost would depend on the age of claimants and would lie between 46 million and 7 million A report by MIND, entitled Still in the Red, identified that there are well established links between debt and mental health, with 1 in 4 adults with a mental health problem living with debt In addition disabled people may face greater barriers to employment and therefore this could impact on their ability to generate a regular income Furthermore there are potential issues with access to the policy Customers with a visual disability may have difficulty reading the policy and any reminder letters issued as a result of any debt recovery processes Deaf / hard of hearing customers may also face difficulties where officers are providing advice on debt Carers The 2011 Census confirms that the provision of more than 20 hours per week of unpaid care has increased in the Borough since 2001 The overall rate of unpaid care is higher in the Borough than both the regional and national levels Almost 2% of residents now provide hours of unpaid care each week, which is a 352% increase in 10 years A further 29% provide 50+ hours each week, a 27% rise over the past decade Fewer residents now provide 1-19 hours of unpaid care per week in the Borough In general terms, therefore, the rising numbers of unpaid carers are acknowledged to be of relevance to this Borough It is possible that carers may be particularly affected by Welfare Reform changes, for instance in relation to under-occupancy Where a disabled person has a partner / carer who has hitherto slept in a separate room, this may have a financial cost to them in future An estimated 2,552 under-occupiers have been identified in Rochdale Borough If affected, their benefits will be reduced by an average rate of 14 a week Carers may be the main point of contact when officers are trying to recover debt and it will be necessary to explore ways to support them with the opportunity of involving The Carers Resource Gender The 2011 Census provides the following breakdown of figures for the Borough: there are 103,642 males (an increase of 39% from 2001, when there were 99,705); and there are 108,057 females (an increase of 23% from 2001, when there were 105,652) The policy will affect anyone in debt to the Council regardless of gender This policy is unlikely to impact adversely on customers because of their gender

6 Age The Census 2011 gives the following breakdown of the Borough s population by age: Age group No in 2011 %age in 2011 Proportional change from , % , % , % , % , % Totals 211,619 These figures indicate that the Borough has a growing number of (i) young adults and (ii) persons aged The Financial Exclusion report raised no particular concerns with pensioners They identified that whilst they were likely to be unbanked and to be struggling with their fuel bills, few used pre-payment meters and few resorted to sub-prime credit They were also more likely to save than other groups Religion or Belief The 2011 Census confirms the following religious groups in the Borough: Christian (128,186, or 606%, a decrease of 115% since 2001) No religion (40,014 or 189%, an increase of 81% from 2001) Muslim (29,426 or 139%, an increase of 45% from 2001) Rochdale s proportion of Muslim residents exceeds the comparative figure for Greater Manchester (87%) and also England and Wales (48%) The policy will affect anyone in debt to the Council regardless of their religion This policy is unlikely to impact adversely on customers because of their religion Sexual Orientation The 2011 Census does not record this data directly, and there is no reference to this in Rochdale MBC s Introduction to Welfare Reform The proposed policy does not impact on Sexual Orientation any more than other groups of applicant Gender Reassignment The 2011 Census does not record this data directly, and there is no reference to this in Rochdale MBC s Introduction to Welfare Reform The proposed policy does not impact on gender reassignment any more than other groups of applicant There are no specific access issues relating to gender reassignment

7 Pregnant Women or Those on Maternity Leave who have given Birth in the Previous 26 Weeks The 2011 Census does not record this data directly, and there is no reference to this in Rochdale MBC s Introduction to Welfare Reform The proposed policy does not impact on pregnant women any more than other groups of applicant There are no specific access issues relating to pregnant women Marriage or Civil Partnership The 2011 Census shows that there are now fewer people in the Borough living as a married couple In 2001, 403% of the population were not living as a couple and that figure has risen to 444% in 2011 The prime reason for this is that a higher percentage of people are now living as single, the number of people living as single has risen by 238% over the past decade and increased by 39% proportionally There are now 5,625 fewer people in the Borough living as a couple in a married or civil partnership than in 2001; this equates to a drop of 74% This is a proportionally greater decrease than across Greater Manchester (31%) and England and Wales (1%) The Financial Exclusion report highlighted that lone parent households are the most likely to be in debt and to resort to sub-prime borrowing, this group was among the most excluded Ex-Armed Forces Personnel The 2011 Census does not record this data directly, and there is no reference to this in Rochdale MBC s Introduction to Welfare Reform The proposed policy does not impact on ex armed forces personnel any more than other groups of applicant There are no specific access issues relating to ex-armed forces personnel 5 Conclusions and Recommendations What are the main conclusions from this analysis? The impact of the policy is more related to those economically disadvantaged people as it is fiscally based Amongst this group, disabled people who are faced with the additional costs of living face particular difficulties Their situation may be added to by the Welfare Reforms One other group identified as being potentially affected are carers There are opportunities here to develop and build operational relationships between the Debt Management Teams and the Carers Resource At every stage of the development of the policy the views of stakeholders have been considered and the policy has been developed and refined to reflect the feedback obtained As a direct result of this equality impact analysis a number of minor changes have been made to the policy

8 This policy will promote support for customers with debts who face a genuine hardship by guiding them to appropriate help and providing a flexible approach to take into account the needs of disadvantaged groups/individuals However, this will not preclude the Council from taking a robust approach where there is found to be an ability to pay All members of the community will need to have the same access and understanding of the Debt Management Policy What are your recommendations? See Action Plan below Equality objectives and targets to address the unequal impact/unmet needs/barriers/low participation See Action Plan below Suggested actions to meet those targets See Action Plan below 6 Consult your stakeholders on the main findings and conclusions of the equality impact analysis and ask for their comments State your consultation and inclusion methodology The Consultation and Inclusion Methodology Used Consultation to date has mainly involved Council Services whilst developing the policy Consultation will continue to be undertaken with appropriate parties when the policy is introduced

9 7 Produce a mitigation action plan for 2013/14 to address any potential unequal impacts / unmet needs/ barriers / low participation Details of this should be included in your service delivery plan 8 Equality impact analysis sign off Name Position Date Sally Atueyi Lead Policy Officer 12/7/13

10 Equality Impact Assessment Action Plan 2013/14 Action Outcome Target Date For Completion Resource Implications Lead Officer To contact the Carers Resource to ascertain if they would provide carer awareness sessions to those Debt Management Teams To develop operational relationships between the Debt Management Team and the Carers Resource To develop a referral pathway to the Carers Resource To obtain more data on the causes and Those involved in recovering debt will be more aware of the issues faced by carers This will ensure that carers views and the vulnerable people that they support are considered This will ensure that Carers are adequately supported This will ensure that the Council understands the November 2013 November 2013 November 2013 December 2013

11 impact of debt on individuals and the community To seek ongoing feedback from those organisations / Council Services who work most closely with the client groups This feedback will be incorporated into the monitoring of the scheme financial hardship arrangements some customers face To ensure an effective channel of communication is in place which gives feedback on the policy; and to determine whether it has caused any financial difficulties December 2013 To provide the policy in alternative formats and languages where required This will ensure that language barriers etc are not an issue for customers On going

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