Equality Impact Assessment 5. EQUALITY IMPACT ASSESSMENT TEMPLATE UPDATED FOR 2007/08 Leisure Facilities Strategy For further information please contact the Corporate Equalities Team on 020 7364 4723 1 Equality Impact Assessment EQUALITY IMPACT ASSESSMENT Name of the policy or function being assessed: Leisure Facilities Strategy Directorate Communities, Localities and Culture Date Impact Assessment completed Is this a policy or function? Policy Function Is this a new or existing policy or function? New Existing Names and roles of the people carrying out the Impact Assessment: (Explain why the members of the impact assessment team were selected i.e. the knowledge and experience they bring to the process). 1. 2. 3. 4. 5. Service Head Signature Date Once you have filled in this document please send a copy to the Diversity and Equalities Team. If you have any questions regarding this form please call the Diversity and Equalities Team. For further information please contact the Corporate Equalities Team on 020 7364 4723 2 Equality Impact Assessment SECTION 1 AIMS AND IMPLEMENTATION OF THE POLICY For further information please contact the Corporate Equalities Team on 020 7364 4723 3 Identifying the aims of the policy1 What is the policy? What is the aim, objective, or purpose of the policy? Equality Impact Assessment The Council’s vision is to improve the quality of life for everyone living and working in Tower Hamlets. It is a vision that is shared by all partners within the Tower Hamlets Partnership, which comprises the Council and other public service providers, including: businesses, faith communities and the voluntary and community sector. The aim of the Leisure Facilities Strategy is: To provide a framework for the development of leisure facilities. To set out the clear aspirations of Tower Hamlets Council in the provision of community leisure facilities, whether through private, voluntary or public partnerships. To provide a plan and framework for the future, taking into account the major population changes predicted. To provide a framework to act as a catalyst in levering funding from a range of local and national bodies. The provision of high quality, accessible leisure facilities in the Borough will contribute significantly to the achievement of this vision, notably by supporting improvements in outcomes relating to health, community cohesion, economic and social wellbeing. The Leisure Facilities Strategy for the borough of Tower Hamlets provides the overall framework for investment in the Council’s leisure facilities over the coming ten years The Strategy is informed by and consistent with national, regional and local strategic drivers and best practice guidance. It will make a significant contribution to the development of spatial planning policy in Tower Hamlets by providing a robust evidence base that outlines the leisure facilities needed to serve the growing and changing population. This will be used to inform the Borough’s emerging Local Development Framework Core Strategy and Corporate Asset Strategy and help give effect to the Community Plan and Local Area Agreement. To deliver this clear spatial vision for leisure facilities in the Borough, the Strategy examines the current supply of leisure facilities in the Borough (taking into account public, commercial and dual use facilities); compares this to the on-going demand for facilities (based on the latest population projections and a nationally recognised modelling tool); identifies gaps in current and future provision; and assesses the quality, suitability and efficiency of existing leisure facilities, with particular reference to residents’ different gender, cultural, religious and physical needs. The Strategy focuses primarily on questions of infrastructure capacity and the current and future need for leisure facilities, and does not make any recommendations in relation to other issues such as service operations, pricing policies or engagement. It is however recognised that these issues may impact on the accessibility of facilities and other avenues are in place to ensure they are adequately addressed. It is important to note that the Strategy is not an investment programme. The Strategy has been created to provide the overall decision making framework for potential future investment in the Council’s leisure facilities over the coming ten years. As a long term strategy it would not be desirable or practical to pre-determine Council spend or funding 1 Please note the term ‘Policy’ is used for simplicity. The broad term can also refer to a function or a service. channels at year one and it does not seek to do this. It supports the Community Plan and forms an essential support to the Local Development Framework by providing a clear For further information please contact the Corporate on 020 7364 4723 analysis of supply and demand thatEqualities followsTeam a nationally recognised model for leisure facilities. 4 Equality Impact Assessment For further information please contact the Corporate Equalities Team on 020 7364 4723 5 Equality Impact Assessment For further information please contact the Corporate Equalities Team on 020 7364 4723 6 Equality Impact Assessment Rationale behind the policy and its delivery (Please state the underlying policy objectives which underpin this service and what they are trying to achieve). Are there associated objectives of the policy? If so, what are they? What outcomes do we want to achieve from this policy? What factors could contribute/detract from the outcomes? Based on the research and evidence collected, three key strategic objectives have been identified that form the basis of the Leisure Facilities Strategy over the next ten years. These are: Strategic Objective One: Address gaps in provision and provide facilities in areas of low participation A key objective of the Leisure Facilities Strategy is to address gaps in the provision of swimming pools, sports halls and health and fitness stations now and in the future in order to satisfy demand from residents. A supply, demand and quality analysis has demonstrated that in broad terms, the following additional facilities will be required by 2018: 1 to 2 additional swimming pools – needed primarily in the east and north east of the Borough Additional four-court sports halls – needed primarily in the centre of the Borough and the Isle of Dogs. Initial planning should consider 3 to 4 additional sports halls. Re-provision or upgrade of existing facilities to ensure they are fully accessible to all residents, taking into account different cultural, religious and physical needs. The Strategy proposes a range of strategic solutions that will increase the capacity of the leisure facilities network. Strategic Objective Two: Generate energy and economic efficiencies The Government and the Council have set ambitious targets for the reduction of carbon emissions over the next ten years. Leisure facilities have high energy needs and therefore the potential to contribute significantly to supporting the achievement of these objectives. For this reason the Leisure Facilities Strategy proposes strategic solutions to make the leisure facilities more energy efficient. In the current financial and economic climate of more constrained funding for local government alongside ever-growing demands from residents for a more personalised, innovative and high quality service, the Leisure Facilities Strategy will also look for opportunities to generate economic efficiencies that will reduce the subsidy requirement for its leisure facilities and make best use of the Council’s wider asset portfolio to deliver value for money for residents – including capitalising on opportunities to ensure leisure facilities reflect the most economical design model, and leveraging off the Building Schools for the Future investment programme to increase community sports hall capacity at lowest cost to the Council. Strategic Objective Three: Improve the quality and suitability of leisure facilities For further information please contact the Corporate Equalities Team on 020 7364 4723 7 Equality Impact Assessment The Council has invested significantly in the development and improvement of its leisure facilities in recent years. The latest annual resident survey results demonstrate that residents feel these developments have improved their experience of leisure and sports facilities in the Borough, with a consistent year on year increase in resident satisfaction and ratings that outperform the London average. In order to maintain this positive trend it is essential that leisure facilities continue to be of a high quality. The Leisure Facilities Strategy proposes strategic solutions to ensure that the Council actively anticipates and plans for major future investments in existing facilities, and continues to make improvements that increase the quality and suitability of facilities for all residents. These objectives are informed by an understanding of the key characteristics of an ideal leisure facilities network (taking into account national, regional and local strategic drivers and best practice guidance) and an assessment of the extent to which the existing network is consistent with this ideal model. It will not necessarily be possible to achieve the full implementation of such a network given spatial and financial constraints. However, the model serves as a benchmark against which individual solutions can be assessed. Broadly speaking, an ideal leisure facility network for Tower Hamlets should: address gaps in provision now and in the future, in particular for swimming pools and sports halls locate major facilities where people will use them most and where they will support the Local Development Framework (e.g. in town centres and transport hubs) provide dry facilities alongside all swimming pools in order to reduce the subsidy requirement focus additional sports hall capacity on school sites to maximise value for money, providing this is supported by the analysis and adequate community access can be secured offer state of the art facilities that are fully accessible to all residents, taking into account cultural, religious and physical needs ensure facilities are designed to be operationally efficient comprise facilities that are energy efficient and carbon reducing. Factors that contribute/detract from the outcomes? Negative factors Funding for Local Government reduced Section 106 contributions reduced due to economic downturn Positive factors Increased participation in sport due to the hosting of the 2012 Olympic and Paralympic Games Local Government local targets to increase health and well-being of residents by implementing localised programmes to increase sports and physical activity and reduce obesity For further information please contact the Corporate Equalities Team on 020 7364 4723 8 Equality Impact Assessment Who is affected by the policy? Who is intended to benefit from it and how? Who are the main stakeholders in relation to this policy? What outcomes would other stakeholders want from this policy? Are there any groups, which might be expected to benefit from the intended outcomes but which do not? Leisure facilities play an important role in enabling the residents of Tower Hamlets to take part in sport and physical activity by providing an accessible and welcoming environment for people of all ages, ethnicities, religious beliefs and backgrounds. The main stakeholders can be described as being: The residents of Tower Hamlets Those working in or visiting the borough A breakdown by equalities themes could include: Black and minority ethnic people Women Younger people Older people Disabled people Gay, lesbian, bi-sexual and transgendered people People on low incomes People following particular faiths The Leisure Facilities Strategy will also form an essential overarching framework and will be used to inform further strategic policy. The Strategy will therefore benefit all those who have the task of providing innovative and sustainable sports and recreational facilities that meet the expectations of the community. These include: Internal officers Architects/Planners Contractors Key partners For further information please contact the Corporate Equalities Team on 020 7364 4723 9 Equality Impact Assessment Promotion of good relations between different communities (How does the policy or function contribute to better Community Cohesion?) How do you promote good relations between different communities you serve based on mutual understanding and respect? What opportunities are there for positive cross cultural contact between these communities to take place e.g. between younger and older people, or between people of different religious faiths? Sustaining and growing participation in sport and physical activity through the provision of high quality, accessible leisure facilities is an important objective on the Government’s agenda, owing to the contribution of sport and sports facilities to a number of priority social and community outcomes. These shared national priorities and their implications for sport are reflected in the Council’s strategic documents including the Community Plan, the Local Area Agreement and the Children and Young People’s Strategic Plan. Of particular note is the cross-government Living Places initiative. This aims to ensure that all communities, particularly those experiencing housing-led growth and regeneration, can benefit from cultural and sporting opportunities by ensuring that sport and culture are embedded in the spatial development of towns and cities. Similarly, Our Shared Future, the report from the Commission on Integration and Cohesion, acknowledges the role that sport and leisure facilities play in bringing people from different backgrounds together. It identifies sports, culture and leisure as one of the four areas where a stronger focus on growing interaction between different groups would help to build integration and community cohesion, and argues that culture and sport should move from being seen as an ‘optional extra’ to being integral to the lives of individuals and the well-being of communities. It is submitted that the service actively aids community cohesion by not only targeting specific groups but also by engaging, with these groups, as far as feasible, in an inclusive and integrated manner. Although it has not been possible to provide definite evidence of this cohesion, the anecdotal evidence would support hypothesis, for example, that young people from varying backgrounds working and playing together will ultimately build a more cohesive and integrated society in the future. This may require specific monitoring. (Specifically identify the relevance of the aims of the policy to the equality target groups and the Council’s duty to eliminate unlawful racial discrimination, promote equality of opportunity and good relations between people of different racial groups). Leisure facilities play an important role in enabling the residents of Tower Hamlets to take part in sport and physical activity by providing an accessible and welcoming environment for people of all ages, ethnicities, religious beliefs and backgrounds. Sustaining and growing participation in sport and physical activity is an important objective on the Government’s agenda, owing to the contribution of physical activity to a number of priority social outcomes including health, community cohesion and safety, meeting the needs of children and young people, and economic prosperity. A summary of the evidence in these areas is outlined below. Sport England have summarised the research relating to the health impacts of sport and found that overall, regular participation in sport and physical activity can: For further information please contact the Corporate Equalities Team on 020 7364 4723 10 Equality Impact Assessment reduce the risk of both physical health issues such as diabetes, cardiovascular disease and some types of cancer; and mental health issues such as depression and anxiety help to address obesity by supporting good weight management help people to recover from an illness or injury and prevent the subsequent reoccurrence of the problem. There are some specific health benefits from physical activity that accrue to different age groups. For young people, regular participation in sport and physical activity supports healthy growth (for example, of the musculoskeletal and cardio respiratory systems), reduces health risks such as high blood pressure, and supports weight management. Physical activity also encourages young people to adopt a healthy lifestyle by providing them with knowledge and skills that help to reduce the risk of some health issues such as substance misuse or teenage pregnancy. Laying the foundations for a healthy and active lifestyle in adolescence also increases the likelihood that this will continue into adulthood. For older people, regular participation in sport and physical activity improves fitness, strength and mobility. This can make it easier for them to perform daily tasks and reduces the incidence of falls – both of which can enable older people to live more independent lives. Sport and physical activity play a role in building community cohesion by creating opportunities for social engagement that bring people from different backgrounds, including ‘hard to reach’ groups, together. This can help to create a greater shared understanding of different ways of life, thereby breaking down barriers that exist in the wider community and fostering stronger social networks. Sports facilities themselves can help to improve people's sense of well being in the place they live. 2 Policy Priorities: (How does the policy fit in with the council’s wider aims? Include Corporate and Local Strategic Partnership Priorities) How does the policy relate to other policies and practices within the council? What factors/forces could contribute/detract from the outcomes? How do these outcomes meet or hinder other policies, values or objectives of the council? There are three broad types of policies that provide the context for the development of a Leisure Facilities Strategy for Tower Hamlets: Policies relating to the delivery of sport (which sports, for whom, and how they are delivered) Policies relating to spatial planning and building design (the facilities in which sports are played) Policies relating to the wider economic, social and cultural agenda (that incorporate For further information please contact the Corporate Equalities Team on 020 7364 4723 11 Equality Impact Assessment Outcome s National Public Service Agreements (PSA) & Departmental Indicators for Strategic Objectives (DSO) pertaining to the National Local Indicators Government Stronger N1 8 – adult PSA 21 – build more cohesive, empowered and active and participation communities Safer in sport and DCSM DSO 1 – encourage more widespread Commun active enjoyment of culture, media and sport ities recreation DCSM DSO 4 / PSA 22 – deliver a successful Olympic Children NI 57 – Games and Paralympics Games with a sustainable and children and legacy, and get more children and young people taking Young young part in high quality PE and sport People people’s DCSF SO / PSA 12 – improve the health and wellparticipation being of children and young people in high PSA 14 – increase the number of children and young quality PE people on the path to success and sport NI 110 – young people’s participation in positive activities elements relating to the delivery of sport and sports facilities.) This section outlines the key national, regional and local policy documents pertaining to these three areas and analyses their implications for this Strategy. Following the 2007 Comprehensive Spending Review the Government established four national priority outcomes for local authorities encompassing a range of performance indicators and cross-government strategic objectives where the Government is looking to achieve better outcomes. Those relating most directly to sport and physical activity are outlined in the table below. Contribution of the Leisure Facilities Strategy to the National Indicator Set These national priorities have been translated into tangible outcomes, deliverables and performance indicators specific to the London Borough of Tower Hamlets – as set out in the Tower Hamlets 2020 Community Plan, The Tower Hamlets Children and Young People’s Strategic Plan 2009-2012, The Tower Hamlets Local Area Agreement 2008-2011, the Council’s annual Strategic Plan and relevant Directorate Business Plans. The Leisure Facilities Strategy contributes to many of the outcomes in these strategic planning documents – the most significant areas of contribution are outlined in the following table. There are two key planning policy documents of particular relevance to the Leisure Facilities Strategy – Planning Policy Guidance 17: Planning for open space, sport and recreation (PPG17) and The London Plan. PPG17 outlines the Government’s expectations with regards to nationwide planning for For further information please contact the Corporate Equalities Team on 020 7364 4723 12 Equality Impact Assessment open space, sport and recreation. It strongly recommends that local authorities carry out a needs assessment and audit of existing facilities to understand how well they are meeting current and future community needs and to consequently inform decisions about new facilities and upgrades to existing provision. PPG17 also recommends that local authorities: o ensure that recreational facilities are accessible by walking, cycling and public transport, and can be easily accessed by people with disabilities o locate more user-intensive facilities in town centres, and o enhance the range and quality of existing facilities. The London Plan is the Mayor's 20-year spatial development strategy for London and local authorities are required to comply with the spatial policies set out within it. The key policies relating to sport and leisure facilities echo the expectations set out in PPG17. Although the new Mayor of London proposes to make some changes to the London Plan to better reflect his priorities, in the case of leisure facilities these would largely serve to further reinforce existing policies and further highlight the importance of providing good facilities for play, sport and recreation. By explicitly examining the supply of leisure facilities in the Borough, comparing this to the ongoing demand for facilities in order to identify gaps in current and future provision, and assessing the quality, suitability and efficiency of existing leisure facilities, the Leisure Facilities Strategy gives effect to this best practice guidance. The emerging Tower Hamlets Local Development Framework reflects national and regional planning, housing and regeneration policies, all of which acknowledge that leisure facilities are essential in the development of new and existing places. Indeed, these planning policies provide the context for the development of the Leisure Facilities Strategy as they require local authorities to undertake a community needs analysis and audit of existing facilities for sport and recreation to understand how well they are meeting current and future needs – the results of which form the basis of the recommendations in this Strategy. They also set the broad parameters for the ongoing maintenance and upgrades of existing facilities – namely that they be open and accessible to all groups, located in town centres and aligned with national and local climate change and energy efficiency policy agendas. The development of leisure facilities in Tower Hamlets is taking place in the unique backdrop of the London 2012 Olympic and Paralympic Games and the Thames Gateway Development. Both of these infrastructure projects will impact on the network of leisure facilities that is accessible to Tower Hamlets residents and are taken into account in planning the evolution of the current network. Other policy relating to wider economic, social and cultural agenda include: Choosing Health : Making Health Choices Easier Choosing Activity Action Plan Healthy Weight, Health Lives in Tower Hamlets 2008-2011 For further information please contact the Corporate Equalities Team on 020 7364 4723 13 Equality Impact Assessment How the policy is implemented (How is, or will, the policy be put into practice and who is, or will be, responsible for it?) Who defines or defined the policy? Who implements the policy? How does the council interface with other bodies in relation to the implementation of this policy? Is the service provided solely by the Department or in conjunction with another department, agency or contractor? If external parties are involved then what are the measures in place to ensure that they comply with the Council’s Equal Opportunities policy? Given the complex and dynamic nature of the proposed solutions, the Leisure Facilities Strategy can only serve as an overarching document outlining the Council’s strategic ambitions. It will enable the Council to develop investment proposals with partners within a clear strategic framework and understand of residents’ needs. This is vital for informing the Borough’s spatial planning processes and preparations for the proposed Community Infrastructure Levy, and for securing funding from external sources. It is recognised that this Facilities Strategy will inform the decision making process for the provision of facilities for the next 10 years, and will help shape the future of sports provision within the Borough. A key objective for this strategy will be to prepare a document that forms part of the PPG 17 assessment and, thus, inform the Local Development Framework (LDF). The Strategy will: Provide an input into other Council agendas, such as, health, regeneration Advise on the future suitability and sufficiency of the present stock of facilities to include the potential for refurbishing, extending, developing or decommissioning. Guide local strategic planning Raise political awareness to difficult decisions Co-ordinate the approach to future sports provision with LEAs, including in relation to the BSF programme Consider and provide clear strategic direction on the important link between sports development and facility development. Individual solutions proposed within the Strategy will need to undergo further detailed assessment that take into account the full technical and financial implications of each proposal, as well as emerging strategic developments in the Council’s wider corporate property portfolio. The key deliverables and milestones needed to take these solutions forward are outlined in the Leisure Facilities Strategy Action Plan. This will be reviewed and reported on to the Asset Management Board every six months. All infrastructure proposals will be subject to full Member scrutiny and Cabinet approval before they can be taken forward to implementation stage. All external parties involved in the delivery of the Strategy are required to have appropriate and demonstrable equalities policies and practices in place For further information please contact the Corporate Equalities Team on 020 7364 4723 14 Equality Impact Assessment For further information please contact the Corporate Equalities Team on 020 7364 4723 15 Equality Impact Assessment SECTION 2 CONSIDERATION OF DATA AND RESEARCH List all examples of quantitative and qualitative data available that will enable the impact assessment to be undertaken (include information where appropriate from other directorates, Census 2001 etc.) Quantitative data: GLA 2007 Round PLP Projections (Low) Census 2001 Active People Survey (Ipsos MORI) School Sports Survey 2003/04 – 2007/2008 Qualitative data: TellUs3 Survey Tower Hamlets Community Plan 2020 Local Development Framework Core Strategy Consultation: July – September 2008 Tower Hamlets Children and Young People’s Strategic Plan Consultation Equalities profile of users or beneficiaries (Use the Council’s approved diversity monitoring categories and provide data by target group of users or beneficiaries to determine whether the service user profile reflects the local population or relevant target group or if there is over or under representation of these groups) Government is still undertaking detailed analysis of 2007/08 Active People data for specific demographic groups at local authority level. Given the importance of population characteristics in planning for fully accessible leisure facilities, the Strategy draws on the 2005/06 data. A comparison of Borough figures against the London average and the national picture is shown in the table below with areas of notable difference highlighted in red (lower) or green (higher). Figure 1: Active People Survey 2005/06: participation rates by population group Category Borough London average National average Overall 19.7% 21.3% 21% Male 22.2% 23.8% 23.7% Female 17% 18.9% 18.5% 16-34 23% 27.9% 30.2% 35-54 21% 21.4% 22.4% For further information please contact the Corporate Equalities Team on 020 7364 4723 16 Equality Impact Assessment Category Borough London average National average 55 years + 7.4% 11.1% 9% White 22.5% 22.5% 21.2% Non white 15.8% 18% 18.6% Limiting disability 6.7% 9% 8.8% No limiting disability 21.6% 23.1% 23.3% Socio-Economic Group A 26.9% 25.8% 25.4% Socio-Economic Group B 20.5% 16.8% 19.2% Socio-Economic Group C1 18.3% 23% 21.3% Socio-Economic Group C2DE 13.7% 15.1% 15.9% The above figures indicate that, in line with national trends, rates of participation in the Borough are generally lower amongst: women older people black and minority ethnic (BME) groups those from C2, D and E social groups (National Statistics Socio Economic Classification 5,6,7, 8) Key issues relating to these groups can be summarised as follows: participation rates among women in the Borough (17.0%) are lower than the London (18.9%) and the national (18.5%) average participation among non-white groups is lower than the regional average with only 15.8% taking part in 30 minutes of exercise three times a week compared with 18% in London as a whole only 23% of 16-34 year olds take part in 30 minutes of exercise three times a week, which is almost 5% lower than in London as a whole and 7% lower than the national average. This is particularly significant given the very high percentage of young people in the Borough and might imply that alternative approaches to the delivery of leisure provision may need to be explored. with participation rates for the A and B social groups being higher than the London and National averages and those for the C1 and C2DE being significantly lower, For further information please contact the Corporate Equalities Team on 020 7364 4723 17 Equality Impact Assessment differences in participation by socio-economic group are further accentuated in the Borough – it is a picture of extremes. Further analysis of the data provides an estimated participation rate for different parts of the Borough, which reinforces this final point. The data presented in the map below suggests that there are pockets of higher participation, mainly towards the south of the Borough, in the wards of St Katherine’s & Wapping, Shadwell, Millwall and Blackwall & Cubitt Town. Although this data is based on estimates rather than actual figures, the results suggest there are clear areas of extremely low participation around the centre and east of the Borough, particularly in Bromley-by-Bow, Poplar, Mile End and Stepney Green. This suggests that the Borough has populations with varying needs and with significantly different current participation habits. Usage by members 2007 – 2008 White UK 203571 Asian Other 6500 Banglades h 83640 Africa n 9620 Chines e 7909 Indian 7890 Caribbea n 5974 Asian 1025 Black Other 2641 Other 1943 User profile of each centre From a Sport England National Benchmarking exercise carried out in August 2006, two Leisure Centre’s were selected and the results based on a sample of 365 users from both Mile End Park Leisure (MEPLC) Centre and Whitechapel Sports Centre (WSC) are as follows: MEPLC Male 56% Female 11 - 19 44% 13% 20 - 59 85% 60+ 2% White 49% Other 51% Disability 11% Female 11 - 19 36% 18% 20 - 59 81% 60+ 1% White 31% Other 69% Disability 6% WSC Male 64% From data collected 2007 / 2008 user profiles are as followsYork Hall (groups representing less than 3% are not included) Male 20 – 29 3130 38% Female U20 4069 49% 4217 51% 1056 13% White White Banglades 30 - 39 40 - 49 50+ 2313 28% 1032 12% 755 9% Other For further information please contact the Corporate Equalities Team on 020 7364 4723 18 Equality Impact Assessment other 9% 79% h 5% 7% MEPLC Male Female U20 7410 48% 4086 27% 7922 52% White 42% Banglades h 32% 20 – 29 5497 36% White other 8% 30 - 39 40 - 49 3334 22% Africa n 4% 50+ 1498 10% Asian Other 4% 917 5% Chines e 4% Other 6% WSC Male Female U20 2827 48% 588 10% 3018 52% White 40% Banglades h 40% 20 – 29 2546 44% White other 9% 30 - 39 40 - 49 1608 28% Asian Other 4% 50+ 663 11% 440 7% African Indian Other 2% 2% 3% John Orwell S.C. Male Female U20 1451 70% 630 30% 366 18% White White other 15% 64% 20 – 29 731 35% 30 - 39 40 - 49 589 28% 244 12% Bangladesh Indian Other 13% 3% 5% 50+ 151 7% St Georges Male 1579 56% Female U20 1228 44% 635 23% White Bangladesh 58% 21% 20 – 29 844 30% White other 11% 30 - 39 40 - 49 718 26% Chines e 3% 369 13% 50+ 241 8% Other 7% For further information please contact the Corporate Equalities Team on 020 7364 4723 19 Equality Impact Assessment Tiller Male Female U20 2079 53% 1876 47% 720 18% white White other 11% 71% 20 – 29 1276 32% Banglades h 6% 30 - 39 40 - 49 1072 27% Chines e 3% 50+ 566 14% 321 9% Asian Other 3% Indian Other 3% 3% Langdon Park (Dual Use) Male 356 82% Female U20 78 18% 155 36% White Bangladesh 43% 28% 20 – 29 119 27% Africa n 9% 30 - 39 40 - 49 95 22% White other 6% 48 11% Indian 5% 50+ 17 4% Chines e 4% Other 5% Equalities profile of staff (Indicate profile by target groups and assess relevance to policy aims and objectives e.g. Workforce to Reflect the Community. Identify staff responsible for delivering the service including where they are not directly employed by the council). Please refer to the Sports and Physical Activity EqIA Evidence of Complaints against the service on grounds of discrimination (Is there any evidence of complaints either from customers or staff (Grievance) as to the delivery of the service, or its operation, on the equality target groups?) Please refer to the Sports and Physical Activity EqIA For further information please contact the Corporate Equalities Team on 020 7364 4723 20 Equality Impact Assessment Barriers (What are the potential or known barriers to participation for the different equality target groups?) People may be excluded from accessing leisure services for a range of reasons: These include: Lack of awareness that facilities exist – e.g. if information is not available to people with visual impairments; people for whom English is not a first language, and people with low literacy skills etc. Lack of appropriate access for people with a disability i.e. wheelchair access, lifts etc. Lack of appropriate facilities for people with particular religious needs; single sex sessions Inability to afford travel to centres The safety of leisure facilities for the elderly / vulnerable / female visitors Feeling uncomfortable in using leisure facilities because of the attitude of staff or other users e.g. disabled people; older people; LGBT Recent consultation exercises carried out (Detail consultation with relevant interest groups, other public bodies, voluntary organisations, community groups, trade unions, focus groups and other groups, surveys and questionnaires undertaken etc. Focus in particular on the findings of views expressed by the equality target groups) Community Plan Consultation: August 2007 – January 2008 To inform the development of the Tower Hamlets Community Plan 2020 a consultation exercise was undertaken with residents to identify what they see as the priorities for the Borough over the next 10-15 years. Feedback was gathered through Borough-wide workshops and consultations and an online survey. Some of the feedback relates directly to the Leisure Facilities Strategy. In particular: there is some support for more leisure centres although this was not a unanimous view, with some residents questioning the value for money of leisure centres there should be more dedicated leisure centre facilities and activities for women and girls, and facilities that are more culturally sensitive in general. For further information please contact the Corporate Equalities Team on 020 7364 4723 21 Equality Impact Assessment More broadly, the consultation identified a widely shared view about the need to provide more leisure and recreational facilities for children and young people as a way of tackling anti-social behaviour, as well as more amenities aimed at older people. Local Development Framework Core Strategy Consultation: July – September 2008 To inform the development of the Tower Hamlets Local Development Framework Core Strategy a consultation exercise was undertaken with the public, private and community sectors as well as residents between July and September 2008 seeking their feedback on the options and alternatives relating to different spatial policies.3 Among other things it asked people to express a preference for one of two overarching strategic options for the development of infrastructure across the Borough. Option A proposed to concentrate development in well-connected and strategically-located town centres, whereas Option B proposed more organic growth in which new places emerge from individual development sites as opportunities allow. The results of the consultation indicated that concentrating develop in town centres marginally greater support (28%) than organic growth, (22%) however there were also many requests to combine elements from both options (38%). This strategic direction is reflected in the strategic options contained within the Leisure Facilities Strategy. The future development of detailed options will be aligned with the detailed policies set out in the final LDF Core Strategy, which is due to be completed by late 2009. Children and young people Tower Hamlets Children and Young People’s Strategic Plan The Tower Hamlets Children and Young People’s Strategic Plan 2006-2009 was refreshed in 2008 and took into account previous consultations that had been undertaken by the Tower Hamlets Youth Service, including those that canvassed young people’s feedback on sports. Amongst the findings, many young people said they were interested in taking part in sporting activities but face a number of barriers to doing so, including poor accessibility. Young people prefer to participate in sport in their local areas but there is a lack of local facilities available to them. To improve access to sporting activities young people want to see improvements to, and on-going maintenance of existing sports facilities, more indoor sports centres, and more local gyms for use at lower prices. Tellus3 Survey: March – June 2008 The 2008 TellUs3 Survey of children and young people in Years 6, 8 and 10 across England asked their views about their local area, including questions covering the five Every Child Matters outcomes.4 The responses for the London Borough of Tower Hamlets were collated, weighted and compared against the national average and statistically significant differences 3 London Borough of Tower Hamlets (2008) Local Development Framework Core Strategy: Options and Alternatives Consultation Summary Report. London: London Borough of Tower Hamlets. 4 Ofsted (2008) Tellus3 Local Authority Report: Tower Hamlets, September 2008. For further information please contact the Corporate Equalities Team on 020 7364 4723 22 Equality Impact Assessment in responses were highlighted, including whether the difference was a positive or negative outcome for the Borough. The following findings have relevance to the Leisure Facility Strategy: When asked to identify which out of a list of activities they would like to go to that they don’t at the moment: o 38% of those surveyed said that they would like to go to the swimming pool (outside of school lessons), compared to 29% nationally (statistically significant difference) o 30% said that they would like to go to a sports club or class, compared to 20% nationally (statistically significant difference) o 36% said that they would like to go to the gym, compared to 38% nationally (statistically significant difference) When asked to identify which out of a list of activities would do the most to make their area a better place to live, 50% identified better sports clubs or centres, compared to 44% nationally – this is a statistically significant difference indicating a negative outcome, as it suggests that children and young people in Tower Hamlets feel that the quality of existing sports clubs and centres is more of an issue than their counterparts in the rest of the country. Ensuring the participation of young people in the 2012 Olympics and Paralympics: January – March 2008 As part of the Learning, Achievement and Leisure Scrutiny Lead Member’s work programme for 2007/08 a working group was established to examine what the Council is doing to ensure that young people, particularly young disabled people, can participate in sports leading up the 2012 Olympics and Paralympics. A survey of 300 young people was undertaken as part of this work stream. Of relevance to the Leisure Facilities Strategy are findings that: 34.8% of young people feel they do not know where to go to play sports in the Borough 22% feel they do not know enough about which sports are offered.5 Summary of findings from consultations with local residents Across these different consultations a number of themes were consistently raised that are relevant to the Leisure Facilities Strategy: Some support for increasing the number of leisure and sports facilities Support for locating sport and leisure facilities in town centres, in line with the emerging LDF Core Strategy Support for improving the quality and accessibility of facilities so that they cater to the needs of the wider community – especially children and young people, women and girls, and the Asian community. 5 London Borough of Tower Hamlets CAB Paper (2008) Report of the Scrutiny Review Working Group on Young People’s Participation in Sports Leading up to the Olympics, p.39. For further information please contact the Corporate Equalities Team on 020 7364 4723 23 Equality Impact Assessment The consultations also identified a range of other issues that are not directly relevant to the Leisure Facilities Strategy but which would need to be taken into account in the forthcoming sports development strategy for the Borough. In particular: Residents of all ages identify affordability as a major barrier to accessing leisure centres, gyms and other sporting facilities – they perceive these facilities as being expensive to access Similarly, they want to see a wider range of activities offered by leisure centres, particularly for children and young people, women and girls, and the Asian community, as well as better public information on what is on offer to support informed decision-making. Identify areas where more information may be needed and the action taken to obtain this data. (You will need to consider data that is monitored but not reported, data that could be monitored but is not currently collected and data that is not currently monitored and would be impossibly/extremely difficult to collect). Gaps in information: 1. People with learning disabilities 2. Traveller and Gypsy community 3. BME communities 4. Women 5. Newly arrived migrants/refugees/asylum seekers 6. Faith groups 7. LGBT groups Action needed: Contact local Third Sector and community organisations to ensure that hard-to reach groups are actively engaged in the process to improve and develop new leisure centre facilities Conduct a feasibility report for each proposed site option and ensure that each equalities strand and associated group are asked to inform on design. For further information please contact the Corporate Equalities Team on 020 7364 4723 24 Equality Impact Assessment SECTION 3 ASSESSMENT OF IMPACT Race – testing of disproportionate or adverse impact Identify the effect of the policy on different race groups from information available above. A key strategic objective of the Leisure Facilities Strategy is to ensure existing gaps in provision are addressed and to provide facilities in areas of low participation. This includes the re-provision or upgrade of existing facilities to ensure they are fully accessible to all residents, taking into account cultural, religious and physical need. Even though race or ethnicity is not directly stipulated, the Council is obliged by national legislation to ensure the full and equal access to leisure facilities regardless of the potential user’s or user’s racial or ethic background. How is the race target group reflected in the take up of the service? Tower Hamlets is one of the most diverse Boroughs in London. Bangladeshi residents form the largest group after White residents. Together these groups account for just 85% of the population. Current estimates do not provide breakdowns by ethnicity and the most up-todate source is the 2001 Census. This data can serve as a proxy for estimating the ethnic make-up of current and future populations. The detailed ethnic composition of Tower Hamlets is as follows White: 51.4% Bangladeshi: 33.4% Black African: 3.4% Other Asian: 3.2% Black Caribbean: 2.7% Mixed: 2.5% Chinese: 1.8% Other: 1.2% Other Black: 0.5% The Government’s Active People Survey 2005/06, indicates that participation rates among BME groups undertaking 30 minutes exercise 3 times a week (15.8%) is both lower than the London (18%) and National (18.6%) averages. Leisure centre membership and usage data reflects that take-up of sport and physical activity services by the local population. From the evidence above does the policy affect, or have the potential to affect, racial groups differently and if so do any of the differences amount to adverse impact or unlawful discrimination? For further information please contact the Corporate Equalities Team on 020 7364 4723 25 Equality Impact Assessment There are no identified adverse effects relating to adverse impact on racial groups. However, further information can be obtained from the Sports Strategy for measures relating to engagement of ethic groups in terms of leisure participation and sports development. If there is an adverse impact, can it be justified on the grounds of promoting equality of opportunity for one racial group or for another legitimate reason? Addressing participation of BME women by promoting and providing targeted sessions, may have create a negative impression on other more mainstream users Could the policy discriminate, directly or indirectly and if so is it justifiable under legislation? No (Include information on adverse impact between different racial groups) For further information please contact the Corporate Equalities Team on 020 7364 4723 26 Equality Impact Assessment Gender – testing of disproportionate or adverse impact Identify the effect of the policy on gender groups from information available above. The Strategy sets out the Council’s aim to ensure that adequate numbers of facilities are available, in geographical locations that are easily and safely accessible by public transport. Improving the quality of existing centres and providing new facilities in better, more accessible locations will encourage both male and female non-users to participate in accessing leisure activities delivered from leisure centres. How are the gender groups reflected in the take up of the service? According to the Active Peoples Survey 2005/06 participation rates for women undertaking 30 minuets of exercise, 3 times a week in Tower Hamlets (17%) is both lower than the London (18.9%) and National (18.5%) average. The data from Active People also demonstrates which activities are most popular with certain groups in Tower Hamlets. Whilst the vast number of smaller sports and responses means that taking a sport-by-sport approach is not statistically robust for the purposes of analysis at a local level, we have clustered the types of activity into four analysis groups to broadly reflect the sports which require use of the core indoor facilities the Strategy focuses on: aquatic sports (includes aqua aerobics, swimming, diving, scuba diving) keep fit and gymnastics (includes gym, pilates, yoga, weight training) racquet sports (includes squash and badminton) team games (includes football, basketball, volleyball, netball and cricket). This data has been compared against five other local authorities – Hackney, Islington, Lambeth, Lewisham and Newham – which are taken from the Institute of Public Finance (IPF) Nearest Neighbours grouping, to illustrate where particular trends in participation may lie which will have implications for the future facility mix and location of facilities in the Borough. Although not geographically adjacent these Boroughs are deemed comparable in socio-economic terms. This breakdown can be used to build up a picture of the types of activities that are taking place within the Borough and cross-tabulation of this data by gender gives a further indication of how future investment might be channelled. The key findings are summarised below. Aquatic sports Participation levels in aquatic activities are extremely variable. In males, the young adults (16-24 years) rate, at 5.9%, is the second lowest of the selected comparator group, above only Hackney (which has experienced well documented problems with the provision of swimming pools). However, participation rates amongst males in the 25-34 and 35-54 years age groups are at or towards the upper end. In females, the opposite trend is evident. The younger age group has a high participation rate, of 17.1%. However, participation levels then fall in contrast with the trend shown by For further information please contact the Corporate Equalities Team on 020 7364 4723 27 Equality Impact Assessment other authorities and, with a participation rate of 4% among females aged over 55, the Borough is the lowest ranked. Keep fit/gymnastic activity In keep fit/gymnastic activity, there is a clearer correlation with age than gender. While the younger ages in both sexes are broadly comparable with other selected local authorities, among adults over 55 years, participation levels in the Borough are by far the lowest, with 3.2% among males against an average of 8.8% and 5.4% among females against an average of 12.2%. Racquet sports Racquet sports are generally more popular among males than females in the Borough. While the participation rates among men are all broadly comparable with other authorities, in women, the rates are mainly towards the bottom end. In women aged 16-24 years the participation rate of 0.7% is the lowest of all the authorities and the 2.3% rate among women aged 25-34 years is the second lowest. Team games Despite having by far the highest participation rate among men aged 16-24 years (63.4%), participation then falls dramatically and levels among men aged 25-34 years become the lowest of all the authorities (14.2%). This factor has been highlighted by consultation with officers, noting that football and cricket are particularly popular and that increases in participation have been achieved. Among women, the participation rate in team games is broadly in line with other authorities. However there is not data to indicate a breakdown, by gender, of those using existing leisure facilities in the borough. From the evidence above does the policy affect, or have the potential to affect, gender groups differently and if so do any of the differences amount to adverse impact or unlawful discrimination? Lack of resources to provide facilities for customers with babies and small children, for example, bay-changing facilities, a secure play area may deter some potential customers. Women (particularly with children) may find it more difficult to access a city centre location particularly if there are parking and vehicular access limitations to the location. More information with regards to implementing gender specific programmes to ensure more active participation of certain groups i.e. women are addressed through Leisure Management Contract with Greenwich Limited, the Tower Hamlets Sports Strategy and the Tower Hamlets Olympic and Paralympic Strategy and Programme. If there an adverse impact, can it be justified on the grounds of promoting equality of opportunity for one gender group or for another legitimate reason? There appears to be some evidence of ‘positive action’ within the service, in relation to the numbers of women / girls who use leisure facilities. This includes the provision of gender specific swimming programmes. For further information please contact the Corporate Equalities Team on 020 7364 4723 28 Equality Impact Assessment Could the policy discriminate, directly or indirectly and if so is it justifiable under legislation? No For further information please contact the Corporate Equalities Team on 020 7364 4723 29 Equality Impact Assessment Disability – testing of disproportionate or adverse impact Identify the effect of the policy on the disability strand from information available above. People with disabilities face specific barriers to participating in sport and physical activity. Most barriers relate to difficulties in accessing sporting and leisure opportunities, due to: 1. Physical barriers – such as lack of accessible facilities, such as gyms and buildings, and limited access to transportation 2. A Lack of services – arising from a lack of understanding and awareness of how to include people with a disability in sport, and limited opportunities and programmes for participation, training and competition. The Leisure Strategy delivers strategic solutions to ensure that adequate numbers of facilities are available, in geographical locations that are easily and safely accessible by public transport, particularly for disabled people, and that the condition of these facilities are maintained to a high standard. Current provision: Two Leisure Centres (Mile End Park & Whitechapel where designed specifically to ensure that they are fully accessible and have excellent facilities and programmes. The other Leisure facilities with the exception of John Orwell have been adapted and are DDA compliant. Braille signs and locker numbering is available at MEPLC How are disabled people reflected in the take up of the service? According to the Active People Survey 2005/06, participation rates for people with a ‘limiting disability’ undertaking 30 minutes of exercise, 3 times a week in Tower Hamlets as being 6.7%, which is lower than both the London average (9%) and the national average (8.8%) Similarly, those identifying ‘No limiting disability’; indicated 21.6% for the borough average, compared to the London average (23.1%) and the national average (23.3%). From the evidence above does the policy affect, or have the potential to affect, disability groups differently and if so do any of the differences amount to adverse impact or unlawful discrimination? Yes. The application and adoption of BS 8300, ‘Design of Buildings and their Approaches to Meet the Needs of Disabled People: Code of Practice, ensures that new developments are assessable and inclusive. The Disability Discrimination Act 1995 (Part 111) places a duty on the Council to provide equal access to services and, where necessary, to remove, alter or provide a reasonable alternative to overcome any physical barriers. The requirement is reflected within the Leisure Centre Strategy. For further information please contact the Corporate Equalities Team on 020 7364 4723 30 Equality Impact Assessment Monitoring the success of specific programmes aimed to increase the participation amongst disabled groups would enable the service to effectively plan for increased participation in the future If there is an adverse impact, can it be justified on the grounds of promoting equality of opportunity for one group or for another legitimate reason? No Could the policy discriminate, directly or indirectly and if so is it justifiable under legislation? No For further information please contact the Corporate Equalities Team on 020 7364 4723 31 Equality Impact Assessment Age – testing of disproportionate or adverse impact Identify the effect of the policy on different age groups from information available above. The Leisure Centre Strategy seeks to ensure that all age groups have equal opportunity in accessing leisure facilities in Tower Hamlets. The Strategy has been informed and draws significantly from consultations already undertaken to support the Community Plan and the Children and Young People’s Plan. This ensures that recommendations for the planning of future provision has taken into account the barriers and perceived barriers effecting certain age-groups in accessing leisure facilities .i.e. public transport How are young and old people reflected in the take up of the service? Children’s participation in sport according to the London Borough of Tower Hamlets TellUs3 Survey Report 2008 In the last 7 days, on how many days have you spent at least 30 minutes doing sports or other active things? 40 30 20 2008 LA All (%) 10 2008 NAT All (%) 2007 LA All (%) 0 None 1-2 days 3-5 days 6-7 days Don't know 2008 LA All (%) 2008 NAT All (%) 8 4 30 21 28 35 27 36 7 4 2007 LA All (%) 2007 NAT All (%) 7 4 27 18 31 35 28 38 7 5 2007 NAT All (%) Results from the Tellus3 survey indicate 30% of respondents in Tower Hamlets spent at least 30 minutes on 1-2 days doing sports and other active things compared to the national average of 21%. This represents an increase of 3 percentage points from 2007. Only 27% of respondents were active on 6-7 days compared to 36% nationally, and 8% weren’t active on any days compared to only 4% nationally. These are statistically significant negative outcomes as they indicate that children and young people in Tower Hamlets are participating less frequently in sport and other active things than the national average. When asked to identify which out of a list of activities they had been to in the last four weeks (not including activities done as part of school lessons): 33% responded that they had been to the swimming pool, compared to 46% nationally – this is a statistically significant difference indicating a negative outcome as it means that children and young people in the Borough have below average rates of swimming pool usage outside of school lessons. Participation rates have fallen from 40% in 2007, compared to the national average which increased from 45% in 2007 For further information please contact the Corporate Equalities Team on 020 7364 4723 32 Equality Impact Assessment 57% responded that they participated in sport at a sports club or class, compared to 58% nationally – this has increased considerably from 43% in 2007, compared to the national average which grew from 48% in 2007 45% responded that they had been to the gym, compared to 27% nationally – this is a statistically significant difference indicating a positive outcome as it means that children and young people in the Borough have considerably above average rates of gym usage. It also represents a large increase in usage from 27% in 2007, compared to the national average which has increased from 22% in 2007. Older people According to the Active Peoples Survey 2005/06 participation rates for people over 55 years of age undertaking 30 minuets of exercise, 3 times a week in Tower Hamlets (7.4%) is both lower than the London (11.1%) and National (9%) average. From the evidence above does the policy affect, or have the potential to affect, age groups differently and if so do any of the differences amount to adverse impact or unlawful discrimination? The omission of ‘family friendly’ facilities could have a negative impact in attracting further participation of parents and their families. The inclusion of baby changing facilities and children play areas considerably increase the ability of parents and carers to partake in leisure activities If there is an adverse impact, can be justified on the grounds of promoting equality of opportunity for one group or for another legitimate reason? No Could the policy discriminate, directly or indirectly, and if so is it justifiable under legislation? No For further information please contact the Corporate Equalities Team on 020 7364 4723 33 Equality Impact Assessment Lesbian, gay, bisexual and trans-gender – testing of disproportionate or adverse impact Identify the effect of the policy on lesbian, gay, bisexual and trans-gender (LBGT) groups from information available above. No data available How are LBGT groups reflected in the take up of the service? The lack of available LBGT user data means that we are unable to ascertain if there is additional demand for specific facilities readjustment, specific sessions or activities From the evidence above does the policy affect, or have the potential to affect LBGT groups differently and if so do any of the differences amount to adverse impact or unlawful discrimination? No one is excluded from sports sessions on the grounds of their sexuality. However, consideration should be given in relation to more sensitive issues such as shared or single sex changing facilities or single sex sporting activities, as these may be constructed as barriers to transgender / transsexuals. However, the adoption of mixed changing facilities may prevent certain groups accessing the services i.e. the Muslim community where separation of the sexes is strictly adhered to If there is an adverse impact which, can it be justified on the grounds of promoting equality of opportunity for one group or for another legitimate reason? No Could the policy discriminate, directly or indirectly and if so is it justifiable under legislation? No For further information please contact the Corporate Equalities Team on 020 7364 4723 34 Equality Impact Assessment Religion/Belief – testing of disproportionate or adverse impact Identify the effect of the policy on different religion/belief groups from information available above. No information available relating to religion or belief groups How are the religion/belief groups reflected in the take up of the service? Given the ethnic breakdown within the borough, the Council and partners have to be sensitive to cultural and religious needs From the evidence above does the policy affect, or have the potential to affect, religion or belief groups differently and if so do any of the differences amount to adverse impact or unlawful discrimination? Lack of space for prayer room/quiet space facilities. Lack of flexibility around wearing of uniforms. Inability to provide appropriate staffing and accommodation facilities where communication must be through a third party e.g. a religious elder, a communication can only be with a member of staff of one particular gender. If there is an adverse impact, can it be justified on the grounds of promoting equality of opportunity for one group or for another legitimate reason? No Could the policy discriminate, directly or indirectly, and if so is it justifiable under legislation? No For further information please contact the Corporate Equalities Team on 020 7364 4723 35 Equality Impact Assessment Health Impact – testing of disproportionate or adverse impact Identify the effect of the policy on physical or mental health of service users and the wider community from any information that is available. (This might include an increased risk to health for some groups in the community, which although not intended, may have still occurred. The impact on health might include: increased mental stress, greater risk of accident or injury, reduced opportunities to have a quality diet, reduced opportunity for physical exercise, or greater incidence of diseases such as heart disease and diabetes). It is widely recognised that regular exercise can have a positive impact on both physical and mental health, including reducing the risk of obesity, heart disease and diabetes. The increased availability of leisure activities through the creation of more leisure centres will improve the health and wellbeing of hard-to-reach groups, particularly those on low income. From the evidence above does the policy affect, or have the potential to affect the health of groups differently? If so, which groups and how does the impact occur? The people of Tower Hamlets face exceptional challenges to their health and well-being and obesity has been identified as one of the most pressing public health challenges. Levels of obesity are linked to premature deaths resulting particularly from circulatory disease. For the period 2004-2006, life expectancy in Tower Hamlets was 75.2 years for men, and 80.2 years for women. This means Tower Hamlets had amongst the worst life expectancy for men in the whole country. In contrast, the best life expectancy was 82.2 years for men and 86.2 for women (Kensington and Chelsea). Results from the national child measurement programme (academic year 2006/07) show that levels of childhood obesity in Tower Hamlets are higher than average for London and England. The prevalence of obesity in children measured in reception was the 3 rd highest in the country and the 2nd highest in London. The prevalence of obesity in children measured in year six was the 13th highest in the country and the 9th highest in London. The proportion of children found to be overweight (but not obese) in Tower Hamlets was found to be lower in reception compared to England, but in year six the differences were not significant. There is currently no reliable local data available on the prevalence of obesity in adults. However, based on the demographic and socio-economic characteristics of the population the Tower Hamlets Primary Care Trust estimates that about 20 per cent of adults in Tower Hamlets are likely to be obese. Coronary Heart Disease (CHD) includes angina (chest pain on exertion), heart attacks and heart failure. Physically inactive people have approximately double the risk of CHD compared to those taking regular exercise. In 2006 there were 207 deaths from CHD in Tower Hamlets residents, of which 95 were in people under the age of 75. CHD accounted for almost a quarter of premature deaths in men and 14% of premature deaths in women. Overall, the age-standardised mortality rate for premature CHD death in Tower Hamlets is 81.6 per 100,000 European Standard population – considerably higher than the rest of the country. The mortality rate for men is particularly high. Across the Borough the death rate was highest in East India and Lansbury, Bethnal Green South, Bromley by Bow and Spitalfields & Banglatown. For further information please contact the Corporate Equalities Team on 020 7364 4723 36 Equality Impact Assessment For further information please contact the Corporate Equalities Team on 020 7364 4723 37 Equality Impact Assessment Additional groups which may experience a disproportionate or adverse impact Identify if there are groups, other than those already considered, that may be adversely affected by the policy? For example those in poverty may be adversely impacted by the policy and it might be useful to consider them as a separate group in the light of the Council’s overall policy objectives. Importance of facilities to lower socio-economic groups There are a number of barriers which limit the opportunity for people to participate in accessing leisure facilities. These include lack of public transport from certain geographical areas, lack of information about new facilities and programmes and the facilities pricing policy. Additional factors which may influence disproportionate or adverse impact Management Arrangements (How is the Service managed, are there any management arrangements which may have a disproportionate impact on the equality target groups?) Please refer to the Sports and Physical Activity EqIA What is the custom and practice in the provision or allocation of this service? (Could these have a disproportionate impact on the equality target groups?) Please refer to the Sports and Physical Activity EqIA For further information please contact the Corporate Equalities Team on 020 7364 4723 38 Equality Impact Assessment The Process of Service Delivery (In particular look at the arrangements for the service being provided). Please refer to the Sports and Physical Activity EqIA Operation Times (When is the service provided; are there seasonal issues; are there barriers to the service based on the time and delivery of the service which may affect the target groups?) Please refer to the Sports and Physical Activity EqIA for the operational times of existing leisure facilities in the borough Methods of communication to the public and internally (What methods do you use to communicate this service? Include review and assessment of methods, media, translations, interpretation etc. bearing in mind the extent to which these media forms are accessible to all sections of the community) Externally Signage East End Life Local media National media Specialist press Leaflets Posters Programmes E-marketing Tower Hamlets website Sports & Physical Activity website Bus stops and local transport advertising Radio Billboards Membership cards Internal publications Word of mouth Adverts Sponsored publications Front line staff Internally For further information please contact the Corporate Equalities Team on 020 7364 4723 39 Equality Impact Assessment Website/Intranet Pulling together Awareness of Service by Local People (Assessment of the extent to which local people are aware of the service based on available data. What measures do you undertake to reach traditionally excluded communities?) Websites – Sport & Physical Activity & GLL Leisure Guide Regular Local Press coverage Promotion at community events Evidence of disproportionate or adverse impact (Is there any evidence or view that suggests that different equality, or other, target groups in the community have either a disproportionately high or low take up/impact of/from this service/function?) yes no If yes, what and why (State below) It is clear from the research that physical issues relating to the accessibility of sports facilities act as a barrier to participating in sports and physical activity. Strategic solutions put forward in the Leisure Facilities Strategy aims to ensure that adequate numbers of facilities are available, in geographical locations that are easily assessable by public transport, particularly for children and young people and disabled people, and that the condition of these facilities is maintained to a high standard. Other non-facility related barriers – regarding how people perceive or experience sport and physical activity, their individual preferences and views on the propensity or need to participate, and difficulties relating to their physical experience of sport – are also significant and will need to be addressed through other avenues, including the Leisure Management Contract with Greenwich Leisure Limited, Tower Hamlets Sports and Physical Activity Strategy and the Tower Hamlets Olympic and Paralympic Strategy and Programme. SECTION 4 MEASURES TO MITIGATE DISPROPORTIONATE OR ADVERSE IMPACT Specify measures that can be taken to remove or minimise the disproportionate impact or adverse effect identified at the end of Section 3. If none were identified in Section 3, identify how disproportionate impact or adverse effect could be avoided in the future. (Consider measures to mitigate any adverse impact and better achieve the promotion of equality of opportunity). For further information please contact the Corporate Equalities Team on 020 7364 4723 40 Equality Impact Assessment 1. Ensure leisure centres contain ‘family friendly’ facilities to enable the potential usage by single parent families and carers. For example, the inclusion of baby changing facilities, kids play area, a crèche and sufficient parking. 2. To look at the possibility the possibility of providing appropriate parking arrangements for people with disabilities i.e. dedicated disabled parking spaces located next to, or near, the front entrance 3. The adoption of a ‘universal design model’ in the design of new leisure facilities. This would include: all buildings access via ramp and rails; signs positioned for people with visual difficulties; reception counters lowered; the implementation of hearing loop systems and the adoption of a interior able to cater for people within wheel chairs. 4. Ensure all groups are involved in the review and development of new and existing facilities i.e. older people, BME, people with disabilities 5. Establish mechanism for consultation with designated community, stakeholder groups and wider community on all aspects of equalities policy. 6. Ensure the Council continues to develop a customer feedback process, which reinforces the commitment to provide facilities that meet the needs of the community. 7. Effective partnership working at local, regional and national level with public, voluntary and the private sector is essential to the achievement of the Strategy’s strategic objectives. 8. Improving the awareness of leisure facilities, and associated programmes of consultation, through improved marketing and communication campaigns i.e. translation service SECTION 5 CONCLUSIONS AND RECOMMENDATIONS Does the policy comply with equalities legislation, including the Duties to promote equality in relation to race, disability and gender? Take into account your findings from the impact assessment and consultations and explain how the policy was decided upon its intended effects and its benefits.) yes no What are the main areas requiring further attention? 1. Ensuring that future design of new build enables the full access of all residents, such as disabled and older people 2. Ensure that centres contain ‘family friendly’ facilities to enable the participation of one parent families, carers and women For further information please contact the Corporate Equalities Team on 020 7364 4723 41 Equality Impact Assessment 3. The forging of links with community organisations to ensure feedback from hard-to reach groups, such as Gypsy and Traveller community, are involved in any future consultation on or needs analysis 4. The engagement of LGBT groups or individuals for the collation and analysis of feedback relating to accessibility to leisure facilities in the borough 5. Ensure that the needs and views of non-users are collated and analysed and used to inform improvement i.e. barriers to BME women Summary of recommendations for improvement See above How will the results of the Impact Assessment feed into the performance planning process? Feed into service plans and individual team plans For further information please contact the Corporate Equalities Team on 020 7364 4723 42 Equality Impact Assessment Future Monitoring and Consultation How and when will the policy be monitored? Regular monitoring through service plans at Service Head and DMT level Suggested consultation for the future (Identify areas for future consultation and any barriers to participation in consultation with proposals to overcome these). The forging of links with community organisations to ensure feedback from hard-to reach groups, such as Gypsy and Traveller community, are involved in any future consultation on or needs analysis Possible barriers: Language Barriers: Information not made available, or not stating that it can be made available as required, e.g. in a different language, or in a different format, such as large print Inconvenience: limitations on time to complete forms or interview i.e. parents, workers and voluntary sector Low Income: Disengaged from regular consultation processes. They may also feel apathy towards the outcome Physical Barriers: Using appropriate locations to enable people with disabilities to participate i.e. wheelchair access, or in appropriate formats, so those with physical/mental impairments can still participate Jargon: Publications and materials not written in plain English Any future consultation will follow Corporate consultation guidelines. For further information please contact the Corporate Equalities Team on 020 7364 4723 43 Equality Impact Assessment SECTION 6 – ACTION PLAN Recommendation Key activity Progress milestones Conduct feasibility report of future sites Undertake DDA audit of new sites Conduct consultation process with key stakeholders for input into design development Work with Tower Hamlets Access Group to improve accessibility Contact groups representing people with disabilities to gain advice on providing measures to improve access Initiate links with TH Children Services Ensure that centres contain ‘family friendly’ facilities to enable the participation of one parent families, carers and women Liaise with relevant community stakeholder organisations Initiate links with TH Children Services Continue to forge of links with community organisations to ensure feedback from hard-to-reach groups, such as Gypsy and Travellers, are involved in any future consultation or needs analysis Initiate links with Praxis and other community groups Develop greater interdepartmental links between key services i.e. Travellers Teams Ensure that future design of new build enabled the full access of all residents, such as disabled, older and children and young people For further information please contact the Corporate Equalities Team on 020 7364 4723 Officer Responsible Progress 44 Equality Impact Assessment Engagement of LGBT groups or individuals for the collating and analysis of feedback relating to accessibility to leisure facilities in the borough Develop links with local LGBT organisations and the LGBT staff forum Ensure that the needs and views of non-users continue to be collated and analysed and used to inform improvement i.e. barriers to BME women Conduct assessment of current programmes to evaluate their success in increasing participation of targeted groups Review current provision Ensure new sites have appropriate parking facilities for disabled users Conduct feasibility report on potential sites Tabulate findings of reports and site onto LBTH Website Negotiate terms with contractor Ensure that all key partners comply with the Council’s equalities policy Ensure EqIA action plan is sited on LBTH Website Achieve a cross-borough approach to equalities For further information please contact the Corporate Equalities Team on 020 7364 4723 45 Equality Impact Assessment 6. FURTHER GUIDANCE FOR COMPLETING EACH SECTION OF THE IMPACT ASSESSMENT TEMPLATE I) SECTION 1 – AIMS AND IMPLEMENTATION OF THE POLICY It is critical, at the outset, to determine the aims of the policy, as this will guide the subsequent development of an IA. The following questions may help to provide an early steer for an IA: This may have already been considered but it is really important to be clear about the policy aims. The following are some of the key questions to address at this stage: What is the purpose of the policy Who is affected by it? Who is the policy intended to benefit and how? How will we put the policy into practice, and who will be responsible for it? How does the policy fit in with the Authority’s wider aims? How does the policy relate to other polices and practices within the Authority? As should be clear from the answers to these questions, at this stage it is essential to identify: 1. The responsibilities that the public authority holds in relation to this policy; and 2. The responsibilities held by other bodies (including other public authorities). Thus, for example, a procurement policy may be imposed on a public authority but when the policy is then implemented by that public authority it must be subjected to assessment. For further information please contact the Corporate Equalities Team on 020 7364 4723 46 Equality Impact Assessment II) SECTION 2 – CONSIDERATION OF DATA AND RESEARCH Public authorities will need to consider how they will collect the information that will enable them to make a judgment of the extent of impact on the different equality strands. There is a case to be made for public authorities to work collectively on this particularly where authorities are operating within the education or health and social services sectors. They may wish to work together both to ensure the most effective and efficient use of public resources and to access the optimum information. Relevant, reliable and up-to-date information is essential. Statistics alone do not provide reasons or explanations for differences. Public authorities must therefore institute a system of information gathering to supplement available statistical and qualitative research. There is a need to collect and analyse existing quantitative data by relevant characteristics as a minimum base from which to judge outcomes but also use qualitative or evaluative research or information gathered by other bodies such as voluntary, community and trade union organisations. Thus both types of data should be regarded as equally relevant as no one type of data is inherently more valuable than the other. Before beginning an IA a thorough audit of available data should be carried out, paying particular attention to in-house data sets that can be used or adapted for the purposes of IAs. There may be a temptation routinely to employ one-off data gathering exercises in order to address perceived shortfalls in available information. While this may be necessary in response to significant contemporary issues, it is not a substitute for putting in place procedures, which allow data to be gathered at regular intervals to inform current and future IAs. With this in mind it may be important to identify in-house sources of data as a first stage in the data gathering process. For example, existing administrative databases may be potentially useful sources of information. There may be a need to consider how these sources of data may be adapted to include new fields so as to capture relevant information, or to consider alternative sources of information if adding new fields is not a practical option within the required timescales. Also comments, which have been gathered during all previous consultations, including the preparation of the Community Plan and Equal Opportunities policy, should continue to inform decision-making and be regarded as a valuable source of information. Note of caution: While the collection of relevant data is important, there is a need to be aware that particular issues of sensitivity and confidentiality may arise in relation to disability and sexual orientation. It is important to recognise the particular benefit of discussion and information gathering with groups representing people with disabilities and of different sexual orientations, in the absence of extensive data on these matters among their employees and recipients of services. Also before in-house databases and other systems of data collection have become well established, the gathering of data to inform an IA is likely to be time consuming and in areas such as sexual orientation only limited information is likely to be available. In all cases, lack of data should not be an excuse for doing nothing. There is a need for flexibility and to continue to monitor the impact of the policy after the completion of the IA. For further information please contact the Corporate Equalities Team on 020 7364 4723 47 Equality Impact Assessment Key questions to guide the sources of data are: What do we need to know about this policy? What information is needed to ensure that all perspectives are taken into account? Who should be involved in determining what information is needed? What existing quantitative data is available, in-house and externally? What existing qualitative or evaluative research is available, in-house and externally? What additional data are needed? Is there a need to generate primary data? Is there a need for secondary analyses of existing data? Who will be partners in information gathering/provision? What processes are required to consult effectively with these partners? Equalities profile of staff For IA’s relating to HR policies and procedures it is necessary to gather data on experiences of staff in relation to the operation of that policy e.g. during an assessment of the Recruitment and Selection policy there will be need to gather data to be able to assess the experiences of different equality groups at the different stages of the process to determine whether there is a differential and/or an adverse impact. Evidence of complaints against the service on grounds of discrimination A simple count of the number and nature of complaints received will provide quantitative information on those policies that spontaneously elicit the highest number of complaints. The authority’s response to complaints may also be examined more thoroughly using qualitative methods of data analysis. It should be remembered however when using reviews as a source of data, that people who have failed to access a particular service are unlikely to be complainants and that certain groups may be less willing to voice their concerns than others. For further information please contact the Corporate Equalities Team on 020 7364 4723 48 Equality Impact Assessment SECTION 3 – ASSESSMENT OF IMPACT III) The next stage is to use the information gathered to decide whether there is, or is likely to be, a differential impact, whether direct or indirect, upon the relevant group(s). If an adverse impact on any of these groups can be identified then there is a need to assess whether the policy is unlawfully discriminatory taking into account that some polices are intended to increase equality of opportunity by taking positive action to redress disadvantages. A decision will then have to be made to ensure that the Council is acting lawfully. Even if the policy is not unlawful, there is a need to consider what to do in the light of the adverse impact identified. Thus for example if the policy is intended specifically to address the needs of a particular group, it may well be justifiable, indeed necessary in order to promote the equality of opportunity of that group. If this is not the case then there is a need to consider whether there is any alternative measure, which would achieve the aim desired without the differential impact identified. Evidence of disproportionate impact of services – Key questions to guide assessment of impact are: Is there differential impact on any of the groups in respect of the quantitative data? Is there differential impact on any of the groups in respect of the qualitative or evaluative data? Is there a difference in the conclusions reached using quantitative and qualitative methods? How can the difference be reconciled? Is the differential impact an adverse one? Is the policy directly or indirectly discriminatory? If the policy is not directly or indirectly discriminatory, does it still have an adverse impact? Is the policy intended to increase equality of opportunity by permitting or requiring affirmative or positive action or action to redress disadvantages? Is it lawful? Is there any alternative measure, which would achieve the desired aim without the adverse impact identified? Is there any mitigation, which would alleviate the adverse impact identified? Are there additional measures which can be adopted which would further equality of opportunity in the context of this policy? Additional factors influencing impact Consideration of additional factors which may influence disproportionate or adverse impact Including the Process of Service Delivery Is there an assessment of need undertaken? Are there eligibility criteria? Is the service targeted to local residents, businesses & visitors? Is the service regulatory, advisory and/or, care based? Is the service free, fee based or commercially driven? What are the likely impacts of all of these elements on the different equality target groups in the community?) For further information please contact the Corporate Equalities Team on 020 7364 4723 49 Equality Impact Assessment IV) SECTION 4 – MEASURES TO MITIGATE DISPORPORTIONATE OR ADVERSE IMPACT The consideration of mitigation and alternatives are crucial elements of the process. Options must be developed which reflect different ways of delivering the policy outcome. The consideration of mitigation of adverse impacts is intertwined with the consideration of alternatives. Mitigation can take the form of lessening the severity of the impact or providing some other remedy, where the adverse impact cannot reasonably be reduced. The mitigation of adverse impacts must be considered at the various stages of the policymaking process. Clear evidence of the mitigation of impacts must be apparent in the policy assessments and details of mitigation and its implementation must be included in the final recommendations. Evidence of the consideration of mitigation must be presented during decision-making. Consideration must be given to whether separate implementation strategies are necessary for the policy to be effective for the relevant group. The following must be considered: How does each option further or hinder equality of opportunity? How does each option reinforce or challenge stereotypes which constitute or influence equality of opportunity? What are the consequences for the group concerned and for the Council of not adopting an option more favourable to equality of opportunity? How will the relevant group be advised of the new or changed policy or service? What are the costs of implementing each option? Will the social and economic costs and benefits to the relevant group of implementing the option outweigh the costs to the Council or other groups? An evaluation of net social benefits achieved by adopting each option must be considered. For further information please contact the Corporate Equalities Team on 020 7364 4723 50 Equality Impact Assessment V) SECTION 5 – CONCLUSIONS AND RECOMMENATIONS The General Duties placed on public bodies by the Race Relations (Amendment) 2000, the Disability Discrimination Acts 1995 and 2005 and the Single Equality Act 2006 requires them to combat discrimination and promote equality of opportunity and good relations between groups on the basis of race, disability and gender. The General Duty requires not only that equality to be taken into account but for it to be accorded considerable weight. This does not necessarily mean that the General Duty overrides other clearly conflicting statutory duties with which the Council must comply but to act in a proportionate manner and accord weight not only to administrative considerations but also to the General Duties. It would be necessary to explain conclusions reached on the validity and reliability of quantitative and qualitative data. In particular, where different types of data differ in relation to the determination of whether or not there is an adverse impact e.g. quantitative data may not indicate adverse impact on a particular group but the qualitative data may do so. In such circumstances the decision as to the weight attached to particular data must be explained. The following questions may help guide decision-making: Who will play a role in the decision-making process? What authority do the decision-makers hold in the Council? What information will inform the decision-making process? What weights will be assigned to various pieces of information? How will these weights be determined? How is the decision-making process to be structured? Will the process involve face-to-face meetings? How many? How will the decision-making process be recorded? FUTURE MONITORING AND CONSULTATION IAs are not one-off exercises but represent a consideration by the Council, at a point in time, of the impact of their policies on different equality strands. In order, therefore to ensure that there is no adverse impact in the future there is a need to establish robust systems to monitor the impact of the policy in order to find out its effect on the relevant group(s) in the future. This must be reviewed on an annual basis. It is essential that monitoring is carried out in a systematic manner and that the results are widely and openly published. If the monitoring and evaluation show that the policy results in greater adverse impact than predicted, or if opportunities arise which would allow for greater equality of opportunity to be promoted, the Council must ensure that the policy is revised. The following questions may help guide future monitoring: Who will be responsible for monitoring? What has to be monitored? Are there monitoring procedures already in place which will generate this information? How could monitoring procedures already in place be adapted to better reflect IA needs? For further information please contact the Corporate Equalities Team on 020 7364 4723 51 Equality Impact Assessment Can existing monitoring procedures be adapted to collect the additional information required in relation to this policy? What monitoring techniques and tools will be the most effective? Will arrangements need to be put into place for others to collect monitoring and evaluation information (for example where the Council is not responsible for the implementation of the policy)? What indicators or targets will be used to evaluate the effectiveness of the policy? In what format will monitoring, information be published? Does the monitoring information identify opportunities for greater equality of opportunity to be promoted? Monitoring, therefore, consists of continuous scrutinising, follow-up and evaluation of policies. It is not solely about the collection of data, it can also take the form of regular meetings and reporting of research undertaken. Monitoring is not an end in itself but provides the data for the next cycle of policy review. For further information please contact the Corporate Equalities Team on 020 7364 4723 52 Equality Impact Assessment VI) SECTION 6 – ACTION PLAN Section 6 of the Equality Impact Assessment Template is an Action Plan with a timetable for implementation. It is very important that this is completed as it details what actions are to be taken, to tackle issues which have been identified in the assessment, and when they will be carried out. These Action Plans are then incorporated into the corporate Equalities Action Plan for all directorates which is up-dated with progress every six months. For further information please contact the Corporate Equalities Team on 020 7364 4723 53 Equality Impact Assessment GUIDANCE ON CONSULTATION An IA requires consultation, which must be carried out with relevant interest groups other public bodies (including health), voluntary, community, trade union and other groups with a legitimate interest in the matter. This should include those directly affected by the policy to be assessed, whether or not they have a direct economic or personal interest. The method by which the Council chooses to conduct consultations at this stage must ensure a fair opportunity to present pertinent information and to provide the Council with a sound basis for decision, without rendering decision-making unmanageable. It will be important to ensure that sufficient time and resources are dedicated to the consultation process to encourage full participation particularly by marginalised groups. Wide publication of the consultation exercise is essential to inform the public and relevant groups about the policy being assessed, and to invite comments on it. This may include press releases, prominent advertisements in the press, the Internet and direct invitations to groups, which are likely to be interested in and able to represent interests and views, which would otherwise be inadequately represented. The information used by the Council in assessing the impact of the policy must be made available on request to those consulted. This will include any quantitative and qualitative data and other documentation such as consultants' reports. CONSULTATION AND INVOLVEMENT FRAMEWORK The Council’s Consultation and Involvement Framework consists of the Compact supported by the Inter-agency Protocol, which provides guidelines on sharing information between agencies, including information for the forward calendar and a Step by Step Guidance for staff, which provides consistent guidance for use across agencies. The Purpose of the Compact The compact sets out standards of consultation and involvement practice that will be followed by those statutory organisations signing up to it. 1. Consultation and involvement processes will be co-ordinated Liaising with other organisations over the timing and scope of the proposed consultation and ensuring that it is listed in the forward calendar on the Web. 2. Clear information will be provided Information on each consultation process will be made available as early as possible and will use plain language (and, where relevant, community languages). 3. Consultation and involvement processes will have an adequate time-scale One month will be given to individuals and organisations to respond to consultation documents and three months when dealing with complex issues. 4. The purpose of each consultation and involvement process will be set out The purpose of every involvement process will be stated clearly from the start, including the time scale, what decisions will be taken and by whom. 5. A variety of methods will be used For further information please contact the Corporate Equalities Team on 020 7364 4723 54 Equality Impact Assessment A variety of methods and approaches will be used to ensure maximum levels of involvement including those groups that we may find difficult to reach. 6. Accurate records of responses will be kept Responses will be recorded accurately. 7. A summary of consultation and involvement findings will be made public A summary of the findings of consultation and involvement processes will be made available to all who took part (respecting any issues of confidentiality). 8. Participants will be given feedback about the outcomes of consultation and involvement processes. 9. Where appropriate, local third sector organisations will be supported in delivering or contributing to the delivery of consultation and involvement. 10. Consultation and Involvement processes will be reviewed and monitored. 11. Training and guidance will be provided to those undertaking consultation and involvement. Further details of the Consultation and Involvement Framework, including guidance for staff may be obtained from the Council’s Intranet or by contacting the Consultation and Involvement Team on x4576. The following questions may be of assistance in guiding consultation: Who is directly affected by the policy? What relevant groups have a legitimate interest in the policy? How do we ensure that those affected or with a legitimate interest in the policy are consulted? What methods of consultation will be used and at which stages of the IA? How will information be made available to those consulted? Will the information be accessible to minority groups such as those with disabilities and ethnic minorities? What barriers exist to effective consultation with each of the groups/bodies/persons identified above? What measures can be taken to facilitate effective consultation in light of any barriers? Have previous attempts at consultation with particular groups been unsuccessful? If so, why, and what can be done to overcome any obstacles? What resources are available to encourage full participation by marginalised groups? If meetings are to be held, where will they be held and at what time of the day? It is important to remember before proceeding with consultation to ascertain what other consultation has already been undertaken by the Council before proceeding with another exercise. The issue of consultation fatigue needs to be taken account of. Groups/individuals see the whole Council as one organisation and can become perplexed why there may be similar consultation exercises may be taking place within very short time spans. It is important to have a co-ordinated and consistent approach. GUIDANCE ON THE PUBLICATION OF RESULTS For further information please contact the Corporate Equalities Team on 020 7364 4723 55 Equality Impact Assessment An important part of the process of IA is to publish the results in a comprehensive and readily accessible form, paying particular attention to special needs of particular groups within each equality category. This is probably best achieved by presenting the IA as a report, which incorporates all the elements along with measures to mitigate adverse impact. The NI Guide to Statutory Duties states that the”mitigation of adverse impacts must be considered at the various stages of the policy-making process. Clear evidence of the mitigation of impacts must be apparent in the policy assessments, and details of mitigation and its implementation must be included in the final recommendations. Evidence of the consideration of mitigation must be presented during decision making”. The report should begin with an Executive Summary of the results of the IA, in particular focusing on any decisions, which have been reached. The report should contain a description of the policy aim, the context within which the policy operates, the scope of the policy and any existing data which are available and which may have informed policy development in the past (Background). The first section, Data Collection & Consultation, should outline how data were collected for the IA, and will also include reference to consultees along with any other procedures, which have been used to draw together pertinent information. Sufficient detail should be provided so that the research procedures could be replicated and the validity of the data confirmed. It should be made clear to all those providing information in relation to an IA how that information will be made available subsequently. For example, sensitive monitoring information, focus group interviews and individual interviews may be anonymous but responses to consultation with representatives will be attributable. More generally it is important to be wary of the possibility of allowing individuals to be identified where inappropriate. The next section, Key Findings, should highlight results that have emerged and should ensure that due consideration is afforded to the equality categories under consideration. The final section, Conclusions, will then draw conclusions from the results in terms of the policy impact and will outline the decision-making process concerning policy review. This section should state the decisions made by the Council on the basis of the IA, for example, by way of an action plan with associated timescales. If a decision is made to introduce measures to mitigate adverse impact or alternative policies then it would be appropriate to address each of the following six questions: How does each option further or hinder equality of opportunity? How does each option reinforce or challenge stereotypes, which constitute or influence equality of opportunity? What are the consequences for the group concerned and for the Council of not adopting an option more favourable to equality of opportunity? How will the relevant group be advised of the new or changed policy or service? What are the costs of implementing each option? Will the social and economic costs and benefits to the relevant group of implementing the option outweigh the costs to the Council or other groups? An evaluation of net social benefits achieved by adopting each option must be considered. This section should also outline systems that will be put in place to monitor for adverse impact in the future and should include all relevant timetables. For further information please contact the Corporate Equalities Team on 020 7364 4723 56 Equality Impact Assessment APPENDIX A Diversity Monitoring Categories (based on the 2001 census) Gender Are you: Female Male Other description _____________ Ethnicity Are you: Asian Bangladeshi Chinese Indian Pakistani Vietnamese Other Asian background (Specify) _________________ Black Caribbean African Somali Other African Other black background (Specify) _________________ Mixed Dual Heritage White & Asian White & Black African White & Black Caribbean Other Mixed background (Specify) _____________ White English Irish Scottish Welsh Other White background (Specify) _____________ Other Any other ethnic background (Specify) _________________ The information which you provide on this form will be kept in accordance with the Data Protection Act 1998 and used for the purpose of monitoring Disability For further information please contact the Corporate Equalities Team on 020 7364 4723 57 Equality Impact Assessment Do you consider yourself to be a disabled person? Under the Disability Discrimination Act 1995 a person is considered to have a disability if he/she has a physical or mental impairment which has a sustained and long-term adverse effect on his/her ability to carry out normal day to day activities. No Yes Sexual Orientation How would you define your sexual orientation? Bisexual Gay Heterosexual Lesbian Age Date of Birth _____________________________________________ Or alternatively, the following age banding 0-4 5-11 12-19 20-25 26-34 35-43 44-52 53-59 60-64 65+ Religion/Belief What is your religious belief? Buddhist Christian Hindu Jewish Muslim Sikh No Religion Other religious beliefs (specify) _______________________________ The information which you provide on this form will be kept in accordance with the Data Protection Act 1998 and used for the purpose of monitoring. For further information please contact the Corporate Equalities Team on 020 7364 4723 58