Understanding Equality Analysis
A guide for staff at Goldsmiths
What is Equality Analysis?
Understanding Discrimination
An Equality Analysis (EA), formally Equality Impact Assessment, is
a thorough and systemic analysis of the effects (impacts) of our
policies, practices and procedures on different groups of people.
Discrimination is where someone is treated less favourably or put at
a disadvantage because of certain personal characteristics, such as
their gender or race, or maybe because they have a disability.
It is an anticipatory process that allows institutions to predict
possible barriers faced by those likely to face discrimination and
disadvantage and to take appropriate actions to have a more
positive impact – especially groups with protected characteristics.
At Goldsmiths we support the improvement and encouragement of
equality, and we have agreed plans to identify and remove barriers
and to promote participation among those who may be more
vulnerable than others.
So, while discrimination may never be intended, EA tests out the
possibility that this may be a consequence of changes that we
make.
The Equality Act (2010) unites and replaces previous antidiscrimination legislation. It ensures consistency in what you need
to do to make the workplace a fair environment in order to comply
with the law.
EA is not an end in itself – it is a way of tackling barriers and
including people who have been traditionally excluded from the
mainstream. It’s also a way of ensuring and showing due regard
has been paid to our duties not to discriminate.
The Equality Act covers the same groups of individuals that were
protected by the previous legislation – these are now known as
protected characteristics – but there are some changes. As a result
you may need to review and change policies and practices.
‘Equality Analysis is not only about addressing discrimination
or adverse impact. They are about positive promotion of
equality of opportunity, improving access, participation in
public life and good relations.’
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Protected characteristics
Civil partners must be treated the same as married couples on a
wide range of legal matters.
To comply with legal obligations (and best practice), we need to
assess the impact on individuals with protected characteristics.
These include:
Pregnancy and maternity (adoption is covered within this)
Pregnancy - being pregnant or expecting a baby. Maternity and
adoption - the period after the birth or adoption and is linked to
maternity and adoption leave in the employment context.
Age
Where this is referred to, it refers to a person belonging to a
particular age (e.g. 32 year olds) or a range of ages (e.g. 18 - 30
year olds).
Race
It refers to a group of people defined by their race, colour and
nationality (including citizenship) ethnic or national origins.
Disability
A person has a disability (by law) if s/he has a physical or mental
impairment which has a substantial and long-term adverse effect on
that person's ability to carry out normal day-to-day activities.
Religion and belief
Religion has the meaning usually given to it but belief includes
religious and philosophical beliefs including lack of belief (e.g.
Atheism). Generally, a belief should affect your life choices or the
way you live for it to be included in the definition.
Gender reassignment
The process whereby a person's physical sexual characteristics are
changed by means of medical procedures. A person has the
protected characteristic of gender reassignment if the person is
proposing to undergo, is undergoing or has undergone a process
(or part of a process).
Sex
This is defined as a person’s legal sex – i.e. man or a woman.
Sexual orientation
Refers to a persons’ orientation or attraction towards; the same sex,
opposite sex or to both sexes.
Gender Identity
Describes the gender that a person sees themselves as. It is not
outlined explicitly as one of the protected characteristics in the
Equality Act. However, should also be considered to ensure people
are not disadvantaged by their gender identity, which could include
(but is not limited to), gender-queer, non-binary, or agender.
‘The social model of disability says that disability is caused by
the way society is organised, rather than by a person’s
impairment or difference. It looks at ways of removing barriers
that restrict life choices for disabled people’.
Marriage and civil partnership
The relationship between two people who are husband and wife, or
a similar relationship between people of the same sex (as newly
defined by Marriage (Same Sex Couples) Act 2013).
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When do I need to complete an Equality Analysis?
Goldsmiths has a strategy to embed equality and diversity so that it
becomes an integral part of our culture and planning processes. EA
should be considered early alongside risk, budget, and health and
safety management.
The test for relevance would be if you can say whether there will be
an effect on people with one of the protected characteristics or not
(positive or negative).
An EA should be started when you are first looking at:
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It may be decided quite early on that an EA is not relevant. In this
case the conclusion still needs to be documented to outline why.
creating new methods of service delivery
creating new policies or practices
developing business plans, strategies and projects
reviewing or amending existing policies, practices or
methods of service delivery
considering a change management process or
organisational review, particularly those that could involve
relocating staff or rationalisation of posts
any major communications or Information and
Communication Technology (ICT) project
introducing online services
reviewing or introducing forms, leaflets, guidance, codes of
practice or websites.
The proposal could have a positive impact, negative impact, or no
impact.
Try to involve relevant stakeholders in the EA process, if possible,
to gauge their views from the beginning and get a wide range of
perspectives.
Goldsmiths have a duty to involve students and staff covered by the
protected characteristics, in particular disability, in any decisionmaking where relevant.
It is quite possible that some policies, practices or services will be
more relevant to one protected characteristic than another (see
case study on next page).
To gain maximum benefit an EA should be begun at the very
earliest stages of developing policies, practices and services.
EAs should be an integral part of policy development and
review, not a one-off or separate exercise.
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Case study 1 – Building accessibility
Following an audit of the premises, a local library made a change to its development plan regarding its road furniture such as directional signs,
white lines, parking bays, zebra crossings and lighting.
When assessing impact across the protected characteristics, the Health and Safety Manager found that the proposed changes to the
development plan rated as highly relevant for groups covered by the protected characteristic ‘disability’. This was particularly the case as
considerations over disability and visibility needed to be looked at before any changes were made. However, the same policy was rated low
impact for groups covered by the protected characteristic ethnicity, as this was unlikely to be an issue.
In addition to disability, what was the relevance for other protected characteristics?
 It was considered to have a potentially negative impact under gender, and considerations were given to safety, particularly in the winter
months
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It was also considered to have a potentially negative impact for the characteristic ‘age’, since older people, constituted a large number
of their service users. Considerations of vulnerability and mobility for this group needed to be looked at
What actions were identified as a result of the Equality Analysis?
The EA helped to identify how the library could remove barriers to access and inclusion for particular groups of people and also have more
positive impacts, promoting equality of opportunity. Actions were taken to:
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Provide an additional five accessible bays in line with best practice guidelines that state that recreation and leisure facilities should have
accessible bays for 6% of the car park capacity – there should have been 13 designated spaces in total when there were only eight
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Place a handrail on either side of all the external steps to and from the building to aid people with mobility impairments in navigating the
steps – there was a handrail on only one side in the majority of cases
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Put appropriate tactile raised markings on the road edges and on stairways into and out of the building to assist individuals with visual
impairments
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Illuminate certain areas at night to make them safer for women and increase visibility for staff and disabled service users.
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Completing an Equality Analysis
consider whether your proposals promote equality of opportunity or
whether more work could be done to promote this.
Identifying what is to be assessed
It is important to identify who owns the policy or function which
means the person who has the authority or responsibility for
updating, agreement and the timescale. Consider who else needs
to be involved, this can include internal and external stakeholders
but it is important to involve those most likely to be affected if
possible. Identify who is going to carry out the assessment, this will
need to be someone who knows the issues well, it does not always
have to be the owner of the policy.
Differential impact
It is usual to discover differences. Instead, look for bias – that is,
significant or disproportionate differences between groups of people
in the way a policy practice or service has impacted on them.
Consider each protected characteristic for relevance and both
positive and negative impact.
Ask the question ‘why?’ and investigate further
Collecting existing sources of information or identifying gaps
in information
Start the process by gathering information.
Questions to consider in identifying any possible adverse
impacts include:
 Is there a lower participation rate for some groups rather
than others?
 Do eligibility criteria appear to disadvantage certain groups?
 Is access to services and benefits reduced or denied in
comparison with other groups?
 Does a group face increased difficulty as a result of a policy,
practice or change to a service?
Information can be sought from internal and external sources and
this stage should assist you in reaching a judgement on the impact
that a change may have on different groups of people, for example:
 workforce/student profiles
 statistics
 staff/student surveys
 focus groups
 complaints analysis
 feedback
Where a differential adverse impact is identified you will need
to consider whether we are acting within the law, appropriate
steps must be taken and outlined, this might involve additional
consultation.
If there are gaps in information that makes it difficult to form an
opinion or information does not exist, you can identify what
additional information needs to be collected or other areas that
could be explored.
How to analyse and act on your findings
Completing an EA is about making comparisons between groups of
employees and service users. You will need to analyse the
information you have gathered and assess the likely impacts of your
proposals (both positive and negative). You will also need to
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Case Study 2 – Naturalisation
Following the move of the British Nationality Act cards database indexes to an established archival institution, a large volume of enquiries regarding
naturalisation certificates were received by the organisation. Since the service was inherited it was new so in line with best practice an EA on the
service as it was being delivered was carried out. The service was complicated and unlike other services at the establishment, it was inefficient and
took considerable time to issue the new certificates. This created a barrier to service users accessing essential documentation that they often needed
urgently.
The EA indicated that the inherited system of enquiry was having an adverse impact under the characteristic of ‘race’. This was because the majority
of customers that made naturalisation enquiries were; from black and minority ethnic groups, non UK residents or if they were UK residents, they had
only been for a short period of time. English was the second language for the majority of service users. A negative impact on disabled staff was also
identified as index cards are difficult to access due to their physical location.
To further understand the impact of the service, the archive identified key characteristics of customers and their needs. Because these were one-off
enquiries, it was difficult to invite customers in for consultation. Instead, evidence was gathered by using customer profiling and exploring the
pathways customers took for different types of enquiry, and by conducting user research. The National Archives was able to identify where the key
barriers to access were. Steps were taken to improve the service delivery and to have a positive impact, including:
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digitising the indexes
providing a more straightforward online tool for searching
involving user testing in the design of the tool testing its accessibility
populating the catalogue at item level with details of individuals.
This enabled the following:
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easier access, accuracy and efficiency for searches carried out by staff
better understanding of gaps in the collection and missing index cards
greater understanding of patterns of post-Second World War migration by country of origin
easier access to search facilities for staff with disabilities.
This had a considerable impact on customers, particularly from black and minority ethnic groups who may have otherwise been excluded from
accessing an efficient service for obtaining naturalisation certificates.
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Mitigating adverse impact
If you have found a significant difference in how you’re treating people
or negative impact, or you have missed an opportunity to promote
equality of opportunity, you need to provide further details of the
actions that can be taken to remedy this. You can:
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Decide to stop the policy or practice at some point because the data
shows bias towards one or more groups.
Why do we want to do this?
Can we set out the reason clearly on paper?
Do we have evidence to support this reason?
Are we certain that this is real hard evidence and not just based
on assumptions?
Is there an alternative less or non-discriminatory way of
achieving the same result?
Question
Have you sought a second opinion from other key managers and
recorded how the decision was made in case it is reviewed in the
future?
Change or mitigate the policy or practice in a way which you think will
eliminate the bias.
Justify it – for example if the data shows the policy operates against a
particular group, but you cannot see an alternative. You’ve looked at
the policy or practice from every angle, considered all options carefully
and there still seems to be no other proportionate way to achieve the
aim of the policy or practice. Then you are going to continue with this
policy or practice in the knowledge it will favour some people less than
others.
Further involvement and consultation
When major impacts or missed opportunities to promote equality of
opportunity have been identified, you will often need to seek advice or
views from relevant stakeholders on what to do next. Further
consultation may therefore be necessary at this stage. You will need to
decide what the most relevant and proportionate means of consultation
will be. Informal dialogue with interested parties may be more
appropriate than formal, written, public consultation. Involving disabled
people will be key here.
Action
In most cases where disproportionate disadvantage is found by
carrying out an EA, policies and practices are changed or adapted.
This is a positive feature, demonstrating fairness at The National
Archives by removing barriers to both staff and service users.
Equality Analysis must be objective and must use evidence in
deciding impact. Value judgements will not do!
Making objective justifications
An EA asks you to carefully consider whether the impacts identified in
the initial assessment can be justified and, if not, to think about ways of
delivering the same outcomes by making adjustments to the proposals.
You should ask yourself:
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Case Study 3 – Removal of microfilm in the reading rooms
In April 2006, removal of microfilm from open access in the reading rooms was piloted by a university library. The aim was to create online access to
the resource via digitisation. Feedback about the impact of removing the film was sought from customers using a poster campaign and consultation
with the Regular Reader’s Forum.
During a further consultation in 2009, feedback was sought from a range of customers who used the microfilms and may have been impacted by the
change in the service. The consultation included customer satisfaction surveys, open user forums, ‘Meet the CEO’ days, and customer feedback
forms. Special attention was paid to disability and whether there would be any accessibility issues which included consulting with disabled customers.
After careful consideration of all the evidence and factors, it was identified that the change in this service would have no negative impact on different
protected groups. Further removals took place subsequently and despite frequent general consultation exercises, there was no negative feedback
regarding accessibility.
In fact, the change positively impacted on those with mobility, visual and manual dexterity issues. This was due to the provision of assistive
technology (for example adapted keyboards and ZoomText) in the reading rooms for those using computers. Such technologies do not exist for
microfilm usage. For users who have difficulty with computers, regardless of group or need, staff offer assistance and, if necessary, microfilms are
available on request.
When a customer contacted The library asking whether they had performed an Equality Analysis and considered the impact on disabled
customers, staff were able to clearly show that a robust consultation process had been carried out (a clear paper trail of evidence exists)
and illustrate that the proposed changes positively impacted on disabled customers to create more accessible records online where they
can be used in conjunction with assistive technology.
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Involvement and consultation
EAs should be completed using language that we can all understand.
The findings should be written in plain English, free from jargon.
A lack of evidence should not prevent an EA from being undertaken. In
cases where something is being introduced for the first time there may
be little experience to draw on or other material evidence. In such
cases you should make a judgment that is as reliable as possible.
Consultation is one way of strengthening judgments by building a
consensus view that can avoid obvious prejudices or assumptions –
this can be supported by involving a diverse range of people.
An initial or routine EA should be part of our day-to-day decision
making processes. In these instances, a simple paragraph that sets
out the relevance of the policy or practice or service, a summary of the
questions completed, and the consultation involved will enable the
Head of Service to ensure an impact assessment has been
undertaken.
Consultation is very important but it also needs to be proportionate and
relevant so that a small policy is not over-consulted on and a more
important policy inadequately consulted on.
Where adverse impact has been found a more thorough EA may need
to be considered to include evidence of additional consultation about
the impacts identified and decisions made as a result.
It is imperative to hear the views of a cross section of those who may
be affected by the change. It is important to consult especially with any
groups for whom you have identified a potential negative impact.
If you need advice and guidance on completing an EA, contact the
Equality and Diversity Advisor.
When you have completed your EA and it has been signed off, please
save it alongside your proposal or project documentation. Bear in mind
that you may be asked how you considered Equality and Diversity
when developing your proposal.
Different methods of consulting with people are more effective for
some groups than others and consideration needs to be given as to
when and where consultation will take place.
The Equality and Diversity Advisor may contact you to ask for a copy
of your EA, and it may be published to enable knowledge and good
practice to be shared externally and across Goldsmiths.
Saving and publishing findings
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Equality Analysis Map
Identify the objectives and
outcomes for a new or changing
policy, practice or service
Gather existing information from
staff and customers, feedback,
data and statistics
Analyse data, collect further
information if necessary – this
may include consultation
Assess impact – identify
barriers/impacts for different
protected characteristics
No evidence that changes
have an adverse impact on
equality of opportunity
Positive or negative impact
identified
Stop, mitigate or justify action
(negative impact)
Look at ways to promote or
utilise this opportunity (positive
impact)
Document findings
Consult on final changes and
proposed actions
Arrange sign off
Publish (if requested)
Monitor and review for impact
once proposal is implemented
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