When reviewing, planning or providing services Northampton Borough Council needs to assess the impacts on people. Both residents and staff, of how it works - or is planning to
– work (in relation to things like disability). It has to take steps to remove/minimise any harm it identifies. It has to help people to participate in its services and public life. “ Equality Impact
Assessments” (EIAs) prompt people to think things through, considering people’s different needs in relation to the law on equalities. The first stage of the process is known as
‘screening’ and is used to come to a decision about whether and why further analysis is – or is not
– required. EIAs are published in line with transparency requirements.
A helpful guide to equalities law is available at: www.northampton.gov.uk/equality . A few notes about the laws that need to be considered are included at the end of this document.
Helpful questions are provided as prompts throughout the form.
1 Name of policy/activity/project/practice
This is:
Existing practice. Decent Homes Phase 1 was an earlier similar programme.
2. Screening undertaken (please complete as appropriate)
Director or Head of Service Christine Ansell, Landlord Services
Lead Officer for developing the policy/activity/practice
Mark Plant, Housing Asset Management
Other people involved in the screening (this may be people who work for NBC or a related service or people outside NBC)
Rachael Scrivener
Lesley Dalby
Alice Arden-Barnatt
3. Brief description of policy/activity/project/practice: including its main purpose, aims, objectives and projected outcomes, and how these fit in with the wider aims of the organisation.
The Decent Homes Programme Phase 2 has been put in place to ensure properties selected for the programme meet the governments Decent Homes Standard. All properties must reach this standard by a date negotiated with Government. More information on this is set out in the Housing Asset Management Strategy that is subject to its own EIA screening.
The programme is contracted to run for 3 years to the value of £22m. This will cover 3,672 properties and will be undertaken by 2 contractors. The contracts commenced in October
2010 .
Homes are surveyed and if the following criteria is not met, then works are carried out to bring the property up to standard:
1. It must meet the current statutory minimum standards for housing
2. It is in a reasonable state of repair

3. It has reasonably modern facilities and services
4. Provides a reasonable degree of thermal comfort
Works to the property can include: re- wiring, replacement of kitchens, bathrooms, some windows, heating, asbestos removal, and other minor works.
Corporate Plan fit:
 ‘Provide good quality homes for tenants’ and ‘support people to live independently.’ which falls under CP 2 Ensuring homes are available for local people.
In addition the project will:
 ‘Deliver value for money services’, which falls under CP 8 ‘Providing quality services’.
 ‘Work to understand our customer’s needs’, under CP 9 ‘Satisfying our customers needs’.
 ‘Ensure residents can influence service delivery and improvement’ and
‘Continuously review customer feedback to further improve our services’ under CP 7
‘Being a responsive Council.’
The programme will deliver the following Housing Service Plan priorities:

Improve the decency of council housing, as the main priority.
In addition the programme will;

Support people to live independently

Enable people to have homes that meet their needs

Increase involvement of tenants in service delivery

Improve the approach to planned maintenance
4 Relevance to Equality and Diversity Duties
Is it linked to
NBC’s Single Equality Scheme?
NBC ’s Public Sector Duties?
Equality Framework Criteria? Service or departmental equality priorities?
Please explain:
The programme can have significant disruption to tenants’ lives. Some properties can require a number of elements of major works, whilst other properties surveyed will not require any. The majority of tenants stay in their homes whilst works are undertaken. If tenants have to move out then the Council works with them to find the best option to do this.
Good communication about the timing of the works in tenants homes is paramount. The
Council must ensure that works are carried out with the minimum of disruption where possible, meet tenants needs, carried out sensitively and with some flexibility.
The following Housing Directorate commitments to equality and diversity are the most relevant to the aims and outcome of Decent Homes Programme Phase 2:

Respecting diversity and difference- the project officers and trades must respect any requirements that tenants may have that differ from the majority of tenants

Eliminating barriers to equality- effective communication with tenants about the nature and timing of the works.

Tackling harassment effectively- ensuring contractors comply with NBC equality duties in the procurement process, processes in place in the event of any reports of

harassment,

Leading on awareness raising- NBC ensuring contractors are adhering to our standards.

Creating a workforce that reflects the diverse population of the Borough.

Looking after the most vulnerable- our customer base has a higher proportion of vulnerable tenants than the general population. Project Liaison Officers are in post to ensure the experience is the best it can be for tenants and are available to provide extra support and information to tenants where needed
How will the aims affect our duty to:
Promote equality of opportunity?
Eliminate discrimination, harassment and victimisation?
Promote good community relations?
Promote positive attitudes towards people with protected characteristics?
Encourage participation of people with protected characteristics?
Protect and promote Human Rights?
For example, think about it from the perspectives of different groups in society. Does it cause harm or a benefit to any group(s) differently to others? Will it differentially affect:
Black, Asian or other ethnic minority and/or cultural groups?
Disabled people? And their carers?
Transgender people?
Men and women?
Lesbians, gay men and/or bisexual people?
Different religious communities/groups?
People of a particular age e.g. older people or children and young people?
Any other groups?
People with flexible or agreed working patterns?
Are there any aspects, including how it is delivered, or accessed, that could contribute to inequalities? (This should relate to all areas including Human Rights .)
No
Please explain:
The aim of the programme to get the selected homes up to the decent homes standard, affects a large number of our tenants irrespective of their equality group. The outcome of the programme should have a positive impact on all, as the home will be up to modern standards, could be safer, and better meet tenants needs where heating has been updated.
The programme could have a negative impact on groups that may face greater disruption to their home life such as some elderly or disabled residents and pregnant women. Works may be postponed where a baby is due. Whilst we attempt to make sure we gain access to the property so that all homes are surveyed, residents can opt out of some works required.
Electrical and gas works are mandatory however. Another attempt to contact the resident at a later is made or when the property becomes empty. Works however must be carried out, and as long as the tenants are fully aware of the nature and timing of the works, they have the opportunity to make alternative arrangements.
Surveyors visit tenants homes to identify what works are required if any, and at the same time will identify where tenants require an assessment for bathing appliances/support. It is important this assessment is carried our prior to arranging for a replacement heating system.
People who are at work during usual contractor hours make individual arrangements with the contractor.

It is particularly important that every effort is made to ensure tenants understand what is happening to their property and when. Our IBS system- Housing IT system holds a range of information about our tenants needs such as communication needs and disabilities that could be used. This information is passed on to the contractor prior to visits. A delivering
Decent Homes booklet has been provided to every tenant potentially affected by work. The booklet explains the service tenants can expect, contact numbers, a residents’ charter, and a strapline explaining that information can be made available in other languages in the most requested translations. Contractors carry language cards.
There was opportunity to ensure that the resident steering group which has been set up to monitor and suggest service improvements was well represented by equality groups, especially groups such as the elderly and disabled who are likely to be most affected by the works. The group has a low attendance however and is due to be reviewed. There are attempts being made to encourage more tenants to join the Steering Group from all equality groups. Currently there is representation from Disabled, Ethnic Minorities and the
Elderly. The project will actively seek tenant involvement by attending area meetings, speaking to Sheltered Housing and seeking support from the Customer Engagement
Team.
If you have indicated there is a negative impact on any group, is that impact:
Any potential negative impact could be mitigated if proper procedure is followed.
Legal: No impact
Intended: No impact
5 Evidence Base for Screening
List the evidence sources you have used to make this assessment (i.e. the known evidence)
(e.g. Index of Multiple Deprivation, workforce data, population statistics, any relevant reports, customer surveys, equality monitoring data for the service area.)
Customer profile information
Customer satisfaction surveys
Are there any significant gaps in the known evidence base? If so what are your recommendations for how and by when those gaps will be filled?
To gain a better idea of the customer experience by equality group, more survey returns are needed. The Council should explore ways to do this., such as telephoning tenants to take the information over the phone.
6 Requirements of the equality duties:
(remember there’s a note to remind you what they are at the end of this form and more detailed information at www.northampton.gov.uk/equality )
Will there be/has there been consultation with all interested parties?

Please explain:
The Decent Homes Programme must be completed, there is no opportunity to consult on whether the programme can go ahead.
All tenants affected by the programme have been contacted by letter and provided with a booklet to explain the programme and what could happen.
A Decent Homes open day was held to give tenants the opportunity to meet the contractors delivering the programme. A tenants group has been set up to monitor service delivery.
Are proposed actions necessary and proportionate to the desired outcomes?
Yes
Please explain:
As above
Where appropriate, will there be scope for prompt, independent reviews and appeals against decisions arising from the proposed policy/practice/activity?
Yes
Please explain:
Customer satisfaction surveys are used and meetings are held regularly between the
Council and the contractor to discuss any issues. Tenants are encouraged to contact the contractor’s Tenant Liaison officers (TLO) or the Council where advice is needed or the tenant is not happy. Due to the nature of the programme – the number of properties, the amount of work and the intrusive nature of the work, there is scope for things to go wrong.
The contractors need to build flexibility into their programme to allow for changes and meeting individual tenants needs. Feedback is requested following completion of works and this is used to inform service improvements.
Does the proposed policy/practice/activity have the ability to be tailored to fit different individual circumstances?
Yes
Please explain:
Some heating systems will not be suitable for tenants with relevant medical need – like asthma for example. By visiting the tenant before works this can be noted and other arrangement on system type made.
Where appropriate, can the policy/practice/activity exceed the minimum legal equality and human rights requirements, rather than merely complying with them?
Yes
No
Comply
Please explain:
From the evidence you have and strategic thinking, what are the key risks (the harm or
‘adverse impacts’) and opportunities (benefits and opportunities to promote equality) this

policy/practice/activity might present?
The contractor employs a Resident Liaison Manager and the Council employs Project
Liaison Officers that ensure individual needs, where possible, can be considered. Each property receives a visit or phone call from the contractor’s TLO prior to works and during the time the property is being upgraded to assess and identify potential concerns/considerations.
Prior to contractors visiting residents in their home, the Council’s Project Liaison Officers supply information about the tenant’s communication needs and other relevant information, currently held by the Council. This information is found from the IBS system- Housing IT system that is updated regularly.
Customer Satisfaction was the highest weighted factor when judging the ‘quality’ element of the tenders in the procurement process. This involves the tenderer providing information on the following: ‘ A detailed statement of the tenderer’s approach to obtaining high levels of customer satisfaction. Proposals for communications with occupiers whose first language is not English or occupiers with sight or hearing disabilities and for vulnerable occupiers shall be provided as part of this Statement.’ Information on how the contractor deals with
Resident Liaison makes up another 15% weighting.
Risks (Negative)
None
Opportunities (Positive)
None Race
Disability
Gender or Gender
Identity/Gender Assignment
Pregnancy and Maternity
(including breastfeeding)
None
None
Works are too disruptive and not conducive for a new baby or mother in labour.
Works are postponed or considered for prioritisation to mitigate this.
None
None
None
None Sexual Orientation
Age (including children, youth, midlife and older people)
Religion, Faith and Belief Consideration is given to religious and other requirements.
Minors are not visited alone.
The Council follows a ‘duty of care’ and the Safe
Guarding Children & Adults
Legislation.
This will be identified at
Tenant Profile stage by the contractor and will be discussed with the tenant on how to precede the works.

Human Rights Safety due to works in the homes. The nature of working in resident’s homes means regards must be taken to dignity, privacy and fairness.
The tenant satisfaction survey asks the following: whether enough information was received before the work started; a start date and time was arranged; the contractor kept the appointment; clean and tidy during works; completion on time; quality of works; polite and helpful staff; satisfaction and improvement.
Questionnaires with an envelope included are hand delivered to residents.
7 Proportionality
Describe the scale and likelihood of these risks and opportunities
A full identification of the proportion of tenants profile has been completed to ensure the contractor of the works, are aware of elderly residents of an older age, individual requirements and sites with young children around.
8 Decision
Set out the rationale for deciding whether or not to proceed to full impact assessment
Date of Decision: 12/12/2011
We judge that a full impact assessment is not necessary since: The initial screening has confirmed relevant risks and equalities have been considered.

Prohibited Conduct under The Equality Act 2010 including:
Direct discrimination (including by association and perception e.g. carers); Indirect discrimination;
Pregnancy and maternity discrimination; Harassment; third party harassment; discrimination arising from disability.
Public Sector Duties (Section 149) of the Equality Act 2010 for NBC and services provided on its behalf: (due to be effective from 4 April 2011)
NBC and services providing public functions must in providing services have due regard to the need to: eliminate unlawful discrimination, harassment and victimisation; advance equality of opportunity and foster good relations between different groups.
‘Positive action’ permits proportionate action to overcome disadvantage, meet needs and tackle under-representation.
Rights apply to p eople in terms of their “Protected Characteristics”:
Age; Gender; Gender Assignment; Sexual Orientation; Disability; Race; Religion and Belief;
Pregnancy; Maternity. But Marriage and Civil Partnership do not apply to the public sector duties.
Duty to “advance equality of opportunity”:
The need, when reviewing, planning or providing services/policies/practices to assess the impacts of services on people in relation to their ‘protected characteristics’, take steps to remove/minimise any negative impacts identified and help everyone to participate in our services and public life.
Equality Impact Assessments remain best practice to be used. Sometimes people have particular needs e.g. due to gender, race, faith or disability that need to be addressed, not ignored. NBC must have due regard to the duty to make reasonable adjustments for people with disabilities. NBC must encourage people who share a protected characteristic to participate in public life or any other activity in which their participation is too low.
Duty to ‘foster good relations between people’
This means having due regard to the need to tackle prejudice (e.g. where people are picked on or stereotyped by customers or colleagues because of their ethnicity, disability, sexual orientation, etc) and promote understanding .
Lawful Exceptions to general rules: can happen where action is proportionate to achieve a legitimate aim and not otherwise prohibited by anything under the Equality Act 2010. There are some special situations (see Ch 12 and 13 of the Equality Act 2010 Statutory Code of Practice
–
Services, Public Functions and Associations).
National Adult Autism Strategy (Autism Act 2009; statutory guidelines) including: to improve how services identify and meet needs of adults with autism and their families.
Human Rights include:
Rights under the European Convention include not to be subjected to degrading treatment ; right to a fair trial (civil and criminal issues); right to privacy (subject to certain exceptions e.g. national security/public safety, or certain other specific situations); freedom of conscience
(including religion and belief and rights to manifest these limited only by law and as necessary for public safety, public order, protection of rights of others and other specified situations); freedom of expression (subject to certain exceptions); freedom of peaceful assembly and to join trade unions (subject to certain exceptions); right not to be subject to unlawful discrimination (e.g. sex, race, colour, language, religion, political opinion, national or social origin); right to peaceful enjoyment of own possessions (subject to certain exceptions e.g. to secure payment of taxes or other contributions or penalties); right to an education ; right to hold free elections by secret ballot . The European Convention is given effect in UK law by the Human Rights Act 1998.