Equality Impact Assessment

A new or revised policy, process or decision that seems fair because it applies to everyone equally may, upon closer analysis, adversely affect people identifying with the protected characteristics as defined by the Equality Act 2010. If this happens this could be direct or indirect discrimination.

To protect against this, the University has an Equality Impact Assessment process that helps you consider the effects of a policy, process or decision on anyone identifying with the protected characteristics and to take action to prevent discrimination.

Examples of Equality Impact Assessments that have been carried out include:

  • Annual Access Agreements 
  • REF 2021: Code of Practice for Selection of Staff
  • Examination and Religious Observance Form
  • Parental leave and pay changes

If you are a policyholder or you are leading on developing a new or revising an existing, University policy, process or decision in a College or Service then you are legally responsible for carrying out an Equality Analysis to consider equality issues and mitigate against possible discrimination.


1. Complete the online Equality Analysis Form with reference to the Equality Impact Assessment Guidance.

Contact the Wellbeing, Inclusion and Culture Team if you:

  • Have read the guidance but still have queries about assessing the impact of a policy on anyone with any protected characteristics
  • Have identified any negative or unclear impacts on the Equality Impact Assessment form
  • Are unsure about whether consultation would be helpful
  • Require consultation as part of the Equality Impact Assessment
  • Have any queries about the form which have not been clarified by the guidance or FAQs

2. The Wellbeing, Inclusion and Culture Team will respond to your EIA form submission with a copy for your records and any feedback or necessary changes required. 

3. If consultation is required, the Wellbeing, Inclusion and Culture Team will discuss this with you and will advise on the necessary channels for the consultation exercise. If consultation is not required, this is the end of the Equality Impact Assessment process.

Guidance

Equality Impact Assessments (EIAs) are a tool used to: 

  1. Undertake an analysis on how a proposed project, policy, or practice might impact differently on staff and students from an equality perspective.   
  2. Identify interdependencies between projects, policies and practices from an equality perspective.  

In order to be effective, EIAs should demonstrate a clear audit trail of how equality considerations were taken into account from the inception of the project, throughout the implementation process and critically at any decision making point throughout the life time of the project. This audit trail will help in demonstrating compliance with the Public Sector Equality Duties (PSED) 2011. 

  1. Project owner undertakes an initial EIA screening: This involves a high level evaluation of how the project may (or may not) impact disproportionately on people with different protected characteristics.   
  2. If the outcome of the screening is that a disproportionate impact has been identified, then a full EIA must be instigated.  
  3. Updates on the EIA must be presented at every project update and crucially when key decisions are taken. The project must not be “green lit” for progression until identified issues are addressed either through mitigation or through a review of the project scope. 
  4. A system should also be in place to review interdependencies between EIAs. This could be a formal review of EIAs at board level. Example: Identifying one project as having a negative impact on people whom English is not a first language may be addressed through mitigation. However having several projects with the same impact is more systemic, and can only be identified and addressed through examining the interdependencies between projects  

What is mitigation?

Example: Does a new recruitment system disadvantage visually impaired users by not being screen reader compatible? If contracts are issued in PDF format, then the chances are that a person using screen reader technology will not be able to access this contract, therefore an alternative format must be issued for this person. This alternative format constitutes a “mitigation”. A mitigation is used to address any potential impacts. A mitigation must appropriately take away the disadvantage that may be experienced as a result of implementing a particular project. 

  1. Contrary to popular beliefs, EIAs do not have to be written up on a template. It does however help for an institution to have some form of written audit trail on how it considered equality issues within the project and during decision making. 
  2. EIAs are not “done” to a project then subsequently shelved, they should be a core part of a project, cyclical and updated frequently as the project develops. This also means that by their very nature, EIAs should also be reviewed once the project is complete to ensure that the anticipated impact(s) and any mitigations are realised.  
  3. Having a nicely written up EIA does not evidence compliance with the PSED! In order to demonstrate compliance, the university must show that appropriate equality information was made available at the point of decision making. 

Frequently asked questions (FAQs)

What is an Equality Impact Assessment?

An Equality Impact Assessment, sometimes called Equality Impact Analysis, is a review of the actual or potential effects of our policies/procedures/services on people who identify with any of the protected characteristics. To ensure that we give careful consideration to the potential impact of a policy/procedure/service, the Equality Analysis Form prompts us to consider a policy* from the perspective of someone identifying with any of the protected characteristics, and to consider how the policy might impact upon them.

* The use of the term ‘policy’ refers to the full range of functions, procedures, activities, and decisions for which the University is responsible.

Why is an Equality Impact Assessment important?

Equality Impact Assessments give us the opportunity to do things better by taking advantage of the positive effects of a policy/procedure/service, and reducing or avoiding negative effects to prevent discrimination.

The public sector Equality Duty requires the University to have due regard to the need to:

  • Eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Equality Act 2010
  • Advance equality of opportunity between people who share a protected characteristic and those who do not
  • Foster good relations between people who share a protected characteristic* and those who do not

In having ‘due regard’ there must be evidence that equality issues have been considered. Therefore Equality Impact Assessments enable the University to meet these legal duties by:

  • Evidencing that equality has been considered throughout the decision-making process across the University
  • Enabling us to pre-empt and discourage incidents of discrimination
  • Highlighting areas of best practice in terms of equality and diversity – sharing things which are working well

Do I need to complete an Equality Impact Assessment?

In order to meet the University’s legal duties, equality issues should be considered and embedded within all decision-making, policy writing and service delivery at the University. University Executive Board (UEB) and Council are aware of this and will expect to see a completed EIA statement on all policy documents submitted. More information about how to include this in your paper can be found in UEB's Guidance & Templates. Therefore an Equality Impact Assessment should be completed:

  • Whenever a new policy is being written
  • Whenever an existing policy is being reviewed or significantly amended

Some University-level policies which are implemented at Faculty/Division level may have already had an Equality Impact Assessment completed at University-level. If this is the case and your Faculty/Division are implementing the policy in-line with the central policy and without any specific local arrangements or variations then an Equality Impact Assessment at local-level is not necessary.

What is meant by ‘policy’?

For the purpose of the Equality Impact Assessment process, the use of the term ‘policy’ refers to the full range of functions, procedures, activities, procedures and decisions for which the University is responsible. This includes both current and new policies.

Therefore any reference in the Equality Impact Assessment paperwork to the ‘policy’ should not be read literally as only applying to a written policy. The use of the word ‘policy’ should be regarded as flexible enough to refer to a procedure, activity, procedure, service, and decision.  

Who carries out an Equality Impact Assessment?

The policyholder, project lead or manager is accountable for ensuring that equality issues have been considered at options appraisal stage and that an EIA is completed. The policyholder is the person who “owns” the policy, ie who has the authority to make changes to the policy, and would be accountable/the point of contact should there be any challenges on equality grounds.

The policyholder may delegate the completing of the EIA to another person if they wish, but they need to be sure that whoever this knows enough about the detail of the policy to be able to thoroughly consider the policy’s actual and potential impact.