ONS Equality Scheme ONS Equality Scheme. Version 8

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1 ONS Equality Scheme Version 8 1

2 Contents Foreword by National Statistician 1 Key points 4 2 Introduction 5 3 About ONS 11 4 ONS as an employer 18 5 Equality impact assessments 22 6 Governance, monitoring, reporting and reviewing 26 This document should be viewed with the following companion annexes. Annex A ONS impact assessment priorities 29 Annex B Roles and responsibilities relating to ONS 35 equality and diversity Annex C ONS equality impact assessment framework 37 Annex D ONS equality and diversity action plan 39 2

3 Foreword by National Statistician ONS is committed to valuing diversity and promoting equality in the way it does business as a statistics office and as an employer. We aspire to demonstrating best practice in the way we do this beyond merely meeting our statutory equality duties. As a statistics office, our mission is to improve the understanding of life in the UK and enable informed decisions through trusted, relevant, and independent statistics. Understanding equality and diversity is a key part of life in the UK and ONS has an important role to play in improving this understanding. Better measurement of equality is a challenge that needs to be addressed if we are to provide an evidence base for developing and assessing policies and allocating resources. ONS published a cross-cutting review of equality data needs across government in October 2007 that identified the challenges of improving equality data sources, analysing data and making it more accessible to users. Implementation of the recommendations from the review will be monitored by a cross-government group which I will chair. As an employer, our vision is that ONS will be regarded as an employer of choice and will be recognised as a great place to work and thrive for all, regardless of age, disability, gender and gender identity, ethnicity, religion, sexual identity and work-life balance needs. At the same time, we believe equality and diversity are everyone s business regardless of background. While progress has been made, in particular through the valuable contributions made by ONS s diversity networks and champions, this scheme recognises that there is more to be done to build a culture and environment in which all members of our workforce recognise that diversity is valued. In particular, we aim to demonstrate statistical leadership in monitoring the workforce and developing a process for carrying out equality impact assessments in ONS. As head of ONS, I am committed to making a reality of the aspirations set out in this Equality Scheme. It is an important step towards promoting greater equality of opportunity for all. I will ensure that the ONS management board routinely considers progress towards meeting the equality and diversity objectives set out here and consistently addresses obstacles to progress. 3

4 1 Key points This equality scheme is both a description of how ONS plans to meet its statutory equality duties as a public authority and a commitment to achieving best practice in promoting equality and eliminating discrimination and harassment It is a single comprehensive scheme with the intention of promoting equality in its widest sense, in relation to age, disability, ethnicity, gender and gender identity, religion/belief, sexual identity and work-life balance The equality and diversity objectives described in this scheme are consistent with the ONS Vision, Values and Strategic Objectives, and in particular should be seen as an elaboration of our commitment to respect as a core value While ONS s equality duties to its workforce are very important, we recognise that as the UK s statistics office the ONS also has a vital role to play in promoting equality across the UK through statistics which are key to measuring equality Promoting equality is core to the expectations ONS staff should have of ONS as an employer, and in the expectations ONS has of its workforce Equality impact assessment is the mechanism through which ONS will mainstream its equality and diversity objectives in the way it carries out its business and manages its staff ONS has developed a new governance structure for steering equality and monitoring the effectiveness of the scheme and associated actions towards promoting equality ONS has: - an assessment schedule in which its back catalogue of functions, policies, practices and projects are prioritised for equality impact assessment, and - a prioritised action plan which will enable ONS to promote equality and eliminate discrimination and harassment 4

5 2 Introduction 2.1 This document ONS is committed to promoting equality for all groups and eliminating discrimination and harassment both in its role as the UK s statistics office and as an employer. This document should be seen in this context. It is both: ONS s response to the statutory duties to develop and publish equality schemes for gender, race and disability, demonstrating how we deliver on our general duties under equality legislation, and an expression of ONS s commitment to going beyond the statutory duties in pursuit of best practice This document describes the context, strategy and a set of actions to enable ONS to meet its equality duties. 2.2 egislative framework General statutory duties The responsibilities of public authorities regarding equality are set out in legislation and statutory codes of practice relating to the: Equal Pay Act 1970 Sex Discrimination Act 1975 Race Relations (Amendment) Act 2000 (RRAA 2000) Disability Discrimination Act 2005 (DDA 2005), and Equality Act 2006 (EA 2006) The core general duties are similar for disability, gender and race, to give due regard to the need to: promote equality of opportunity between equality groups, and eliminate unlawful discrimination and harassment (as defined in the legislation and including for example discrimination on the grounds of gender reassignment) However, there are important areas where there are different legislative requirements in addition to the general duties. For race (RRAA 2000) There is an additional requirement to promote good relations between people of different racial groups. 5

6 For disability (DDA 2005) There are additional requirements to: promote positive attitudes towards disabled people encourage participation by disabled people in public life, and take steps (or make reasonable adjustments) to meet disabled people s needs, even if this requires more favourable treatment ONS will also meet our general employment duties for age, sexual orientation and religion/belief as set out in the following legislation: Employment Equality (Age) Regulations 2006 Employment Equality (Sexual Orientation) Regulations 2003 Employment Equality (Religion or Belief) Regulations Specific statutory duties Government departments, agencies and other public authorities have specific statutory duties to develop and publish equality schemes for gender, race and disability demonstrating how they will go about delivering their general statutory duties and employment duties. As part of the specific statutory duties on gender, race and disability equality, public authorities are required to include a statement of the authority s arrangements for assessing the impact of its policies and practices, or the likely impact of its proposed policies and practices. The codes of practice for each duty clarify that the separate schemes can form part of a general or comprehensive equality scheme. Some government departments/agencies have chosen to do this in a single equality scheme (for example Department of Health, earning Skills Council) whereas others have published three separate schemes (for example H Treasury, Department for International Development) Rationale for a single Equality Scheme We believe that ONS will be best able to make progress towards the goal of equality of opportunity and elimination of unlawful discrimination and harassment through a single Equality Scheme. We believe the advantages of a single Equality Scheme are: It brings together for the purposes of monitoring and accountability all the actions which the authority will take to promote equality of opportunity and eliminate discrimination and harassment It helps to ensure that increasing equality of opportunity for one group is not achieved at the detriment of another group It is consistent with the move to recognise that individuals can be affected by multiple equality characteristics, symbolised in the merging of the three 6

7 original equality commissions (Equal Opportunities Commission, the Commission for Racial Equality, and the Disability Rights Commission) into the single Equality and Human Rights Commission It recognises the similarity between specific duties on gender, race and disability and allows the organisation to aim higher than simply meeting the minimum standard of each individual statutory duty It facilitates promoting equality of opportunity and eliminating discrimination and harassment by extending it to equality relating to sexual orientation, religion/belief, age and work-life balance However, we recognise: It is important to ensure that the single Equality Scheme is not seen as a poor alternative to individual schemes by including the same level of information and commitments that individual schemes would have, in particular in the action plan The aim should be to publish the Equality Scheme in a way which will allow a user to pull out the sections of the scheme relating to their strand of interest, for example on disability, ethnicity or gender Procurement The legislation makes explicit reference to the requirements and responsibilities regarding procurement practices. Race Relations (Amendment) Act 2000 (RRAA) and procurement To comply with their duty under the amended Race Relations Act, all public authorities must take race equality into account when procuring goods, works, or services from external providers. Public authorities must build relevant race equality considerations into the procurement process to ensure that all of their functions meet the requirements of the Race Relations Act, regardless of who is carrying them out. The Disability Equality Duty and procurement The Disability Equality Duty applies to bodies carrying out public functions or to contractors carrying out public functions on behalf of a public authority. If a contractor is merely providing services on behalf of a public authority then the obligation to comply with the duty remains with the public authority that contracted out the function. The Gender Equality Duty and procurement Under the Gender Equality Duty, where a contractor is carrying out a public function on behalf of a public authority, the legal liability for the gender duty in relation to that function remains with the public authority that contracted out the function. 7

8 2.3 Involvement and consultation in developing the scheme The duties The three statutory duties are different in that: the disability duty requires that public authorities involve disabled people in producing the Disability Equality Scheme and that involvement should not be confused with consultation ( Doing the Duty Disability Rights Commission) the gender duty, on the other hand, requires that the public authority should, in preparing a scheme, consult employees, service users and others ( Gender Equality Duty Code of Practice (England and Wales) Equal Opportunities Commission 2006), and the race duty does not explicitly refer to consultation in drawing up the scheme, but puts emphasis on effective consultation in delivery of public functions; that public authorities must set out in their race equality scheme their arrangements for assessing, and consulting on, the likely impact of their proposed policies on race equality ( Code of practice on the duty to promote race equality Commission for Racial Equality 2002) ONS s view We consider that while involvement is a statutory requirement only for disability stakeholders, ongoing involvement of all equality-strand stakeholders in developing, monitoring, reviewing and delivering equality objectives should be the ONS s objective. How ONS has involved equality stakeholders in the development of this scheme In developing this scheme we: carried out an ONS-wide consultation exercise on an early draft of an equality scheme and used the ONS intranet to communicate changes that would be made in a further draft as a result of consultation responses set up a number of equality and diversity working groups across the ONS and asked group members to rework sections of the scheme and contribute proposals for equality and diversity actions for consideration in the action plan, and asked an editorial team to assess the effectiveness of amendments to the scheme made in response to stakeholder requests, and to propose improvements for the final working draft How ONS will continue to involve equality stakeholders in prioritising and delivering equality objectives We will continue to use a multiple approach to involve stakeholders in promoting equality in the ONS. a) We will involve our staff, experts in other parts of the public sector and other external stakeholders at key points in developing and reviewing the content of the ONS equality scheme by continuing to use the working group approach or a similar process 8

9 b) We will actively involve equality stakeholders in proposing and prioritising actions that ONS should take to improve equality, for recommendation to the relevant steering group and to quality assure reported progress against actions 2.4 Terminology Diversity and Equality The Equality Act 2006 (8 (2)) says diversity means the fact that individuals are different. The Review of Equality Data (October 2007) proposed that the definition of an equal society used in the Equalities Review (February 2007) should be amended to read (amendment shown in bold): An equal society recognises and values people s diversity their different needs, situations and goals and removes the barriers that limit what people can do and can be. Due regard and proportionality Public authorities are required to give due regard to the need to promote disability equality in its various dimensions. Due regard has two elements; proportionality and relevance. In all their decisions and functions, public authorities should give due weight to the need to promote disability equality proportional to its relevance. This requires more than giving consideration to disability equality. (Disability Rights Commission (2005) The Duty to Promote Disability Equality Statutory Code of Practice England and Wales) Equality impact assessment Equality impact assessment is the process of assessing the impact of existing or proposed ONS functions, policies, practices and projects in relation to their consequences for equality of the ONS workforce or the society we serve where: Functions include ONS s public duty to manage the census and surveys and publish analytical reports Policies include high-level strategies (for example an external communication strategy or a site strategy) and individual policies (for example a recruitment policy) Practices cover informal, undocumented way we usually do things (for example the process for handing over work responsibilities when roles change or how meetings are usually conducted) Projects cover the development of new functions and policies or developments relating to corporate services (for example the development of a new survey, a flexible working policy, IT support mechanism or a site development project) 9

10 Reasonable adjustment This is a change that a business or organisation is required to make in order that disabled employees and customers are not put at an unfair disadvantage to others as required by the duties of the Disability Discrimination Act. For a public authority, what should be considered reasonable will be determined by the type and size of the organisation, the cost of the adjustment, disruption to business while work is being carried out, practicality of carrying out the adjustment and the potential benefits to disabled customers and employees. 10

11 3 About ONS 3.1 Office for National Statistics ONS is a public authority with responsibility for producing official statistics. Until the end of arch 2008, ONS was an agency of H Treasury, reporting to the minister with the title Exchequer Secretary. With the implementation of the Statistics and Registration Services Act 2007, ONS became a non-ministerial department reporting to an independent Statistics Board and ultimately accountable to Parliament. 3.2 ONS vision and values ission why ONS exists Our mission is to improve the understanding of life in the United Kingdom and enable informed decisions through trusted, relevant, and independent statistics. Vision what we will achieve by 2012 At the heart of decision-making and opinion-forming, we will be a prestigious place to work, a world leader, innovative, geared for change and delivering more with less. Continuous improvements to our systems will allow for more analysis while maintaining the high quality of our statistics. Values shape our behaviours We embody the Civil Service core values of integrity, honesty, objectivity and impartiality. We also live by our own organisational values, which are central to delivering our vision in our own unique circumstances. We recognise and value: Respect: We respect the background and lifestyles of every colleague, their skills, contributions and potential Commitment: We are committed to high-quality statistics and analysis, professional standards, keeping data confidential, open communication, personal responsibility for delivery, and the development of personal and organisational capabilities 11

12 Flexibility: We view change as an opportunity and continually seek improvement. We have a broad corporate view and respond to the overall needs of our organisation Results: We focus on customers and suppliers and their changing needs, embedding quality into our products and processes, providing value for money and delivering our commitments ONS culture the way we do business Delivery in challenging circumstances requires consistency in the way we conduct our business. In strengthening our shared culture, we operate with: Pride: We are proud of the quality, relevance and timeliness of our outputs and the role they play in improving life in the UK Professionalism: We adhere to the Code of Practice for Statistics, the National Statistician s Code of Conduct, and relevant protocols. We pursue the highest professional standards in every part of the ONS Outward focus: We understand and adapt flexibly to the fast-changing world in which we operate. We actively seek opportunities for external engagement and positive promotion of ONS. We are transparent about the work we do and decisions we take. We minimise our impact on the environment Ambition: We search for new and innovative ways to carry out our work. We set ourselves challenging goals for the change we wish to bring about 3.3 ONS strategic principles To deliver the vision for ONS, our strategy is to transform our statistical business through a clear focus on people and support for the necessary innovation. The following are the key strategic principles which we will use in making the vision a reality. A high-performing statistical business Demand for high-quality ONS statistics will continue to grow and the resources to meet this demand are limited. To meet this challenge we will improve our performance across all parts of the business. We will: work in partnership with our key customers to understand both their current and future needs deliver a prioritised statistical work programme which evolves to meet customer needs and reflects the UK as it changes. ower priority activity may need to make way to address new demands devote a greater proportion of resources to adding value by analysing the data, improving accessibility and producing easy-to-read reports 12

13 undertake high-quality data collection, emphasising improved efficiency through the use of administrative data, streamlined survey design and integrated sources improve respondent trust and goodwill through efficient survey design and developing collection methods standardise our processes, systems, and tools where there are business benefits in doing so, and strengthen the way our statistical directorates and our corporate services work together Statistical leadership Independence will increase the prominence of the ONS. We will: work with partners to improve the trust in statistics establish statistical standards and best practice to provide a framework for quality production of official statistics be active participants in the key statistical activities of the EU, UN, OECD and other international organisations, and maintain formal and informal contacts with other statistics producers to promote our own best practices and to learn from others A clear focus of people In our constantly changing environment, our abilities to make difficult decisions, manage change, and to lead, manage and support others will be critical to our success. We will: enhance our employee policies and practices to allow us to retain and recruit the staff we need develop our skills and competences to undertake our roles more effectively and better equip us to embrace and deliver change develop our capabilities to provide the right mix of expertise to deliver the business recognise those who uphold our values recognise the value and importance of a diverse workforce that feels valued for its contribution treat people with respect and dignity, and communicate more effectively, engage more fully, listen and seek feedback People leadership Strong leadership will be essential to achieve our vision. All managers in the organisation will: build effective teams, encourage talent, motivate individuals and promote diversity be personally accountable, act corporately and deliver results communicate openly, transparently, with objectivity and consistency, whether the news is good or bad seek to improve business operations, through better use of resources and technology, and improved processes, and provide effective leadership, giving clear direction, setting objectives, dealing with difficult situations and championing new ways of working Senior managers in the organisation will be visible and available to staff. 13

14 Targeted innovation Innovation is essential for us to thrive in a fast-changing world. We must constantly review what we produce, and how we produce it. We will: focus on innovation that produces cash savings to reinvest in meeting new demands, or that builds on the quality of our outputs build a framework to encourage and deliver innovation, allocating a proportion of our budget for new developments encourage ideas to be put forward and strengthen the skills required to translate innovative ideas into business benefits, and work with partners who can add to our knowledge 3.4 ONS public functions The ONS carries out a range of public functions, summarised below. We have a wide range of customers including central and local government, academics, the wider public and international bodies. Our statistics and reports are published on the National Statistics website The census (England and Wales) We carry out the ten-yearly census which goes to every household in England and Wales. We report the results and publish analyses using the census data. We work with the census offices of Scotland and Northern Ireland to ensure consistency across the UK. Household and business surveys We carry out a number of our own surveys to households (for example, the Integrated Household Survey) and businesses (for example, Annual Business Inquiry, Annual Survey of Hours and Earnings). We report the survey results and publish analyses. We carry out surveys on behalf of other organisations (for example the Disability Survey for the Office for Disability Issues). We lead consortia of organisations for funding cross-cutting surveys. 14

15 National Accounts and related statistics We compile and publish the UK s National Accounts, which provide estimates of UK economic growth. We additionally compile and publish estimates of short-term economic growth and environment accounts. Further analysis and research We carry out and publish reports from a range of further analyses and research projects drawing on our own data sources and other government and non-government data sources. These include reports on: Population trends Health statistics Social trends Regional trends Economic and labour market trends Other economic analyses Productivity of public services Survey and analysis expertise We are a centre of expertise for survey methodology and aspects of analysis (for example, time series), and the advice of our methodologists is sought across and beyond government. We lead the work on harmonising survey questions and outputs from surveys across government. Dissemination In addition to considerable efforts we make to ensure our own data and reports are clear and accessible, we compile and manage the Neighbourhood Statistics website. International data requirements We meet the UK s legal obligations for a range of international data requirements. We take an active role in shaping international standards, guidance and new data requirements. Statistical leadership We provide leadership for statisticians across government through the Government Statistics Service. 3.5 ONS s contribution to measuring equality in the UK ONS makes a significant contribution to the measurement of equality in the UK through a number of its functions. The census (England and Wales) Information from the census provides a benchmark for a number of equality characteristics in the population. In addition, the Code of Practice on the duty 15

16 to promote racial equality explicitly encourages public authorities to use the Census 2001 ethnicity classification for monitoring purposes. Household and business surveys ONS surveys are considered by government departments to be primary sources of data for monitoring a number of aspects of equality in the UK: The Annual Survey of Hours and Earnings for the gender pay gap The abour Force module of the Integrated Household Survey for inequality in employment, use of childcare, job tenure and provision and take-up of flexible working The Integrated Household Survey in combination with registration data for inequality in life and health expectancies Collecting information on sexual identity ONS is an international leader in the development of questioning on sexual identity. The objective of the current project is to develop questioning which could be used in household surveys to collect information on sexual identity. Statistical leadership on measuring equality The ONS led a cross-government review of equality data needs and published a report from the review in October The review made a number of recommendations including: A number of recommendations to strengthen the coherence of data on equality A number of recommendations for filling data gaps A number of recommendations for improving data accessibility and presentation Setting up of a high-level cross-government group to monitor implementation of the further recommendations in the review and to ensure that equality evidence base is fit for purpose for current and future data needs. This group has now been set up and is chaired by the National Statistician. Its terms of reference are to report on progress against recommended actions and to take a strategic overview across equality data collection. 3.6 ONS policies and practices as a statistics office National Statistics. Our statistical outputs are produced according to the National Statistics Code of Practice for Statistics and relevant protocols. Internal policies and practices. ONS has a number of internal policies which determine how we go about producing statistics in practice and how we provide the corporate services needed to support the production of statistics. These are: External communication policies (publications, website, etc) Internal communication (intranet, cascade systems) 16

17 Procurement policy Information anagement policies Facilities policies Employment policies International standards and guidance. Some parts of our business are carried out within an international framework. For example: The compilation of the UK National Accounts is carried out according to international guidelines to ensure comparability (System of National Accounts 1992) Procurement and partnership The ONS spends part of its overall budget on externally purchased goods and services, most particularly services. We also frequently work in partnership with other organisations. We recognise the importance of best practice in procurement and partnerships for meeting our statutory duty to promote equality. 3.7 ONS s commitment to its customers Our customers can expect the ONS to: continue to develop data sources which contribute to measuring equality give due regard to the accessibility of statistics and reports for diverse users, and consult, listen to and involve a wide range of equality stakeholders in identifying future needs for equality data 17

18 4 ONS as an employer 4.1 What staff can expect from the ONS Staff can expect that ONS will: keep their personal information confidential treat them fairly and in line with our statutory legal duties and ONS employment and HR policies make sure everyone has the opportunity to engage in learning and development with relevance to equality give every staff member equal opportunity for training, development and promotion, and make sure our recruitment, performance management and promotion processes are open and clear give all staff the information/training and support they need to understand the legal requirements of them, to promote equality of opportunity and recognise and eliminate bullying and harassment, and offer staff safe communication channels to raise equality issues and problems 4.2 Equality and diversity learning and development To effectively eliminate discrimination and promote equality of opportunity we recognise that our employees need the appropriate knowledge, skills, confidence and resources. We offer staff a number of different ways of ensuring that they understand the expectations ONS has of them with regard to equality. These include: andatory Diversity Awareness training for new starters Diversity Awareness sessions for other staff E-earning on equality and diversity Refresher sessions Coaching for those with specific responsibilities relating to equality and diversity, for example diversity champions and network chairs ONS recognises that the learning and development needs of its staff change throughout their careers. Equality and diversity learning and development needs of staff are regularly identified in discussion with their line managers and recorded in a Personal Development Plan which all staff are required to have. 18

19 4.3 ONS s expectations from its staff We expect our staff to: treat each other and with respect and dignity, in their daily working life contribute to progressing their business areas equality and diversity objectives include at least one personal equality and diversity objective in their own performance agreements (which may relate for example to a contribution to their business areas assessment schedule for equality impact assessment, a role in diversity networks, an aspect of staff management, a contribution to corporate policies which impact on equality) take responsibility for their own learning and professional development, and where applicable the learning and development of their staff, making good use of the opportunities and resources on offer, and act in line with equality legislation addressed in Human Resources and other policies We encourage staff to contribute in progressing the wider equality objectives of the office by recording their personal information for monitoring purposes. 4.4 onitoring workforce diversity ONS collects data on equality and diversity relating to the majority of our workforce to: monitor progress towards targets assess the impact of changes in employment policies and practices identify discrimination, and assess equality of opportunity in learning and development To enable us to do this, we are reliant on: the goodwill and commitment of staff in recording their personal information on the ONS people management database, and the goodwill of applicants to the ONS Staff can expect that ONS will keep their personal information confidential. Employee data is analysed by the Equality and Diversity onitoring Group on a quarterly basis and disaggregated by each equality strand, grade and directorate. The report provides information about recruitment, staff currently in post, applications for and receipt of training, disciplinary procedures, and staff leaving employment. A report will be published annually with data summarising our progress towards our diversity targets and ONS will take care to ensure that the data do not allow the identification of individuals. 19

20 4.5 Progress to date on equality in employment The action plan accompanying this scheme demonstrates the commitment of ONS to promoting equality and the challenges ahead for ONS as an employer. There is, however, progress to report since the publication of our first Race Equality Scheme in In particular significant progress has been made in two key areas. We have strengthened our arrangements for governing and delivering our equality and diversity programme which benefits our approach to all equality groups. We have: increased the visibility of the ONS diversity champion and site champions and clarified their roles established and supported a range of staff diversity networks and identified chairs and sponsors for a number of them raised the understanding of the importance of equality and diversity through a diversity forum carried out an accessibility review of all the buildings we occupy. Actions are underway to ensure all our buildings are accessible to disabled people as required by the Disability Discrimination Act continued to offer diversity awareness to our staff on the implications of the legislative framework supporting equality, and developed a system for ensuring reasonable adjustments are made for all new and existing disabled employees We have improved our systems for gathering and interpreting information relating to the recruitment, retention and development of our employees by disability, ethnicity, age and gender and flexible working arrangements, and identified further data needs in this area. We have: adapted systems to use Census 2001 categories to monitor ethnicity improved the equal opportunities data which is collected on applicants to the ONS and automated transfer of this information onto the ONS people management database introduced monitoring at all stages of our external recruitment campaigns introduced learning and development monitoring in the ONS people management database introduced monitoring of exit information, and introduced monitoring of performance reviews 4.6 Employment policies and practices The ONS has a range of policies and practices covering the way it operates as an employer. These fall under the broad headings of: Recruitment policy including probation earning and development strategy and policy 20

21 Equal opportunities/diversity policy which includes bullying and harassment and complaints procedures Hours and leave including flexible working, home-working, maternity, paternity, adoption, special leave and sick absence Performance management/promotion Pay and pensions General conduct including discipline and inefficiency procedures Grievance Retention, resignation and redundancy Security covering data, personnel, document and physical security Welfare including health and safety, stress, gender identity and reassignment policies Communications Travel and subsistence 21

22 5 Equality impact assessments 5.1 What is equality impact assessment? As part of the specific statutory duties on gender, race and disability equality, public authorities are required to include a statement of the authority s arrangements for assessing the impact of its policies and practices, or the likely impact of its proposed policies and practices. Impact assessment is the process of assessing the impact of existing or proposed public functions, policies, practices and projects (FPPPs) in relation to their consequences for equality. It should be an ongoing approach, way of thinking and process embedded in projects and development practices, not a bolted on activity which happens at the start or end of the development of a new function, policy or practice. The purpose of equality impact assessment is to achieve equality improvements by identifying and removing or reducing barriers to equality and/or maximise positive impact for equality so, in most cases, effective impact assessments are likely to require actions to bring about greater equality. The organisation is required to act proportionately in relation to issues identified in the assessment so it may not always prove possible to remove negative impacts of FPPPs. 5.2 Principles underlying equality impact assessment in the ONS In line with best practice, ONS is committed to: mainstreaming equality impact assessment in the way we do business, and assessing the impact of its FPPPs on equality in relation to age, gender and gender identity, disability, ethnicity, religion/belief, sexual orientation and work-life balance (in relation to employees and on the wider population we serve) 5.3 Initial screening of ONS FPPPs Initial screening has been carried out on existing ONS FPPPs and will be carried out on new ONS FPPPs to: prioritise impact assessments for our back catalogue, and 22

23 ensure impact assessments are carried out where appropriate for new FPPPs We will prioritise our existing FPPPs against the following criteria: The FPPP is a major one and we have regarded it in terms of the significance for the ONS activities in terms of: - the number of people affected (both our employees and the wider customers we serve), - the nature of the impact on people under the relevant strands - scale and cost, and - Profile in terms of coverage in the media There is a clear indication that, although the FPPP is minor, it is likely to have a major impact on equality in terms of: - numbers of people affected, and - seriousness of likely impact In general, where there is doubt, we have and will continue to apply the precautionary principle in deciding whether a FPPP requires impact assessment. This initial screening process has enabled us to prioritise impact assessments as shown in the current assessment schedule in Annex D of this scheme. 5.4 ONS equality impact assessment This section provides an overview of the current ONS guidance for carrying out equality impact assessments (EIAs). The full guidance can be found on the ONS intranet. Questions ONS EIAs address, as an example, are as follows: What kind of equality impact might there be? How significant is it in terms of its nature and the number of people likely to be affected? For which equality groups will there be an impact? And is the impact negative or positive (or is there potential for both)? On what aspects of the equality duties will this impact be? (Promoting equality of opportunity? Eliminating unlawful discrimination? Eliminating equality related harassment? Promoting positive attitudes to different equality groups? Encouraging participation of different equality groups in public life? Taking steps to meet disabled peoples needs, even if this requires more favourable treatment?) Could the impact actually be unlawful, for example constituting unlawful discrimination? What further information is required to gauge the probability and extent of the impact? What does the evidence tell us about the probable impact on different equality groups? 23

24 What action do we need to take to reduce negative impact or increase positive impact? If this action does not mitigate fully against negative impact, what is the justification for this? When and how will we know the actual impact of the new FPPP or of actions taken relating to new or existing functions, policies and practices? 5.5 ainstreaming ONS equality impact assessments As shown in the action plan, we will put in place a number of changes to achieve the objective of mainstreaming the process of equality impact assessment including: Working towards embedding EIAs in ONS project management practice A report on initial screening for equality impact will be required in all ONS project initiation documents and, where projects are judged relevant, milestones for carrying out different parts of equality impact assessment must be included in project time plans The ONS project management course will include a module on equality impact assessment for projects. Working towards increasing ONS capability and reducing reliance on external experts Working towards the objective of EIAs being carried out solely by ONS staff (both from inside and outside the business area involved) with small teams brought together for the time of the assessment Including a requirement for EIA consultants, where they are used, to train ONS staff alongside carrying out assessments Including a module on equality impact assessment in the mandatory diversity training for all new staff Developing EIA courses for staff who will be taking part in EIAs Encouraging staff to take part in EIAs in their own or other areas for personal development and evidence of meeting equality and diversity personal objectives Requiring line managers to give due regard to staff requests to take part in equality impact assessments as part of personal development Reducing reliance on ad hoc consultations In line with guidance (Disability Rights Commission Disability equality impact assessment and Disability Equality Duty p40), ONS will not require 24

25 a consultation with equality groups as a mandatory stage of EIAs where other appropriate sources of information already exist Representatives from staff equality groups will be invited to form part of the membership of an impact assessment panel to provide guidance to assessment teams As a statistics office, ONS is ideally placed to build an ongoing evidence base from a wide range of data sources, including the outcomes of previous consultations, which can then be used in subsequent assessments ONS has a range of professional experts on a number of areas of equality whose expertise could also be sought as part of gathering evidence The wider mainstreaming of equality and diversity across the ONS will also increase the equality knowledge and expertise across business areas 25

26 6 Governance, monitoring, reporting and reviewing 6.1 Governance and responsibilities The fundamental principle underlying ONS s strategy for meeting corporate equality and diversity objectives is that every member of ONS staff has a contribution to make. However we recognise that delivery of these objectives will be most effective if there are clear roles and responsibilities at different levels of the ONS hierarchy for ensuring all staff are able to contribute. A diagram showing the relationships between the different roles is shown in the accompanying document Annex B. The Equality and Diversity Steering Group (EDSG) meets quarterly and draws members from across business areas of the organisation, diversity site champions and co-opted attendees as appropriate. Human Resources Division provides the secretariat for the group. It operates in a fully transparent way and reports to the Departmental Operations Committee (DOC). Its responsibilities are to: monitor progress against the Equality Scheme action plan and resolve obstacles to progress review the scheme action plan at intervals and address issues raised in an issues log quality assure annual equality and diversity progress reports for submission to DOC, ready for publication ensure that DOC communicates the requirement for all new departmental functions, policies, practices and projects to undergo equality impact assessment where they meet the relevance criteria, and develop the bid for, and agrees the spend of, the corporate diversity budget The current membership of the steering group can be found on the ONS intranet. EDSG may at times have Equality and Diversity Sub-groups to resolve specific obstacles to progress or provide a specialist role, for example a working group on improving the monitoring of workforce diversity. The National Statistician and Executive anagement Group is responsible for ensuring ONS complies with its statutory duties regarding equality. The ONS equality and diversity champion role is held by a member of staff at ONS executive board level. The responsibility of the ONS champion is to: sponsor the ONS s Equality Scheme and chair EDSG ensure the executive board members give due regard to equality and diversity issues throughout ONS business with emphasis on best practice rather than simply meeting statutory duties 26

27 act as a communication conduit between the board, site champions (see below) and other staff on equality and diversity issues, and be the owner of corporate risks relating to equality and diversity Diversity site champions (with deputies and administrative support where appropriate) are identified on each ONS site. Their responsibilities are to: work with the ONS equality and diversity champion to deliver the Equality Scheme and attend Equality and Diversity Steering Group meetings be a focus for diversity, identify and communicate equality and diversity issues relating to their site nurture and support diversity networks on their site, and provide expertise in an advisory capacity for equality impact assessments ONS has a number of active diversity networks on each site including networks grouped as disability; culture and ethnicity; work-life balance; lesbian, gay, bisexual, transsexual and transgender; all ages; faith/belief and a network for interviewers. While the activity of networks is self-determined, they are encouraged to: identify and record issues on an issues log that relate to their needs and suggest ways that ONS functions, policies, practices and projects can be amended to address these facilitate their members contributions to promoting equality including cultural understanding, positive attitudes and good relations between different people increase the understanding of equality issues across the ONS contribute to the work of the Equality and Diversity Steering Group either directly or through sub-groups liaise directly with HR and Facilities anagement to resolve local issues, and provide advice on dealing with issues affecting individual circumstances Network sponsors (and their deputies where appropriate) provide support and encouragement to specific networks. Human Resources Division provides an advisory function through the diversity advisor and also provides the secretariat function for the EDSG. The role of the diversity advisor is to: provide expert advice and guidance on equalities and diversity matters ensure up to date diversity policies and guidance are in place bring compliance matters to the attention of senior management and promote best practice over and above compliance oversee corporate communication on diversity issues via, for example, the diversity intranet, working with networks and champions. act as secretariat to ONS Equalities and Diversity Steering Group, and co-ordinate ONS equalities employment monitoring work 27

28 6.2 onitoring and reporting progress against the action plan Overall progress reports against the Equality Scheme action plan will be tabled at each EDSG meeting. EDSG meeting agendas, papers and notes will be posted on the ONS intranet, with care taken to ensure information is not disclosive. Annual reports on progress against the Equality Scheme will be quality assured by the EDSG and published on the ONS website. They will report on a number of headline indicators which may include: Total numbers of equality impact assessments conducted itigating actions taken as a result of equality impact assessment Progress against actions to address key issues site by site Additionally progress against workforce diversity targets should routinely form part of corporate reports. 6.3 Reviewing the scheme The main chapters of the Equality Scheme will be reviewed at intervals (at least every three years) with the annexes reviewed more regularly as appropriate. The action plan will be reviewed every six months during its first year and at least annually after that. 6.4 Suggestions or complaints about the scheme Suggestions or complaints about the scheme should either be sent to the ONS Diversity Advisor or raised with the diversity champions or diversity networks. Annexes to the scheme will be published as stand-alone documents on the ONS intranet to allow updating although the initial versions are included here for illustrative purposes at the time of publication. 28

29 Annex A ONS impact assessment priorities Detailed list of ONS functions, policies, practices and projects Guide to tables: The first column in each table lists ONS functions, policies, practices and projects (FPPPs) with the objective of making the description as accessible as possible to a wide audience [given that the final version would be published] and disaggregating FPPPs to a level at which the equality priority score is most meaningful. They are broadly consistent with those in the outputs diagram used in the consultation on the ONS statistical programme In the spirit of transparency, the prioritisation of FPPPs for equality impact assessment is then demonstrated. The FPPPs are first classified as major or minor. ajor FPPPs are then provisionally screened against a number of criteria (number of people who are affected by the FPPP either ONS staff or the public, potential seriousness of impact relating to equality and diversity, scale and cost of FPPP, the public profile of the FPPP). inor FPPPs are also screened for major impact on equality in terms of numbers of people affected and potential seriousness of impact The criteria scores of high (H), medium () and low () are then used to propose a priority score for carrying out equality impact assessment on the basis of low priority, medium priority, H high priority, E equality impact assessment already carried out Census, Demography and Regional Statistics Functions, policies, practices or projects Recruitment of census field staff Employment of census field staff Conduct of census field operation Non-compliance relating to census Consultations on requirements for information from census questions Census communications, questionnaire and Internet design. Provide statistical disclosure controls Census reports Produce population estimates, projections and analyses at a national and sub-national level igration statistics Implementation of recommendations from Review of igration Statistics Demographic Analysis NeSS Regional Statistics and analysis includes Release Regional Statistics ajor FPPP inor FPPP Priority Numbers of people Seriousness of impact Scale and cost profile Nos. of people Seriousness of impact H E H 29

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