1. Introduction 1.1 This impact assessment was undertaken using the methodology and approach set out in Hounslow s Equalities Impact Assessment Guidance. The assessment was undertaken by Sarah Catchpole (Principal Equalities Officer) and Robert Della-Sala (Head of Customer Service and Access Transformation). 1.2. The focus of this assessment is to consider the impact the proposed changes to customer contact with the London Borough of Hounslow 1.3 The purpose of the changes is to achieve the channel shift from unnecessary telephone and face to face contact to self service and the internet that is required to support promise 8 of the Hounslow Plan and the access transformation that was agreed in the course of the Performance Improvement Programme. 2. The Duty to Complete an Equalities Impact Assessment 2.1 The duty to carry out an Equalities Impact Assessment (EIA) on Council policies, services or functions is a legal requirement under the Race Relations Amendment Act 2000 and the Disability Discrimination Act 2005 and the Equality Act 2006. 2.2 The London Borough of Hounslow has extended EIAs beyond the three equalities categories of race disability and gender to incorporate other equality groups including age, sexuality, faith or belief and human rights. This is to ensure that the Council fulfils its legal requirements to identify direct and indirect discrimination on residents and staff following the Employment Equality (Age) Regulations 2006; Employment Equality (Religion and Belief) Regulations 2003; the Equality Act (Sexual Orientation) Regulations 2007 and the Human Rights Act 1998. 2.3 It is essential that the impact of any policy be assessed in order to promote equality. An impact assessment is mandatory when drafting new policies, undertaking reviews, making changes to existing policies, restructuring services or changing the way in which Council services are delivered. An assessment therefore ensures that the needs of the community are being met. 2.4 When considering the impact of a policy on the community the following points need to be considered: 1. The impact on people due to race
2. The impact on people due to religion 3. The impact on people due to language 4. The impact on people due to age 5. The impact on people due to disability 6. The impact on people due to gender 7. The impact on people due to sexual orientation 8. The impact on community relations and community cohesion 9. The impact of attitudes towards disabled people 10. The impact on the participation of disabled people in public life 11. The impact on people s human rights 3. The Equality Duty 3.1 When considering the impact of the policy there must be due regard to the need to eliminate unlawful discrimination, promote equality of opportunity and promote good relations. 3.2 Under the Disability Equality Duty, imposed in the Disability Discrimination Act 2005 local authorities have a specific duty to: 1. Encourage participation by disabled people in public life 2. Take steps to take account of disabled people s disabilities even where that involves treating disabled people more favourably than others. 3.3 The DDA also requires local authorities to provide reasonable adjustments to allow for access to services by disabled people. 4. Summary of Proposals 4.1 The website will be promoted at the main source of information about Council services. In addition all web pages will be revised to make it easier for users to navigate around the site. E-forms will be introduced wherever possible and be promoted as the predominant means of transaction with the Council. An enhanced payments system will also be introduced. 4.2 Service related emails will be implemented and promoted as the predominant means of contacting the council where there are clear operational reasons for doing so and e-forms are not available. This is to prevent individual officer contact, which is dependent of the availability of the individual. 4.3 A new telephone system will be implemented which will be menu based and will allow customers to pick the service they want. The aim is to provide an improved service for customers by reducing unnecessary calls. Some calls will not be answered by a member of staff but will be in the
form of a recorded message giving the customer the information they require. 5. Summary of Equalities Impact by Group Category High Medium Low None Comment Race x No obvious disproportionate impact from the proposals on people of different racial groups Religion x No obvious disproportionate impact form the proposals on people of different religious groups Language x There could be concerns for customers for whom English is not their first language. A lack of understanding of English could result in customers being disadvantaged or not receiving the correct information. Age x There could be a slight impact on elderly customers but this would most likely be linked to a language problem or disability. Gender x No obvious disproportionate impact from the proposals on people of different genders. Sexual x No obvious disproportionate impact from the Orientation proposals on people of different sexual Community Relations and Cohesion Disability including attitudes towards disabled people and participation of disabled people in public life x x orientation There is no obvious disproportionate impact from the proposals on community relations and cohesion There is the potential for impact on disabled users. Further discussion on this issue is below. 6. Further Assessment 6.1 Language 6.1.1 For many customers English is not their first language. The system will introduce recorded messages for some services and will not result in the customer speaking to a member of staff. An example of this will be in the parking service where customers will be directed to a message which will inform them of how to appeal a penalty charge notice. For customers who do not understand English very well this could lead to legal
disadvantage as they may not understand their right to appeal and the process involved clearly. 6.1.2 An inability to understand the information being provided could result in severe disadvantage. 6.1.3 The Council in its Equality Scheme has defined severe disadvantage. Severe disadvantage can be arise from the following situations Financial loss (e.g. housing benefit claim) and/or Health, no improvement or deterioration (e.g. misdiagnosis, unable to understand medical instructions) and/or Lead to legal disadvantage (e.g. Noise abatement notice unable to read legal duty to comply, trading standards notices, health and safety requirements etc) and/or Cause severe distress to the service user (e.g. missing child, fire in home etc) Other grounds may include To ensure that non-english speaking residents are able to access essential services, e.g. the police, education services, and safety campaigns around fire etc. To enable people to access the democratic process, for example enabling people to register to vote or take part in local consultation; To support local community groups or intermediaries working directly with new migrants; To enable people to function effectively as citizens in society and be able to get along with others, by ensuring that they understand local rules and systems e.g. rubbish disposal or parking restrictions To ensure compliance with the Race Relations (Amendment) Act 2000 and other relevant regulations to ensure that no-one is disadvantaged in accessing services because of his/her inability to communicate verbally or non-verbally. 6.2 Disability 6.2.1 There is potential for huge impact on disabled people. It is important to remember that disabled people can be extremely vulnerable and that disability does not just include those with a physical issue but can involve those with a mental disability also. 6.2.2 The Disability Discrimination Act 1995 defines a person as having a disability if he has a physical or mental impairment which has a
substantial and long-term adverse effect on his ability to carry out normal day to day activities. 6.2.3 There could be a huge impact on those with sensory disabilities. Telephones are the lifelines of blind and physically impaired people particularly; it allows them to participate in normal day to day life without the need for a carer or relative or without placing undue physical exertion on themselves. Many deaf people find it impossible to use automated services they either cannot hear them clearly enough due to the volume or pace of speech in the recorded messages. Deaf people cannot ask an automated service to speak louder or to speak slower or with more clarity. 6.2.4 People who suffer from learning disabilities or mental health issues may not understand the voice prompts and may become distressed. They may also not understand the information they are being asked to leave. As an example, the Transport Inclusion Unit uses voicemail services when unavailable; there have been many occasions where people with learning difficulties or mental health issues have left a message but have not included their name or telephone number. This has left staff unable to contact the customer back and has resulted in the customer becoming distressed that their issue has not been resolved. 6.2.5. There could also be an impact on disabled people by asking them to use the internet as their primary method of contact with the Council. There needs to be consideration of disabled people's access to computers. 6.2.6 A recent survey found that only 1/3 of disabled people had access to computers; an even smaller majority had access to home computers. For those who did not have any access the reasons were that: They were not able to financially afford a computer Others stipulated that they could not access public services (e.g. library provision) as due to their disability they could physically attend the provision. 6.2.7 Whilst most public buildings are Disability Discrimination Act compliant this does not always mean a disabled person feels able to use the facility. Also it could be considered unreasonable to ask a disabled person to have to make what could be a difficult and painful journey down the Civic Centre/library/other internet provision every time they wish to contact the Council. 6.2.8 All of the examples outline above show that there could be an impact on a disabled person s ability to participate in public life. 7. Mitigation of Impact
7.1 All of the impacts discussed above can be mitigated against. 7.2 The web, e-forms and the new automated telephone service will provide new and additional opportunities for residents to receive council information 24/7 which is not currently the case. For some disabled people accessing services using the telephone or the internet rather than having to attend the civic centre in person may be beneficial. 7.3 By retaining some ability to speak to a member of staff via the automated phone service those with specialised needs, e.g. translation of service information, will be able to access the service they require. 7.4 For those customers who have hearing impairments, it is vital to ensure that the voice recordings a clearly spoken, simple and easy to understand. The new telephony system will allow callers to listen to messages again by pressing the star button. Where unclear messages are left staff will be able to call back to obtain more information. 7.5 Publication of the minicom service will also make sure that hearing impaired customers contact the council in the most appropriate way. In all cases, staff who have contact with disabled or vulnerable customers will seek to assist and re-assure those residents who find the new systems difficult to access in order to reduce the impact of the changes. 7.6 Once the system is in place, a focus group of disabled residents could be used to test the systems in place and suggest improvements. This could be part of on-going customer feedback. 8. Summary of Advice 8.1 There is potential for impact on some equality groups. Disabled users in particular may find contacting the council using telephone systems or internet facilities difficult. However, steps can be taken to mitigate the impact on these groups. 8.2 There is limited ethnicity/disability data regarding how residents currently access council services. All the current access routes will continue to be available though will not be as well publicised as the web and e-form/email routes. 8.3 It is hoped that by channel shifting the majority of customers contacting the council it will leave current face to face or voice to voice services able to provide a better and faster service to those customers who need more specific help. 9. Recommendations
9.1 That an initial EIA template is completed by each service/section affected by the automated telephone service once the call menus have been created to assess for impact on the service s specific customer group 9.2 That a focus group of disabled residents be set up to review the system once in place and the feedback used to improve the system. 9.3 That monitoring takes place in the first 6 months to compile ethnicity/data on how customers access council services. 9.4 That a further EIA is done once the system has been in place for 6-12 months to assess for actual impact on customer groups.