NOT PROTECTIVELY MARKED
IPCC Equality Analysis (EA) Template
1. Title of policy/practice/activity/decision being assessed: Revised IPCC statutory
guidance
2. Name of assessor/Author: Sarah Morley
3. Lead director: Amanda Kelly
4. Date of assessment: 06/01/14
5. Version number: 2
6. TRIM record reference for current/previous versions: IPCC/10280-010 / IPCC/10280009
7. Date of next review: January 2015
8. What are you assessing?
Section 22 of the Police Reform Act 2002 gives the IPCC the ability to issue statutory guidance
to local policing bodies, chief officers and people serving with the police. The statutory guidance
gives guidance on dealing with complaints, conduct matters and death or serious injury matters.
It is one of the ways in which the IPCC assists local policing bodies and forces to comply with
their legal obligations and achieve high standards in the handling of complaints, conduct and
death and serious injury matters.
This EA assesses the content of revised statutory guidance developed in 2012. An EA was
originally completed in November 2012. This is an updated version of that review as the
guidance has been in operation for just over 12 months. The only change to the EA is in the
ongoing monitoring process for the guidance. No other changes were found to be necessary as
there have been no changes to impact.
9. Will service users from different protected groups or who speak Welsh be affected by
the policy/practice/activity/decision? How are they likely to be affected?
The guidance is primarily aimed at professionals within the police service and local policing
bodies. It will, however, be publicly available so that members of the public can access it. The
statutory guidance will also be published in Welsh so that it is accessible to those who speak
Welsh.
The statutory guidance includes content about the accessibility of the complaints system.
Specifically, it mentions:
 children and young people,
 people with learning difficulties,
Equality Analysis – Revised Statutory Guidance – Review of EA Jan 2014
Page 1 of 4
NOT PROTECTIVELY MARKED




people with mental health difficulties, people whose first language is not English,
people whose most effective form of communication is through the spoken not the
written word
people whose effective means of communication is sign language, and
people who are vulnerable or disadvantaged in some other way.
The guidance advises local policing bodies and forces about actions to be taken to assist
people falling within these categories to access the police complaints system. This should
promote effective engagement in the complaints system for these groups and positive actions
by police forces and local policing bodies.
The guidance also contains general content about dealing with allegations of discriminatory
behaviour throughout the main body of the guidance. This should assist local policing bodies
and police forces to effectively deal with such allegations made by protected groups.
A public consultation was carried out on the statutory guidance. The consultation was sent to a
wide variety of groups including groups representing the interests of protected groups and
people who speak Welsh. Responses were received from the Children’s Commissioner in
England, the Children’s Commissioner for Wales and the London Gypsy and Traveller Unit.
Feedback from these groups, particularly in terms of the accessibility of the complaints system,
was incorporated into the content of the guidance.
It is not anticipated that the statutory guidance will have a negative effect on any of the
protected groups or people who speak Welsh.
10. Will external stakeholders from different protected groups or who speak Welsh be
affected by the policy/practice/activity/decision? How are they likely to be affected?
The effects of the statutory guidance for non-police stakeholders from protected groups or who
speak Welsh reflect those for service users as they relate mainly to the accessibility of the
guidance and the accessibility of the police complaints system.
Police stakeholders will be applying the guidance. For officers and members of police staff who
speak Welsh, the guidance will be available in Welsh. It is not anticipated that there will be any
other effects on protected groups or those who speak Welsh.
11. Will commissioners or staff from different protected groups or who speak Welsh be
affected by the policy/practice/activity/decision? How are they likely to be affected?
IPCC commissioners and staff will use the guidance to assess the work of police forces and
provide them with support. For commissioners and staff who speak Welsh, the guidance will be
available in Welsh. It is not anticipated that there will be any other effects on protected groups
or those who speak Welsh.
Equality Analysis – Revised Statutory Guidance – Review of EA Jan 2014
Page 2 of 4
NOT PROTECTIVELY MARKED
12. Does this policy/practice/activity/decision offer any potential to improve our
understanding of the needs or experiences of people in different protected groups?
As part of the development of the statutory guidance a 12 week public consultation was carried
out. During this period, we received feedback which can be used in developing oversight and
confidence work and other communications materials, for example the benefits of using different
communication channels such as videos explaining the complaints system on youtube which
may be more accessible than written materials for young people or people with low literacy.
Feedback from the consultation has been shared across directorates so that it can feed into
different areas of work.
13. Have you considered making any changes as a result of this EIA to respond to
negative impact, or issues arising from research or consultation? What did you consider
or do?
Changes to the guidance had already been made as a result of consulting with people
representing the interests of people in different protected groups prior to completing this EA. For
example, content was added suggesting where information about the police complaints system
should be available, additional support that children and young people may need and advocacy.
The EA has not identified any further areas of negative impact.
14. Have you identified any issues or concerns which need to be dealt with by someone
else? If so, what are these issues and who have you passed them to?
As noted above, feedback in the public consultation touched on the IPCC’s oversight work and
communications materials. These have been passed on to the lead for oversight and
confidence work and the Head of Strategy and Communications.
15. Do you need to monitor or review the ongoing effect of the
policy/practice/activity/decision, if so how do you plan to do this?
Queries about statutory guidance have been kept under review since it was published in
November 2012. No need for immediate change has been identified and this review method will
continue. Additionally, further change to legislation is expected during 2014 so the statutory
guidance will be reviewed as part of the implementation of this change.
16. Does the policy/practice/activity/decision help us to work towards current corporate
equality objectives? If so, which ones?
The statutory guidance helps us work towards the following corporate equality objectives
 identify and respond to emerging issues in policing, complaint handling, and
investigations
 work to narrow the access, confidence, and awareness gap
Equality Analysis – Revised Statutory Guidance – Review of EA Jan 2014
Page 3 of 4
NOT PROTECTIVELY MARKED
17. Has your directorate equality champion provided feedback:
YES
18. Is this EIA suitable for publication?
YES
19. Has your project board, or line manager approved this document:
YES
20. Have you TRIM’d this document?
YES
Equality Analysis – Revised Statutory Guidance – Review of EA Jan 2014
Page 4 of 4