This report summarises and compares the responses received from stakeholders who took part in the Commission’s consultation on the development of its three-year strategic plan, either by attending an event or submitting a response online.
It is based on the online consultation report prepared by Dialogue by
Design and the report by David Pirnie, the external facilitator, summarising the four events which were held during February and
March 2009. This report is not a substitute for reading either of these reports or for reading the original submissions.
Priority 1: Build a society without prejudice – promoting good relations and fostering a vibrant equality and human rights culture in Britain
Comments from participants at the events and submissions to the online consultation converged on a number of issues, including: the need for the Commission to provide more detail for its stakeholders about how it intends to achieve its objectives; work more strategically with other bodies with similar objectives; and strengthen the presentation of equality issues in the media.
The Commission’s strategy was welcomed by most participants, although it was felt that it required a greater emphasis on concrete objectives and how these objectives would be achieved. Some participants were also concerned that the Commission ambitious approach may result in it taking on too much, at the expense of working with others better placed to deliver, particularly grass roots organisations. There was support for the Commission working in partnership and capitalising on local projects.
The issue of the Commission’s media presence was also raised.
Participants expressed frustration that the equality and human rights agenda is not currently communicated vigorously enough, nor through all media outlets, such as those which certain groups, such as young people, are more likely to use.

Another source of concern was both the amount and the value of the research being done by the Commission. Two conflicting opinions were voiced: some participants argued that the Commission’s priority should be to concentrate on action, based on the comprehensive research which is already available; whilst others felt instead that ongoing research is essential in continuing to inform the
Commission’s strategy and policies.
Finally, participants in both consultations agreed on the importance of education and awareness, in the widest sense. This included educating and raising awareness amongst people of all ages about the rights and responsibilities involved in living in a diverse society, not only emphasising legal obligations but attempting to reach hearts and minds, therefore changing attitudes.
Priority 2: A fairer Britain for all – reducing the gap in outcomes to secure fair life chances, access to services and dignified treatment.
Participants debated the meaning of ‘fairness’, with some expressing a preference for the language of ‘equality’, as they saw the use of the word ‘fairness’ as a dilution of ambition. Some even saw the quest for a ‘fairer Britain’ as overly ambitious and regarded equality of opportunity as aspiration enough. This in turn raised questions about which forms of inequality of opportunity should be addressed as a priority, and whether the aim should instead be equality of outcome rather than opportunity. Some participants argued that the most extreme forms of inequality should be a priority, even if they affect relatively few people.
There was also a concern that a commitment on behalf of the
Commission to an agenda as huge as ‘fairness for all’ might result in the explicit human rights agenda being neglected. Proponents of this argument saw the establishment and promotion of human rights law as the basis for securing more abstract notions such as fairness and equality. For this reason, some stakeholders believe references to human rights should be more explicit in the Commission’s strategy.

Stakeholders wanted the Commission to enforce the equality duties in the private as well as the public sector. There was a perception that the Commission’s strategy and priorities are oriented towards the public sector and that the role of businesses, particularly the
90% of businesses that are small and medium-sized, are being overlooked. It was felt that the rights of millions in the private sector were at risk and that the Commission should campaign to end this disparity between the rights of individuals in the public and private sectors.
Participants in the online consultation thought that the Commission should work in partnership more, in particular with the voluntary sector. This point was emphasised even more strongly by those who attended the events. They maintained that the Commission is trying to do too much and that instead it should focus on bringing together key players, supporting them with research, information and resources, and forging partnerships to find solutions.
There was some concern that measures to advance equality may be implemented inconsistently in different parts of the United Kingdom.
Stakeholders in Wales and Scotland felt that the Commission is too
England-centric while some stakeholders in more remote parts of
England felt that the Commission is too metropolitan in outlook.
Priority 3: Secure and implement an effective legislative and regulatory framework for equality and human rights.
The majority of stakeholders considered this priority to be the most important, as it is at the heart of everything that the Commission can and should be doing. They also agreed to a large extent on the issues which this priority raises and on what needs to be done in support.
Firstly, they agreed that this is the most important aspect of the
Commission’s work; there was a shared view that legislative change is always the precursor to social change, and that if the Commission is successful in implementing a legislative framework for equality and human rights then ultimately the culture will change in line with this.
Secondly, there was an agreement that in order for legislation to be effective, it must be enforced, and therefore the Commission must

use the legal powers and duties at its disposal. However, participants were uncertain on how the Commission should proceed.
For example, how should it decide which cases to pursue, and what issues would be better advanced through rewards and encouragement to comply?
Participants felt that this lack of clarity was compounded to some extent by possible contradictions between the need to enforce the law and the need to respect the diversity and difference inherent in a multi-cultural society. Some stakeholders thought it was unlikely that the New Equalities Bill would hold all the answers.
A third issue raised was the need for proper access to justice for all, to ensure that individuals can seek redress. Successful enforcement was perceived to depend on the ability of individuals to access reliable, high quality and properly resourced advice centres, such as
Citizens Advice Bureaux, law centres or other independent advice centres,. The provision of such advice would also do much to build faith in the Commission.
The issue of accessibility was also raised by many stakeholders.
Participants repeatedly made the point that the language used by the Commission is not clear enough and that clarity is the fundamental starting point for accessibility. The Commission’s language, even in the proposed strategic priorities, is such that neither those seeking to enforce the legislation, nor those hoping to be served by it, can understand it all.
It was felt to be particularly important to ensure that the legislation is comprehensible for the middle-ranking managers who are mostly responsible for ensuring compliance with legislation. There was some concern that public sector staff may not understand human rights obligations in the context of their work in delivering public services, and also that some of those most in need of protection, such as people with learning difficulties, are vulnerable as a result.
The need for the Commission to address this was seen as another clear priority.
One final point made by participants was that the role and expertise of trade unions have been largely ignored in the drafting of the priorities. Their absence was particularly apparent and surprising in relation to this priority, as they are perceived to have been pioneers in the struggle for equality and against discrimination.

Priority 4: Promote awareness and understanding of rights
The Commission’s communications and promotion role, according to all participants, are equal in importance to its enforcement of equalities legislation but in some ways more significant in terms of changing the culture and the context within which the legislation is used.
One clear message from participants, emphasised also in relation to priority 3, was the need for clarity of communication. People need to understand exactly what the legislation means, what their rights are, and what the consequences of non-compliance are. It was also felt it would be useful if these messages became associated with the
Commission, so that the EHRC brand becomes increasingly associated with notions of fairness and justice, and also with the resources and the expertise to achieve it. The Disability Rights
Commission was cited as an example of how this has been achieved in the past.
Participants thought that the Commission was unlikely to be able to manage this on its own, and that therefore third sector partners and bodies such as trade unions would be essential in ensuring that the work of the Commission meets the needs all of its stakeholders.
For this reason stakeholders commented on the apparent omission of potentially valuable partners from the Commission’s strategy.
Many stakeholders also addressed the question of the methods the
Commission should use to promote understanding and awareness of rights and of its own role and remit. Many suggestions were made for how to achieve this, including investing in awareness and education programmes; toolkits for employers; guidance for the public; s takeholders regarded the Commission’s helpline as particularly useful and would like to see its resourcing and use expanded.
The Commission’s website was criticised, for two reasons. Firstly, some participants felt that the Commission was over-reliant on this single medium, despite the fact that many of the most disadvantaged people do not have access to the internet. Secondly, some of the participants saw the website as overly corporate in tone

and language, and not user friendly either for the public in general or more particularly for some of the people it is designed to help.
The Commission’s relationship with the media was regarded as of vital importance by stakeholders, though there was a perception that the Commission had yet to create a media presence beyond the confines of the political world and the more conservative news programmes. There are suggestions, for example, that Radio 4 and
Newsnight should be abandoned in favour of more popular media outlets, such as local radio, and that the Commission should be attending the Ideal Home or Daily Mail Exhibitions instead of, or as well as, the party conferences. There was a feeling that such outlets and venues are more likely to attract the people who most need a better awareness and understanding of justice, equality and fairness.
Finally, stakeholders emphasised the importance of positive messages as well as those about awareness and compliance. It was pointed out that there is still no widespread appreciation of the benefits that an awareness of equality and fairness can bring to organisations in all sectors, and that progress is as likely to come from stressing these positives as from enforcing compliance.
Priority 5: Build an authoritative and responsive organisation
There were some divergences of opinion over this priority between those who attended the events and those who responded to the online consultation.
Firstly, submissions to the online consultation for the most part stressed that build ing the Commission’s authority was integral to its future. However, this was not emphasised as much by participants in the events, for whom this priority was seen as merely the vehicle for achieving the other four priorities. Secondly, whilst respondents to the online consultation focused more on the external practicalities of the Commission’s role, those who participated in the events were more concerned about the Commission’s internal values, principles and behaviours.
However there was substantial agreement on the need for the
Commission to establish its authority by undertaking action to

promote equality and fairness and by demonstrating its willingness to enforce the regulatory framework.
There was also agreement on the need to work with and through others, particularly grass roots organisations and trade unions, both to avoid unnecessary duplication of work and to take advantage of others’ specialist knowledge and contacts. The lack of a clear strategy to engage key stakeholders was a concern for many stakeholders in both consultations.
Respondents to the online consultation were also concerned about the Commission’s capacity and its ability to command the confidence of others. There was some emphasis on the need for the Commission to build on the work and successes of the
Commission for Racial Equality, the Equal Opportunities
Commission and Disability Rights Commission, and to ensure it does not lose the expertise accumulated by the staff of these organisations. The importance of the Commiss ion’s staff having a sound knowledge base in the face of new legislation was also stressed by many participants.
Finally, respondents to the online consultation thought it was important both that the composition of the Commission’s Board reflects the Com mission’s purposes and that the Board contains individuals who are able to connect well with the public through the media, in order to offer leadership in creating a fair and cohesive society.