Equality Impact Assessment - Policies
Organisational Change ( which includes
Redundancy and Restructuring, Redeployment
and Disturbance)
Title of policy being assessed:
Department and Section:
Human Resources
Names and roles of officers completing
this assessment:
Senior/HR Adviser, Corporate Resources
HR Services
County Hall
Glenfield
LE3 8GA
Contact Telephone Numbers:
0116 3056744
0116 3056028
Date assessment completed:
March 2010
Defining the policy
1. Why is the policy necessary? What are its aims and objectives? What outcomes is
the policy designed to achieve and for whom?
The purpose of the Council’s Organisational Change Policies and Procedures is to provide
managers with clear guidance to oversee organisational change within the Council. The
Redundancy and Restructuring Policy and Procedure acts as a framework based around
statutory requirements whereas the Redeployment and Disturbance Policies and Procedure
support its implementation.
The aims of the policies are to provide a fair, transparent and effective process for dealing with
such situations, ensuring compliance with statutory requirements. Employees will receive as
much notice as possible of any organisational change and consultation with Trade Unions will
always exist.
The objectives are to ensure as far as possible the security of employment for its employees.
However, there may be changes to legislation, organisational requirements, financial pressures,
technological developments, etc. which may affect staffing requirements. The Council is
committed to minimising the number of compulsory redundancies and will seek, wherever
possible, to reduce employee numbers by alternative means e.g. reduction in hours, voluntary
redundancy in the first instance.
The policies are applicable to all employees of Leicestershire County Council.
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2. How have these aims, objectives and outcomes been determined? What research and
engagement/involvement/consultation has been undertaken/used to inform the design
and delivery of the policy? How have needs based on race, gender, disability, age,
religion/belief or sexual orientation been taken account of?
Leicestershire County Council identified that the existing Organisational Changes Policy and
Procedure required updating and more comprehensive guidance was needed. Consequently a
decision was made to create three distinct policies, Restructuring and
Redundancy, Redeployment and Disturbance.
Research was undertaken by reviewing similar policies and procedures from other Local
Authorities and guidance from the CIPD and ACAS.
Consultation has take place with:
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Trade Unions
Manager Focus Groups
People Strategy Board
Department Workforce Group
Workers Groups – Black Workers Group, Disabled Workers Group and Lesbian, Gay,
Bisexual and Transgender Workers Group
Legal Services
Employment Committee
Feedback was received from the Trade Union which led to the following changes to the policies;
Disturbance Eligibility Criteria
Originally proposed that employees should travel in excess of 11 miles per day in order to
receive disturbance allowance. Following consultation with the Trade Union this requirement
was reduced to 6 miles.
Compensation Payment
It was proposed to stop awarding compensation payments for reduction in hours. Following
consultation with the Trade Union the existing condition remained in place.
Public Transport
In order to support the Councils commitment to green travel it was agreed that employees
travelling to work by public transport would be recompensed for the full additional travel costs
and not just for the amount in excess of 6 miles per day.
3. (a) Who is responsible for implementing the policy? What processes, procedures
and/or criterion will be critical to deliver the policy? Review these against the
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access needs that various equality groups of people have and consider if they
result in barriers which prevent these groups of people from either finding out
about the policy or benefiting from it? (See Section 6 for examples)
(b) Consider what barriers you can remove, whether reasonable adjustments may be
necessary and how any unmet needs that you have identified can be addressed.
For disabled people, as defined under the Disability Discrimination Act, this
could mean treating them more favourably to ensure that there is equality of
outcome.
(c) When you are deciding priorities for action you will need to consider whether
the barriers result in an adverse impact or discrimination that is illegal. These
will constitute your top priority. The other priorities will be dependent on such
issues as whether a group is particularly excluded or connected to the core
business of the service, whether there are adjustments that would mean several
groups benefit.
Ensure that the actions you identify are put into the attached equality improvement plan.
a) Line managers will be responsible for implementing the policies. In order to deliver the
requirements of the policies it is critical that line managers follow the procedures outlined
in the documents to ensure that issues prior to, during and subsequent to major
organisational change are managed fairly and consistently. In order to support managers
with the administration of these policies, a training programme for managers will be
conducted. The policies all have accompanying manager guidance and checklists and
further additional support will be available from the Employee Service Centre helpdesk
and HR Services. The policies will be published on the Council’s intranet site and made
available in bases/establishments where there are large numbers of staff based who do
not have access to the intranet.
In terms of implementation of the policies, each action plan will have an individual EIA
which will consider and explore equality issues that may arise.
b) As each action plan will be accompanied by its own EIA any barriers that may exist will be
identified and necessary reasonable adjustments considered.
c) N/a
4. What measures and methods have been designed to monitor the application of the
policy, achievement of intended outcomes and identification of any unintended or
adverse impact? How frequently will the monitoring be conducted and who will be
made aware of the analysis and outcomes? List your answers below.
HR Services will monitor the number of Restructurings occurring at any one time across the
Council and the number of people affected. This information is shared with the Trade Unions to
assist in planning resources.
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A representative from HR Services will provide advice during the development of action plans
and thereafter during any redundancy and redeployment processes, ensuring that the correct
procedures are followed fairly and consistently.
Approval is required from the HR Business Partner prior to an action plan being circulated for
consultation. Following consultation the action plan must be ratified by the Departmental
Assistant Director/Director.
A copy of all action plans are sent to Employment Committee.
Individual EIAs are required to be submitted for each action plan. This would therefore identify
any specific issues regarding a particular restructuring or reorganisation.
A corporate approach to monitoring the equality aspects of action plans will also be adopted, this
will include:
 Monitoring within HR services of the number of EIAs attached to action plans
 Departmental Equalities groups quality assuring t completed EIAs
In terms of redeployment, a database has been developed which in future would allow
management information to be provided to enable analysis of any trends (i.e. the success of
otherwise of the redeployment process in general, analysis of ethnicity and diversity issues). It
is anticipated that a true analysis of these trends would not be viable until April 2011.
5. Consider the answers given in questions 1, 2, 3 and 4 and assess whether the policy
and its implementation results could result in adverse impact on or discrimination
against different groups of people. If you consider that there is adverse impact or
discrimination, or the potential for either, please outline below and state whether is it
justifiable or legitimate and give your reasons for this.
Employees with fewer than 2 years Local Government are not eligible for redeployment status
which may be considered disadvantageous for younger employees. This timeframe reflects the
statutory requirement to receive a compensatory payment.
Employees aged 55+ are eligible for immediate pension benefits if made redundant. This could
be considered disadvantageous for people below 55 as they would not have access to their
pension benefit. This is a condition of Leicestershire County Councils Pension Scheme and as
such can not be altered. Conversely employees may feel that their age is a key determinant
when undertaking a restructuring exercise due to the associated pension related costs in
releasing them. Costs should be only one of several factors when considering requests for
voluntary redundancy / flexible retirement and managers need to ensure a robust selection
process is in place.
As the Council advocates redeployment as a means of reducing the number of redundancies,
unfortunately this inhibits external recruitment. This therefore may prevent the Council from
meeting targets previously set in recruiting a representative workforce. However, the County
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Council has a statutory obligation to assist employees secure redeployment, so its necessary for
the County Council to provide a framework and processes to assist in the redeployment of
employees.
6. (a) If you have identified adverse impact or discrimination that is illegal, you are
required to take action to remedy this immediately.
(b) If you have identified adverse impact or discrimination that is justifiable or
legitimate, you will need to consider what actions can be taken to mitigate its
effect on those groups of people. This arises out of the duty to promote good
relations between people of different groups and is in keeping with the Council’s
approach to social cohesion. Also, the new PSA15 explicitly requires councils to
address disadvantage across all six equality strands.
Ensure that these actions are listed in the attached equality improvement plan.
6 (a) N/a
6 (B) Individual EIAs are required to be submitted for each action plan. This would therefore
identify any specific issues regarding a particular restructuring or reorganisation.
OPPORTUNITIES FOR SOCIAL COHESION OR PROMOTING GOOD RELATIONS
BETWEEN DIFFERENT GROUPS OF PEOPLE
7. Social cohesion is a priority for councils. Progress made towards building more
cohesive, empowered and active communities is now being measured through
national Performance Indicators. Essentially social cohesion is about promoting a
sense of connection, trust and belonging both within and across communities and
groups. Review all the actions and targets that you have identified as a result of this
equality impact assessment to identify what social cohesion issues could arise, for
example:
(a) Are there ways in which the policy development process could bring different
groups of people together, for example to monitor its impact or develop its future
shape?
(b) Could the implementation of the policy result in different groups of people being
brought together? Has the capacity of the policy to bring different groups
together been fully utilised?
(c) Does the implementation of the policy have the potential to lead to resentment
between different groups of people? How can you compensate for perceptions
of preferential or differential treatment? Are these implications or decisions
being explained to those affected?
(d) If the EIA improvement plan identifies addressing a gap in the service for a
particular group of people, has this also addressed the potential for perceptions
of preferential treatment for the group? (For example, if you give priority
treatment to disabled people, how will you manage the negative attitudes that
non-disabled people may develop as a result?)
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(e) How can the policy explicitly demonstrate the council’s commitment to promote
equality across race, gender, disability, age, religion/belief and the LGBT
communities?
List your answers below. Ensure that the actions you identify are put into the attached
equality improvement plan.
7 (a) No
7 (B) No
7 (C) Individual EIAs are required to be submitted for each action plan. This would therefore
identify any specific issues regarding a particular restructuring or reorganisation.
Employees on maternity and adoption leave should be offered a suitable alternative vacancy to
return to if a restructure takes place during their absence. This may cause resentment,
however, it is a statutory requirement and therefore the County Council needs to continue to
follow this practise.
7 (D) The right to return to a suitable alternative post following return from maternity / adoption
leave is a statutory entitlement therefore the Councils policy can not be amended.
7 (E) The Council’s commitment to equality of opportunity is demonstrated within the principles
of the three policies. The policies advocate that at all times during their operation employees
are treated fairly and without discrimination on the grounds of race, nationality, ethnic or national
origin, sex, marital status, disability, age, sexual orientation, trade union membership or activity,
political or religious belief and unrelated criminal conviction.
Each action plan will have an individual EIA which will consider and explore equality issues that
may arise.
The Council is committed to consulting with the Trade Union and Workers when developing
policies and producing action plans to ensure equality exists across all 6 equality strands.
The Organisational Change Polices and Procedures will be reviewed cyclically taking on board
any feedback received by the Trade Unions and workers groups.
The number of employees made redundant as a result of a restructure will be monitored and any
apparent inequality will be addressed.
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8. EQUALITY IMPROVEMENT PLAN
Please list all the equality objectives, actions and targets that result from the Equality Impact Assessment (continue on separate sheets
as necessary). These now need to be included in the relevant service plan for mainstreaming and performance management purposes.
Equality Objective
Ensure Policy supports
managers to take account of
needs based on equality strand
when planning restructure or
redundancy
Ensure Policy supports
managers to take account of
needs based on equality strand
when planning restructure or
redundancy
Ensure equality issues are
considered as part of the
formulation of action plans
Ensure equality issues are
considered as part of the
formulation of action plans
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Action
Target
Officer
responsible
By when
Inclusion of EIA template as
part of restructuring and
redundancy action plan
template
EIA template produced and
launched
Senior HR
Adviser
Occurring
currently
Inclusion of Equality Impact
Assessment guidance in
restructuring and redundancy
policy
Guidance included as part of
policy documentation
Senior HR
Adviser
04/2010
Asst Hr Adviser –
Resourcing and
Strategic
Development
Team, HR
Services
Departmental Equalities Groups Departmental Equalities Groups Equalities Board
to quality assure Equality
regularly quality assure EIA’s
Impact Assessments
and quarterly report received by
Equalities Board
Monitor number of action plans
received that contain an EIA
Quarterly reporting on the
number of EIA’s included in
action plans
On-going
On-going
1st Authorised signature (EIA Lead) ……………..……………………… Date: ………………………………………………………..
2nd Authorised signature (Member of DMT) …………………………………………. Date: …………………………………………
Once completed and authorised, please send a copy of this form to the Equality and Diversity Team in the Chief
Executives Department.
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