Community Impact Assessment Form For a summary of this Community Impact Assessment, click here Title of Community Impact Assessment (CIA): Review of the Private Sector Housing Assistance Policy 2003 (amended 2011) Directorate: Environment and Community Safety Date of assessment: 27/5/14 Names and roles of people carrying out the community impact assessment. (Please identify Lead Officer): Clare Ibbeson Urban Renewal Team Manager, John Wooderson Head of Urban Renewal Section A – What are you impact assessing? (Indicate with an “x” which applies):A decision to review or change a service A strategy A policy or procedure A function, service or project X Are you impact assessing something that is?:New Existing Being reviewed Being reviewed as a result of budget constraints X 1 Describe the area you are impact assessing and, where appropriate, the changes you are proposing? The Private Sector Housing Assistance Policy (PSHAP) sets out the range of assistance that Salford City Council will make available for private sector home owners, together with the eligibility criteria and the conditions that will be applied to each form of assistance. The assistance can be directly or indirectly funded and may be in the form of a loan which may be secured against the property The Policy makes provision for a number of types of themed assistance to support the Council’s priorities, outlined as follows; Home Improvement Assistance Relocation Assistance Adaptations Assistance Block Improvement Assistance Affordable Warmth Assistance Empty Property Assistance Security Assistance Environmental Improvement Assistance Residential Leaseholders Discretionary Assistance Compulsory Purchase Order Assistance And the Policy makes provision for the following financial products to be used to support the themed assistance projects; Repayment Loan Interest Only Loan Interest Roll-up Loan Equity Participation Loan Secured Interest Free Loan Direct Financial Assistance Earlier versions of the policy included a number of terms and conditions, which together with terms and conditions set out in the main chapter, plus themes of assistance, were contradictory, the updated version aims to remove any confusion. Each theme of assistance is now organised in the same way with the following headings and reference to primary legislation where relevant – where specific terms or conditions override general terms and conditions of the Financial Products, this is clearly stated. Purpose Who Administers this Assistance Eligibility Type of Works Types of Financial Product which apply 2 Fees and Other Costs Conditions Policy Limits Specific changes to policy include as follows; Home Improvement Assistance Priority Points Policy has now become an annex to PSHAP and has been changed as follows; remove allocation of 30 points for ‘anyone under 60’ review latest benefits conditions remove length of time on waiting list Maximum age of child currently considered for ‘priority points’ = 10 o Change to (a) Dependent child under 5 (b) Any dependent living in the property as their main residence with a recognised medical condition Policy Limit increased to £12,000 excluding VAT, solicitors costs and other fees (solicitor costs and VAT can vary depending on client/contractor circumstances) Policy limit can be exceeded without exception to policy if client is highest priority and it is required to address a Category 1 Hazard (HHSRS) (with approval) Clients are limited to the maximum policy limit within an 3 year period to limit repeat applications exceeding the policy limit Relocation Assistance The Homeswap option is now removed. The option of a temporary decant is now removed. Under the old policy, if an assisted person chose to repay the loan within the first five years then the applicant would only be required to repay the original amount of the loan. This has been removed. Adaptation Assistance Now adopts a discretionary condition that ‘if the property is sold, assigned or transferred within 10 years of the grant being certified it becomes repayable’. Now adopting DFA without charge finance type for recycling lifts Block Improvement Assistance 3 Defined specific works have been changed to “external elements of the building which will have the greatest positive impact on the perception of the block and local area” Currently provided free of charge to both landlords and owner occupiers but is now changed to assess contribution levels on a scheme by scheme basis depending on funding route and strategic context Schemes will only now proceed if there is a high enough take up to make the scheme economically viable. Energy efficiency assistance Change of focus to support Green Deal / ECO / GMEAS and retains focus on fuel poverty Empty property assistance Updated to reflect current HCA Empty Property Funding eligibility (not guided by this policy) but put in place to make provision for Council to continue funding grants for Empty Properties if HCA funding ceases. a. Conversion assistance Will be removed HMO (Houses in Multiple Occupation) assistance Will be removed Security assistance No change Environmental improvements No change Major Capital Works Charges for Residential Leaseholders Earlier versions simply made provision for discretionary loans, now updated to provide clear eligibility and terms and conditions Compulsory Purchase Order discretionary compensation There is a statutory provision for compensation available, the value of which can be disputed by the claimant up to 6 years after the intention to ‘vest’ is known. If dispute is not lodged, SCC proposes to extend the availability of compensation for a further 4 years. Financial Products Any application for assistance will only be approved where the Council is satisfied that the carrying out of the eligible works is the most 4 satisfactory course of action When assessing the form and extent of assistance to be offered the Council will take into account the financial circumstances of all adults living within the property. Changes to financial products Currently provide and are retaining Repayment Loan / Equity Participation Loan / Secured Interest Free Loan – as a sequential test Propose to also introduce Interest Only Loan / Interest Roll-up Loan as next preference before Equity Loan in sequential test Adding a maximum value to loan, the loan should not be for more than 70% of the available equity (with the exception of Leaseholder and Relocation Loans) Change to the minimum amount to be repaid on an Equity Participation Loan. The minimum repayment will now be the amount originally advanced Section B – Is a Community Impact Assessment required (Screening)? Consider what you are impact assessing and mark “x” for all the statement(s) below which apply Service or policy that people use or which apply to people (this could include staff) Discretion is exercised or there is potential for people to experience different outcomes. For example, planning applications and whether applications are approved or not Concerns at local, regional or national level of discrimination/inequalities Major change, such as closure, reduction, removal or transfer Community, regeneration and planning strategies, organisational or directorate partnership strategies/plans Employment policy – where discretion is not exercised Employment policy – where discretion is exercised. For example, recruitment or disciplinary process X X If none of the areas above apply to your proposals, you will not be required to undertake a full CIA. Please summarise below why a full CIA is not required and send this form to your directorate equality link officer. If you have identified one or more of the above areas, you should conduct a full CIA and complete this form. n/a 5 Equality Areas Indicate with an “x” which equality areas are likely to be affected, positively or negatively, by the proposals Age X Religion and/or belief Disability X Sexual Identity Gender (including pregnancy and maternity and marriage and civil partnership) People on a low income (socio-economic inequality) Gender reassignment Other (please state below) (For example carers, ex offenders, refugees and asylum seekers, gypsies and travellers) X Race If any of the equality areas above have been identified as being likely to be affected by the proposals, you will be required to undertake a CIA. You will need only to consider those areas which you have indicated are likely to be affected by the proposals 6 Section C – Monitoring information C1 Do you currently monitor by the following protected characteristics or equality areas? Age Yes (Y) or No (N) Disability Y Gender (including pregnancy and maternity and marriage and civil partnership) N Gender Reassignment N Race N Religion and/or belief N Sexual Identity N People on a low income (socio-economic inequality) Y If no, please explain why and / or detail in the action plan at Section E how you will prioritise the gathering of this equality monitoring data. Y Equality monitoring statistics are not collected for all types of assistance but some types of assistance will be fully monitored where they are delivered as a service, such as Home Improvement Assistance, Security Assistance, Affordable Warmth Assistance and Adaptations Assistance. Equality monitoring statistics are not collected for all types of assistance but some types of assistance will be fully monitored where they are delivered as a service, such as Home Improvement Assistance, Security Assistance, Affordable Warmth Assistance and Adaptations Assistance. Equality monitoring statistics are not collected for all types of assistance but some types of assistance will be fully monitored where they are delivered as a service, such as Home Improvement Assistance, Security Assistance, Affordable Warmth Assistance and Adaptations Assistance. Equality monitoring statistics are not collected for all types of assistance but some types of assistance will be fully monitored where they are delivered as a service, such as Home Improvement Assistance, Security Assistance, Affordable Warmth Assistance and Adaptations Assistance. Equality monitoring statistics are not collected for all types of assistance but some types of assistance will be fully monitored where they are delivered as a service, such as Home Improvement Assistance, Security Assistance, Affordable Warmth Assistance and Adaptations Assistance. Other (please state) (For example carers, ex offenders, refugees and asylum 7 seekers, gypsies and travellers) Section C (continued) – Consultation C2 Are you intending to carry out consultation on your proposals? Yes If “no”, please explain your reason(s) why If “yes”, please give details of your consultation exercise and results below The draft amended policy and a draft community impact assessment have been made available to the public via the internet for 12 weeks. The staff teams who support the various themes of assistance have been sent the draft amended policy with a series of questions and have been consulted throughout the review. The relevant changes to the draft amended policy have been directly consulted on at the Home Improvement Agency Advisory Group and have been accepted by a group of wider professionals and customers of the service. The relevant changes to the draft amended policy have been directly consulted on by the Regeneration Scrutiny Panel and have been accepted by the Councillors present. 8 Section C (continued) – Analysis C3 What information has been analysed to inform the content of this CIA? What were the findings? Information about financial products provided and the values and interest returned to analyse the benefits of the Financial Products. Found that the current products needed to be updated as the housing market had changed significantly since the policy was originally written. Please include details of, for example, service or employee monitoring information, consultation findings, any national or local research, customer feedback, inspection reports, and any other information which will inform your CIA. National research into private sector assistance policies to assess good practice and to inform changes to prioritisation for Home Improvement Assistance found that most policies had a time limit within which no further assistance would be provided. Please specify whether this was existing information or was obtained specifically in relation to this equality analysis and CIA process Consideration of the impact of statutory legislation as it impacts on the terms and conditions that apply to discretionary Adaptations Assistance led to a decision being taken to include the discretionary elements which allow a charge to be set for mandatory DFG. Consultation with Street UK the loan provider and managers responsible for the various themes of assistance found that the current products needed to be updated as the housing market had changed significantly since the policy was originally written. Consultation with staff on HIA assistance values and limits to agree the new increased Home Improvement Assistance policy limit found that the current policy limit was agreed without consideration of the impact of survey fees, legal charges etc and the remaining funding was not sufficient. Consultation with managers delivering Relocation Assistance to inform the removal of Homeswap and temporary decant found that the current products needed to be updated as the housing market had changed significantly since the policy was originally written. Consultation with managers delivering various themes of assistance to agree other changes to policy based on feedback about practice of the policy and assessment against the current market and council strategy found that small changes to procedure should now be mirrored in policy, but no significant negative changes were proposed. 9 Section D – Potential impacts and how these will be addressed Could your proposals have a differential impact relating to age equality Will people within certain age ranges not be getting the outcome they need? Will people within certain age ranges be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? If you are unable to eliminate, reduce or mitigate negative impacts, are your proposals potentially discriminatory on the grounds of age? Yes (Y) Will the proposals mean that people within certain age ranges will experience positive outcomes? Highlight any positive impacts Y No (N) Y Explain impact(s) and what evidence or data exists to support your analysis? Home Improvement Assistance is aimed at older and vulnerable people. The current prioritisation policy provides points to anyone under age 60 and this is now removed but there is still opportunity for people under 60 to qualify because of vulnerability, including illness and infirmity issues, or the seriousness of their housing condition. Home Improvement Assistance prioritisation will take into account children but the age limit has been changed from under 10 to under 5. However we have added the option to consider the health needs of any dependent person who lives in the homes as their permanent residence, so any child with a health need will still be considered. Refining the process for prioritisation of Home Improvement Assistance will ensure that the limited financial assistance available each year will be focussed on the core group of older and vulnerable people for the Home Improvement Agency. General changes to the layout of the policy and to remove duplication of terms and conditions will make the policy more accessible by a wider customer group. If a Home Improvement Assistance client is assessed as the highest priority and assistance is required to address a Category 1 Hazard (HHSRS) then with appropriate senior manager approval the policy limit can now be exceeded without exception to policy. Are the proposals likely to impact on community cohesion? Is there potential to enhance relationships between people who share a protected characteristic and those who do not? Identify areas where there is N 10 potential to foster good relations Section D (continued) – Potential impacts and how these will be addressed Could your proposals have a differential impact relating to disability equality Will people with a disability not be getting the outcome they need? Will people with a disability be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? If you are unable to eliminate, reduce or mitigate negative impacts, are your proposals potentially discriminatory on the grounds of disability? Yes (Y) Y Adaptations Assistance has adopted a discretionary procedure to set a charge against a property where the grant sum exceeds £5000 then if the property is sold, assigned or transferred within 10 years of the grant being certified it becomes repayable. However this does not change the eligibility or access to grant in the first instance. Will the proposals mean that people with a disability will experience positive outcomes? Highlight any positive impacts Y Adaptations Assistance now makes provision for recycling equipment free at the point of use for the customer. Are the proposals likely to impact on community cohesion? Is there potential to enhance relationships between people who share a protected characteristic and those who do not? Identify areas where there is potential to foster good relations No (N) Explain impact(s) and what evidence or data exists to support your analysis? General changes to the layout of the policy and to remove duplication of terms and conditions will make the policy more accessible by a wider customer group. N 11 Section D (continued) – Potential impacts and how these will be addressed Could your proposals have a differential impact relating to gender equality (this includes pregnancy and maternity and marriage and civil partnership) Will men, women or boys and girls not be getting the outcome they need? Will men, women or boys and girls be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? If you are unable to eliminate, reduce or mitigate negative impacts, are your proposals potentially discriminatory on the grounds of gender? Will the proposals mean that men or women, boys or girls will experience positive outcomes? Highlight any positive impacts Are the proposals likely to impact on community cohesion? Is there potential to enhance relationships between people who share a protected characteristic and those who do not? Identify areas where there is potential to foster good relations Yes (Y) No (N) Explain impact(s) and what evidence or data exists to support your analysis? N N N 12 Section D (continued) – Potential impacts and how these will be addressed Could your proposals have a differential impact relating to equality for people planning, undergoing or who have undergone gender reassignment? Will people planning, undergoing or who have undergone gender reassignment not be getting the outcome they need? Will people planning, undergoing or who have undergone gender reassignment be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? If you are unable to eliminate, reduce or mitigate negative impacts, are your proposals potentially discriminatory on the grounds of gender reassignment? Yes (Y) No (N) Explain impact(s) and what evidence or data exists to support your analysis? N N Will the proposals mean that people planning, undergoing or who have undergone gender reassignment will experience positive outcomes? Highlight any positive impacts Are the proposals likely to impact on community cohesion? Is there potential to enhance relationships between people who share a protected characteristic and those who do not? Identify areas where there is potential to foster good relations N 13 Section D (continued) – Potential impacts and how these will be addressed Could your proposals have a differential impact relating to race equality Will certain racial groups not be getting the outcome they need? Will certain racial groups be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? If you are unable to eliminate, reduce or mitigate negative impacts, are your proposals potentially discriminatory on the grounds of race? Yes (Y) No (N) Explain impact(s) and what evidence or data exists to support your analysis? N Will the proposals mean that people within certain racial groups will experience positive outcomes? Highlight any positive impacts N Are the proposals likely to impact on community cohesion? Is there potential to enhance relationships between people who share a protected characteristic and those who do not? Identify areas where there is potential to foster good relations N 14 Section D (continued) – Potential impacts and how these will be addressed Could your proposals have a differential impact relating to religion or belief equality Will people of certain religions or who have particular beliefs not be getting the outcome they need? Will people of certain religions or who have particular beliefs be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? If you are unable to eliminate, reduce or mitigate negative impacts, are your proposals potentially discriminatory on the grounds of religion or belief? Will the proposals mean that people of certain religions or who have particular beliefs will experience positive outcomes? Highlight any positive impacts Are the proposals likely to impact on community cohesion? Is there potential to enhance relationships between people who share a protected characteristic and those who do not? Identify areas where there is potential to foster good relations Yes (Y) No (N) Explain impact(s) and what evidence or data exists to support your analysis? N N N 15 Section D (continued) – Potential impacts and how these will be addressed Could your proposals have a differential impact relating to sexual identity equality Will gay, lesbian and/or bi-sexual people not be getting the outcome they need? Will gay, lesbian and/or bi-sexual people be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? If you are unable to eliminate, reduce or mitigate negative impacts, are your proposals potentially discriminatory on the grounds of sexual identity? Will the proposals mean that gay, lesbian and/or bi-sexual people will experience positive outcomes? Highlight any positive impacts Are the proposals likely to impact on community cohesion? Is there potential to enhance relationships between people who share a protected characteristic and those who do not? Identify areas where there is potential to foster good relations Yes (Y) No (N) Explain impact(s) and what evidence or data exists to support your analysis? N N N 16 Section D (continued) – Potential impacts and how these will be addressed Could your proposals have a differential impact on socio economic equality (people on a low income)? Will people on a low income not be getting the outcome they need? Will people on a low income be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? If you are unable to eliminate, reduce or mitigate negative impacts, are your proposals potentially discriminatory on the grounds of socio economic inequality? Yes (Y) Y No (N) Explain impact(s) and what evidence or data exists to support your analysis? Clients will now be limited to the maximum policy limit for Home Improvement Assistance within an 3 year period, to limit repeat applications exceeding the policy limit. Only people on a low income are eligible for this type of assistance so the introduction of this condition will not disproportionately affect people on a low income and where the condition creates hardship, the Assistant Mayor for Housing and Environment maintains the discretion to make exceptions to the policy. The Homeswap option is now removed from Relocation Assistance. This gave an extra option to people whose homes were being acquired by the council for the council to identify their new property. However the housing market has changed significantly since the policy was originally written and the council is not managing area based regeneration projects on the same large scale, therefore the need to identify properties for people has reduced. The council retains Relocation Assistance which allows people to identify their own property. In both cases a charge would be set on the property therefore there should be limited impact on people with a low income. The option of a temporary decant is now removed. This gave an extra option to people whose homes were being acquired by the council for the council to find them a temporary property until their new property was ready. However the housing market has changed significantly since the policy was originally written and the council is not managing area based regeneration projects on the same large scale, therefore the need to identify temporary properties for people has reduced. The council retains Relocation Assistance which allows people to identify their own property and these should be readily available in the present housing market. There should therefore be limited impact on people with a low income. There is a change to the minimum amount to be repaid on an Equity Participation Loan. The minimum repayment will now be the amount originally advanced. The housing market 17 is currently stable so the fluctuations of housing value which would impact on this are minimal. There could therefore be a moderate impact on people with a low income who sell their property for less than the purchase price. Where the condition creates hardship, the Assistant Mayor for Housing and Environment maintains the discretion make exceptions to the policy. Under the old policy, if an assisted person chose to repay a Relocation Assistance loan within the first five years then the applicant would only be required to repay the original amount of the loan. This has been removed. In this case the applicant now will either pay, the original amount of the loan, or they will pay a value based on the increased value of their property. If they are paying back more then they will also be receiving an increased revenue from the sale of the property which they will keep themselves. There should therefore be limited impact on people with a low income. Block Improvement Assistance is currently provided free of charge to both landlords and owner occupiers but is now changed to assess contribution levels on a scheme by scheme basis depending on funding route and strategic context. It is intended that this will reduce the amount of work that is provided free at the point of access to those home owners who are capable of funding the work themselves. There should therefore be limited impact on people with a low income. Any application for a Financial product will only be approved where the Council is satisfied that the carrying out of the eligible works is the most satisfactory course of action. Where the council deems it is not the most satisfactory the council will provide advice and in some cases will be able to provide alternative services which are more appropriate. E.g. where Home Improvement Assistance is not the most satisfactory course of action because a home needs repairs well in excess of the policy limit, the housing options support and advice service will be offered. When assessing the form and extent of assistance to be offered the Council will take into account the financial circumstances of all adults living within the property. Under current policy other owners of the property (siblings, ex-spouses) are not always considered in the financial assessment. Under the new policy they will be and this may mean an increased number of people liable for repayments. However an increased number of repayments 18 should mean a reduced value of payment per person. The new policy introduces a maximum value to the loan, the loan should now not be for more than 70% of the available equity (with the exception of Leaseholder and Relocation Loans). This change is intended to protect the customers equity and to protect the council’s investment. This applies, except in cases where the applicant has been determined the highest priority, as determined by the Home Improvement Agency Priority Assessment and there is a need to address a Category 1 Hazard in the property. In cases of hardship the policy states the Council may consider loans which exceed this limit. Y This policy introduces Interest Only Loans and Interest Roll-up Loans as the next preference in the sequential test before Equity Participation Loans. This introduces financial products on top of the repayment loan which bear interest. However unlike repayment loans which require repayment of interest and capital each month, these new loan products allow for repayment of only interest or for the entire repayment to be set as a charge only repayable on transfer of the property. While the value of the charge is increasing by the rate of interest, this should provide for a reduced payment option for some clients. Will the proposals mean that people on a low income will experience positive outcomes? Highlight any positive impacts Are the proposals likely to impact on community cohesion? Is there potential to enhance relationships between people who share a protected characteristic and those who do not? Identify areas where there is potential to foster good relations N 19 Section D (continued) – Potential impacts and how these will be addressed Could your proposals have a differential impact relating to any other equality groups, for example, carers, ex offenders, refugees and asylum seekers, gypsies and travellers)? Will people within any other groups not be getting the outcome they need? Will people within any other groups be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? If you are unable to eliminate, reduce or mitigate negative impacts, are your proposals potentially discriminatory for people within any other groups? Will the proposals mean that people within any other groups will experience positive outcomes? Highlight any positive impacts Are the proposals likely to impact on community cohesion Is there potential to enhance relationships between people who share a protected characteristic and those who do not? identify areas where there is potential to foster good relations Yes (Y) No (N) Explain impact(s) and what evidence or data exists to support your analysis? N N N 20 Section E – Action Plan and review Detail in the plan below, actions that you have identified in your CIA, which will eliminate discrimination, advance equality of opportunity and/or foster good relations. If you are unable to eliminate or reduce negative impact on any of the equality areas, you should explain why Impact (positive or negative) identified Proposed action Person(s) responsible The eligibility criteria of some types of assistance have been reduced – to ensure resources are better targeted at those most in need To monitor access to the scheme by all groups to ensure the proposed effect Service Managers Terms and conditions to access funding have been changed – to protect the council’s investment and prevent misuse of resources, i.e. Limit to service every 3 years 70% LTV Minimum repayment Interest on loans Assess financial circumstances of all adults Reduce access of landlords Grant repayment on a charge To monitor the effect of the changes on the most vulnerable Loans Administrator 21 Where will action be monitored? (e.g., Directorate Business Plan, Service Plan, Equality Action Plan) Team Business Plan Target date Required outcome Mar 2017 Resources are better targeted at those most in need Loans Administrator contract meetings Mar 2017 Council’s investment is protected while most vulnerable still receive service. Could making the changes in any of the above areas have a negative effect on other groups? Explain why and what you will do about this. Not known Review Your CIA should be reviewed at least every three years, less if it has a significant impact on people. Please enter the date your CIA will be reviewed - June 2017. You should review progress on your CIA action plan annually. 22 Section F – Summary of your CIA As your CIA will be published on the council’s website and accessible to the general public, a summary of your CIA is required. Please provide a summary of your CIA in the box below. Summary of Community Impact Assessment Brief summary of proposal or what you are impact assessing The Private Sector Housing Assistance Policy (PSHAP) sets out the range of assistance that Salford City Council will make available for private sector home owners, together with the eligibility criteria and the conditions that will be applied to each form of assistance. The assistance can be directly or indirectly funded and may be in the form of a loan which may be secured against the property. The policy has been reviewed in light of the changing housing and economic markets and to support practical day-to-day delivery. How did you approach the CIA and what did you find? We met with managers, staff, multi-agency groups and published information for customers online to gather information about the changes required and then to review the proposed changes. It was found that housing and economic markets had changed so significantly since the 2011 review of the policy that changes were required to ensure that the council’s investment is being protected, this led to proposals to charge interest on the Council’s loan products and to change the terms and conditions to clarify the circumstances under which a loan may be made. It was also reported by service managers that changes were needed to policy to ensure that services’ eligibility criteria were properly focussed on those most in need of service, and to remove some policy offers which were no longer appropriate. What are the main areas requiring further attention? The Policy has now been updated to reflect changes to eligibility criteria, loan terms and conditions and to remove some of the previous policy offer. Summary of recommendations for improvement It is proposed to monitor the effect of changes to the eligibility criteria of some types of assistance, to ensure access to the scheme by groups most in need is protected. And it is proposed to evaluate changes to the terms and conditions of funding, to monitor the effect of the changes on the most vulnerable. 23 Section G – Next Steps Quality Assurance When you have completed your CIA, you should send it to your directorate Equality Link Officer who will arrange for it to be quality assured. Your CIA will be returned to you if further work is required. It is important that your CIA is robust and of good quality as it may be challenged “Sign off” within your directorate Your directorate Equality Link Officer will then arrange for your CIA to be “signed off” within your directorate (see below). Your directorate Equality Lead Officer or other senior manager within your directorate should “sign off” your CIA (below). Name Signature Date Senior Manager Lead CIA Officer Publishing When your CIA has been signed off within your directorate, your directorate Equality Link Officer will send it to Elaine Barber in the Equalities and Cohesion Team for publishing on the council’s website. Monitoring Your directorate Equality Link Officer will also send your CIA to your directorate Performance Officer where the actions identified within your CIA will be entered into Covalent, the council’s performance management monitoring software so that progress can be monitored as appropriate. 24