Equality Impact Assessment Form Before you complete this form, please contact the EDU as they can provide advice, guidance and support through this process. Please return the completed form to the EDU. The boxes will expand as you type. Step 1 – Define policy/ practice i. Name of policy/ practice Redundancy Consultation and Management Process (three policies/protocols) 1. Management of Organisational Change Policy: Avoidance & Mitigation of Redundancy 2. Management of Compulsory Redundancy Protocol 3. Redeployment Guidance and the Job Seeker’s Register ii. Owner of policy/ practice Human Resources (HR) iii. Date of policy/ practice approved January 2002 iv. Approved by (committee) Human Resources Committee and Court Step 2 – Description of policy/ practice i. What are the aims? 1. Policy on avoidance and mitigation of redundancy 2. Management of the compulsory redundancy process 3. Redeployment guidelines through the Job Seekers Register ii. Who does it cover? (students, staff) Staff iii. How often is this policy/ practice reviewed? Regularly; pilot currently underway to evaluate effectiveness of new arrangements agreed in June 2008 for managing FTF redundancies Step 3 - Could there be any barriers for a minority group in this policy/ practice? (Please tick all that are relevant) √ Age √ Disability √ Gender √ Race Sexual orientation Religion and Belief Step 3a – Yes, there is a potential barrier for a minority group X Step 3b – No, there is no barrier for a minority group Step 4 – what basis do you have for this conclusion? There is a perception that any of the above mentioned minority groups may be affected by the application of both the Policy and the Protocol. Step Go to Step 4 Go to Step 9 Go to Step 5 This may be due to (for example) over concentration of one minority group in a given area selected for possible redundancy. Step 5 – Does the evidence show… Go to Step 5a, b or c HR has developed the Management of Organisational Change: Avoidance & Mitigation of Redundancy Policy to staff and trade unions are fully consulted upon the scope to avoid or mitigate the potential need for redundancies. HR has developed the JSR and its associated guidelines to ensure all redeployment opportunities are considered fully for all affected staff. The Management of Compulsory Redundancy Protocol is implemented under the review and approval of the Redundancy Committee and Court as appropriate to ensure appropriate checks and balances are in place and appropriate decisions taken. HR has produced Guidance for the Structural Change Committee and the Redundancy Committee who implement the Policy and Protocol on the three main areas which may have an equality impact – 1. The consultation process 2. The selection of the pool of potentially affected staff at risk of redundancy. 3. The criteria and processes used to select the activities, skills and experience etc. which will be required to select staff to be retained or released. Step 5a – A positive impact (please provide an example) 1. The Management of Organisational Change: Avoidance & Mitigation of Redundancy Policy emphasises exploring redeployment opportunities for existing staff as an alternative to redundancy. To support this process the University has developed (i) The Job Seekers Register (JSR), as an additional support to staff who are seeking re-deployment. (ii)The University’s Recruitment and Selection Policy places an obligation on recruiting managers to consider staff at risk on the JSR prior to wider advertisement of vacancies. 2. The JSR highlights the protection in law given to women who are pregnant or on maternity leave, and to disabled members of staff. 3. If an individual is considered for a position through the JSR (i.e. through redeployment) they must meet the essential criteria only to gain an interview and subsequent appointment to a redeployment position. 2 4. The University applies a 90-day consultation approach to all redundancy procedures where business needs allow, irrespective of the numbers of staff affected. 5. The University implements the EC interpretation of when to initiate consultation, which is earlier than the UK interpretation and consequently beneficial for staff at risk. Step 5b – A negative impact - You will need to consult with stakeholders (the EDU would assist with this process) A particular staff cohort may feel to be disproportionately affected by compulsory redundancies in specific cases of provisional or actual redundancy. Step 5c – No impact N/A Step 6 – Continue to promote good opportunity for all Go to Step 7 Go to Step 9 Go to Step 9 The JSR is an integral part of the University’s Recruitment and Selection Policy, and re-deployment is emphasised within Management of Organisational Change Policy: Avoidance & Mitigation of Redundancy Policy. Step 7 – Involve and consult stakeholders (the EDU would assist with Go to Step 8 this process) to address negative issues in the policy/ practice The University consulted with campus Trade Unions, Senior Management Group, Human Resources Managers and the University’s lawyers in developing the existing suite of policies and guidance. The Trade Unions would not agree to the Management of Compulsory Redundancy Protocol, hence it is a management instrument rather than a collective agreement. The University Court and the Redundancy Committee approves all the recommendations made by the Structural Change or Redundancy Committee as appropriate. Effected staff members and representative Trade Unions are fully consulted throughout the process at the avoidance and compulsion phases. Step 8 –Please outline the changes you are making to the policy/ practice Go to Step 9 The Policy and Protocol are in accordance with the existing Ordinance for Academic & Related Staff and employment legislation. The Ordinance is under review through a Scotland-wide initiative currently. 3 Checks and balances are embedded within the policy including: Online guidance and coaching is provided to the Structural Change Committee and Redundancy Committee by the HRM’s. The EDU would recommend that the coaching is formalised for consistency of approach. No final decision can be made by the Structural Change Committee. The Redundancy Committee and University Court ensure all procedures are fairly applied to all involved. Guidance is provided to the Structural Change and Redundancy Committees highlighting what criteria are considered potentially discriminatory and should not be used when selecting candidates for Compulsory Redundancy. (Appendix A) Appeals can be made through other University procedures such as the Ordinances’ Appeal Procedure, Grievance Policy and ultimately through Employment Tribunals. The University has established a pilot scheme devolving decision-making to Redundancy Committees for redundancies which arise from fixed-term funding. This will be piloted until summer 2009, before a final agreement is sought. Step 9 – Publish results in the EDU Annual report Please return this form and where appropriate attach a copy of the amended policy or practice or appropriate data to the EDU for annual reporting The guidance and processes for Structural Change Committee and Redundancy Committee concerning selection pools can be viewed at http://www.gla.ac.uk/services/humanresources/policies/p-z/redundancymgt/mgrguidepools/ Step 10 – Regular review This will be reviewed when the policy is next updated in summer 2009. Signing off process – for owning Faculty, Department or Service Name/Signature of EIA owner Date of completion Ian Black 12 February 2009 4 Signing off – Equality and Diversity Unit Received date Approved Actions 12 February 2009 Yes X No Publish, return for review, return and discuss, request evidence, incomplete form…. Date Signature 12 February 2009 Naseem Anwar Equality and Diversity Unit 12A The Square, Glasgow G12 8QQ Email: equality@gla.ac.uk Tel: 0141 330 1887 5 Appendix A Redundancy Protocol EIA Checklist When considering the selection criteria for Redundancy, managers are encouraged to consider the equality implications of the criteria chosen. Outlined below are criteria which should be avoided as this could be considered discriminatory or subjective.1 Length of continuous service (can be used in extremis as a tie-breaker where scores are the same, but must be objectively justified) Attitude (subjective) Attendance and timekeeping records (can be used but only with great care as they are potentially discriminatory against disabled and women post-maternity leave; the reasons for and extent of absences must be known and accurate, and disability and pregnancy-related absences discounted) Sickness absence records (narrower circumstance but similar problem to attendance records) Disciplinary records (only current warnings may be relevant) Age or similar criteria or effect (unless objectively justified) Last In, First Out [LIFO] (this may be potentially discriminatory as women may be more likely to be selected as they may have less service as a result of career breaks; and in some cases it could also amount to indirect age discrimination if it can be shown that a far higher percentage of short service employees fall within a pool) This information has been taken from University of Glasgow’s HR Guidance Notes on redundancy Pools & Selection 1 6