RACE EQUALITY
SCHEME
RACE EQUALITY SCHEME
This document is intended to fulfil the Council’s statutory requirement to set out a Race Equality Scheme.
1. BACKGROUND
1.1 The Council’s General Duty to Promote Race Equality
1.1.1 The Race Relations Act 1976, as amended by the Race Relations Act 2000, gives the Council, in common with other public authorities, a general duty to promote race equality. Under the duty, the Council in carrying out its functions must aim to:
• Eliminate unlawful racial discrimination • Promote equality of opportunity
• Promote good relations between people of different racial groups
1.1.2 The duty’s aim is to make race equality a central part of the way the Council works, by putting it at the centre of policy making, service delivery, regulation and enforcement, and employment practice.
1.2 The Council’s Specific Duties
1.2.1 To help public authorities meet this general duty, the Home Secretary made an order under the Act in December 2001that gives them specific duties in policy, service delivery and employment. The aim of these duties is to guarantee better performance of the general duty to promote race equality.
1.2.2 Under the specific duties covering policy and service delivery, the Council must publish a Race Equality Scheme which:
(a) States the functions and policies the Council has assessed as being relevant to the general duty to promote race equality; and
(b) Sets out the Council’s arrangements for meeting the duty by:
• Monitoring its policies for any adverse impact on race equality • Assessing and consulting on the likely impact of proposed policies • Publishing the results of its assessments, consultation and monitoring • Ensuring that the public have access to information and services • Training its staff on the general duty
1.2.3 Under the specific duty on employment, the Council is required to monitor by racial group its existing staff, and applicants for jobs, promotion and training. It must also monitor and analyse by racial group:
• Grievances
• Performance appraisals (when they lead to benefits or penalties) • Training
• Staff leaving the employment of the Council
1.3 Timing
1.3.1 The legislation provides for the Race Equality Scheme to be adopted by the Council by 31 May 2002. The timetable is therefore very tight, a fact which was recognised by the Commission for Racial Equality itself when it issued in
December 2001a draft Statutory Code of Practice covering both the general duty and the specific duties, indicating that the final version of the Code would not be issued until May 2002.
1.3.2 The Council’s Race Equality Scheme has been prepared in the light of the Commission’s initial advice, and guidance from the Employers’ Organisation for local government by way of seminars and workshops.
1.3.3 Due to the short timescale and the absence of definitive advice the proposed Scheme is necessarily provisional and will need to be looked at again when there has been an opportunity to carry out further research and study examples of best practice
1.4 The Council’s commitment
1.4.1 The Council welcomes this opportunity to re-affirm its commitment to promoting racial equality. It fully supports the underlying principle of the legislation which is to “mainstream” race issues so that they become fully integrated into all the Council’s thinking and activities. The disciplines which are set by the legislation should help to give form and structure to its overall strategy for promoting equality.
1.4.2 For many years the Council has had an active Equal Opportunities Policy for employment issues, notably in the field of recruitment and selection. There is now an established practice for the regular and comprehensive monitoring of existing staff and job applicants, and targets are set in relation to the population of the District as a whole.
1.4.3 In 1998 the Council adopted the Commission for Racial Equality (CRE) Standard which sets levels of achievement for racial equality in policy making and service delivery as well as employment. The Council’s performance against the Standard was monitored as a Best Value performance indicator, resulting in the achievement of Level 2 last year which placed us in the upper quartile of authorities.
Strategy document for staff which dealt specifically with the implications of the Stephen Lawrence Inquiry, and which published the CRE Standard in full.
1.4.5 At service level actions arising from the Stephen Lawrence Inquiry were built into Service Plans.
1.4.6 The AVDC/AVREC Liaison Forum established a number of priorities for action, one of which was to train all staff in cultural awareness. A two-year series of courses is currently well under way and staff at all levels are required to attend.
1.4.7 A widespread awareness of cultural differences is seen as critical to the policy of “mainstreaming” racial equality. It is only empathy, sensitivity and
understanding on the part of individual members of staff that is likely to break down the barriers of institutional racism and uncover those aspects of racism which are effectively hidden and which rarely surface as formal complaints.
1.4.8 The courses in cultural awareness reinforce the messages that the Council seeks to impart in its Customer Care Policy which stresses the importance of treating people as individuals, and of identifying and meeting their needs, especially the needs of members of particular social or community groups.
2. HOW THE COUNCIL PROPOSES TO IMPLEMENT THE GENERAL DUTY
2.1 The Council will continue to promote racial equality at corporate and at service level
2.2 A member of the Council’s Cabinet will assume responsibility for promoting racial equality within the Council generally. This will include reviewing policy, making recommendations for change, oversight of monitoring at all levels, and ensuring that adequate funds are available. The Cabinet Member will be assisted by their Policy Advisory Group and a team of officers who will be drawn from the service areas most affected. This support group will work collaboratively with Heads of Service and other officers to promote equality of opportunity at all levels of the organisation.
2.3 At the level of service delivery all Service Plans will specifically address race equality as an issue. Even where it has been concluded that a service has no immediate impact on race equality because, for example, there is no current reason for believing that ethnic groups are affected differentially, the Service Plan will indicate what steps have been taken to arrive at these findings.
2.4 Where services have a particular relevance to the General Duty a programme of action will be specified in the Service Plan which is likely to include
2.5 Similarly, Best Value Reviews will take full account of race equality issues as a matter of routine by screening issues for relevance and prioritising actions. The outcomes will be incorporated into Service Plans.
2.6 As Procurement is a relevant function under the Race Relations Act the Council will review its procurement policy in order to ensure that its duty to promote racial equality is built into the specifications for outsourced services. This means specifying to contractors and other providers a service that meets the needs of all groups in the community.
2.7 The Council will also seek to influence organisations that are in receipt of grant from the Council by reviewing service level agreements to ensure that the promotion of race equality is a condition of grant.
3. HOW THE COUNCIL PROPOSES TO IMPLEMENT THE SPECIFIC DUTIES
3.1 As required by the legislation the Council has examined all its functions and policies to determine which of them are relevant to the general duty to promote racial equality. This has been accomplished by interviewing each Head of Service individually and recording outcomes. Heads of Service were asked to assess the degree of relevance of each function and policy and to draw up a list of priorities for action.
3.2 Broadly speaking any service which has a direct customer inter-face was seen as having a potential impact on racial equality. The specific screening criteria were:
Is there any evidence, or other reason to believe, that there is a higher or lower participation or uptake by different groups?
Is there any evidence, or other reason to believe, that different groups have different needs, experiences, issues and priorities in relation to the particular policy?
Have consultations with relevant groups, organisations or individuals indicated that particular functions or policies create problems which are specific to them?
3.3 The attached list, which has been compiled from the data collected from the Heads of Service, shows the list of relevant functions and policies in full and gives an initial indication of when action is planned over the 3-year period beginning April 2002. Year 1(2002/3) is seen as top priority, Year 2 (2003/4) as medium-term priority, and Year 3 (2004/5) as low priority. At this stage no specific action is planned for many of the entries in Year 3 because, based on the best information available, there is little or no evidence of adverse impact on black and minority ethnic groups. However these services will be kept under constant scrutiny and will be fully assessed again in Year 3.
4. WHAT ARRANGEMENTS THE COUNCIL WILL MAKE FOR MONITORING FOR ADVERSE IMPACT
4.1 The Council recognises the need to collect, store and analyse data about people’s ethnic backgrounds with a view to:
Highlighting possible inequalities Investigating the underlying causes Removing any unfairness or disadvantage
In service delivery this means identifying which groups are using the Council’s services, and how satisfied they are with them, as a first step to considering ways of reaching under-represented groups and making sure that services are targeted and provided fairly.
4.2 In monitoring service delivery four main activities can be identified:
Ongoing contact – which monitors people’s experience over a period of time of the processes that are used to deliver the services, and shows how different ethnic groups are treated at different stages of a process.
“Episodic” contact – which looks at what happens when contact between the Council and the service user is short term, limited and occasional
“Usage” - which enables the Council to draw up profiles of service use and the needs of different groups
Satisfaction or complaints – which can be carried out by adapting routine customer satisfaction surveys and records of service complaints to include a question about ethnic background.
4.3 These different kinds of monitoring will be incorporated into notes for guidance for Heads of Service to assist them in carrying out the actions for promoting racial equality prioritised in their Service Plans. Service Heads will also be encouraged to review any existing monitoring systems and to decide whether systems need to be improved or even replaced; and to research any other data that is currently available either within the Council or externally. External data that Service Heads may use include:
Information from other Councils Census
Continuous Household Survey Pressure group data
Statutory agencies Deprivation studies Published research reports Community views
4.4 Service Heads will also be encouraged to use active consultation with
Consultation may take the form of surveys, interviews, focus groups or regular meetings with dedicated community groups. Consultation is seen as a means for effecting improvements as well as simply identifying inequalities.
4.5 The guidance notes for Service Heads will cover the kind of targets and indicators that may be used to evaluate the effectiveness of the policy or function. Also, most importantly, Heads of Service will be advised on how to make a full evaluation of any apparent adverse impact and to consider what measures may be appropriate for rectifying the situation.
5. WHAT ARRANGEMENTS THE COUNCIL WILL MAKE FOR ASSESSING AND CONSULTING ON THE IMPACT OF PROPOSED POLICIES
5.1 The Councilrecognises the need for carrying out a so-called “impact
assessment” of proposed policies as well as existing ones. The arrangements set out above for screening and monitoring existing functions and policies are essentially impact assessments in that they represent a systematic way of finding out whether a function or policy has a differential effect on different racial groups. An impact assessment of proposed policies differs in that it helps the Council to identify potential rather than actual inequalities and provides the opportunity to respond appropriately in advance.
5.2 The Council acknowledges that impact assessment is an integral part of policy making, and that the assessment should begin as soon as a relevant new policy is considered.
5.3 The Council will operate a three tier scheme of assessment which will apply to all proposed policies and changes to existing policies. An initial screening will be carried out in the way described above, based on existing knowledge and data and best estimates of the size of the issue and the people it will affect. Where the screening points to a possible differential effect on different racial groups, a partial impact assessment will follow, building on the initial screening by
outlining the risks and benefits, and including the informal advice of experts and interested groups. Where necessary the partial assessment will be expanded into a full impact assessment which will be formally reported and which will include the results of external consultation, a final recommendation and arrangements for monitoring and evaluating the assessment.
5.4 The sources of data for a full impact assessment will generate questions like;
What existing quantitative and qualitative data is available in house, or externally?
What additional data is needed?
Is there a need to generate primary data?
Is there a need for a secondary analysis of existing data? Who will be partners in the information gathering?
vary according to need but will be designed to allow and encourage people from all ethnic backgrounds to take a full part. The Council recognises that
traditional methods have not always been successful in persuading people from ethnic minorities to take part and welcomes the suggestions made by the Commission for Racial Equality in their draft Code of Practice on the new legislation.
5.6 The final stage of the process is to review a proposed policy or change in policy in the light of the assessment and consultation, and if appropriate make
revisions. Questions that need to be asked include:
Is there a different impact on different racial groups?
Is there any difference in the conclusions drawn from different information sources, or are they consistent?
Does the policy appear to be directly or indirectly discriminatory?
Is there an alternative measure that could achieve the same goal without adverse impact?
5.7 In considering options for change the Council will have regard to the following:
How each option meets all or some of the three elements of the General Duty How each option challenges or reinforces stereotypes
What the net social/equality benefits of each option are How the final recommendations on options will be justified How the impact of the selected option will be monitored
5.8 The principles and criteria set out above will be incorporated into the guidance notes for Service Heads on the new legislation. Service Heads will be expected to apply the three tier scheme of impact assessment to all proposed policies and changes to existing policies which fall within their remit and which do not need to be reported to Cabinet or Council. Their assessments will need to be reported in their Service Plans.
5.9 Where a proposed policy or change in policy is listed on the Council’s forward plan of policies to be decided by the Cabinet, a more corporate approach will be adopted. The Council’s forward plan, which is produced on a four-month rolling basis, will be scrutinised by the Cabinet Member who has overall responsibility for promoting race equality. The Cabinet Member will make an initial impact assessment and decide what further action may be necessary in consultation with the equalities support group (as defined in paragraph 2.2 above). Service Heads will then be asked to take appropriate action referring assessments back to the Cabinet Member as necessary.
6. HOW THE COUNCIL WILL MEET ITS DUTY FOR MONITORING EMPLOYMENT
6.1 The Council recognises that employment monitoring provides a basis on which to:
Make sure that staff selection decisions are based on objective criteria that strictly match the job to be done
Avoid unlawful discrimination in employment
Make sure that the Council achieves its employment targets
Make the workforce more representative of the community the Council serves
6.2 The Council’s arrangements for monitoring the areas of employment specified in the legislation are set out below and will all be operative for the year
commencing 1April 2002. The monitoring will be carried out by the Personnel Division in collaboration with Heads of Service.
Staff in post
The Council already monitors staff in post and reports its ethnic profile annually to Cabinet, showing the distribution of ethnic categories by grade. Last year ethnic minority staff represented 3.6% of the workforce against an interim target of 4.0% which is based on the minority ethnic population of the District as a whole. The target will be reviewed when the 2001 Census figures become available.
Applicants for employment
The Council also monitors all job applicants and reports the results annually to Cabinet. Monitoring takes place at each stage of the recruitment and selection process, i.e. at application, shortlisting and appointment. The Council’s current objective is to attract more applications from people from ethnic minorities.
Applicants for training
The Council does not have applicants for training as such. Training needs are normally established as part of the staff appraisal process and are mutually agreed between line manager and member of staff. The Council will focus its monitoring on those staff who receive training, as set out below.
Applicants for promotion
The Council will now include successful internal applicants in its monitoring of appointments by ethnic origin, and compare the success rates of internal and external candidates.
Staff receiving training
The Council will monitor training by ethnic origin under three main heads:
Post-entry
External courses, including provision by individual departments In-house courses
In recognition of their contribution to career development, the following areas will be monitored separately:
Management development training Supervisory development training Secondments
Staff who benefit or suffer detriment as a result of its performance assessment procedures
This duty is not seen as applicable to the Council by virtue of the nature of its appraisal procedures.
Staff who are involved in grievance procedures
The Council will monitor complaints raised under its formal Grievance Procedure and its Bullying and Harassment Procedure; and appeals against Hay Job Evaluations.
The data collected will include the nature of the complaint; whether it was resolved and at what stage of the process; and what action was recommended.
Staff who are the subject of disciplinary procedures
The Council will monitor all formal action under its Disciplinary and Appeals
Procedure and its Capability Procedure, including Stage 1 warnings; and disciplinary action under its Probation Procedure.
The data collected will include the nature of the offence or shortcoming; the finding, including the penalty where appropriate; whether there was an appeal; and the outcome of an appeal
Staff who cease employment
The Council will monitor dismissals including any compulsory redundancies and will also collect data from voluntary leavers by way of an exit questionnaire which will focus on the reasons for leaving. The questionnaire will be supplemented on occasions by targeted face-to-face interviews with staff.
7. WHAT ARRANGEMENTS THE COUNCIL WILL MAKE FOR TRAINING ITS STAFF ON ITS DUTY TO PROMOTE RACE EQUALITY
7.1 The Council will focus on the training needs of those staff who have special responsibilities for managing and introducing its Race Equality Scheme. These staff will be primarily Heads of Service and line managers in areas that are particularly affected.
7.3 This training programme will build on the Council’s existing cultural awareness training which staff at all levels are due to attend
8. WHAT ARRANGEMENTS THE COUNCIL WILL MAKE FOR PUBLISHING THE RESULTS OF ITS ASSESSMENTS,
CONSULTATIONS, AND MONITORING
8.1 Where actions are taken in pursuance of Service Plans the results of
assessments, consultations, and monitoring will be reported in the following year’s Plan.
8.2 Various methods will be used to publicise outcomes to the public, including a regular item in the spring edition of District Link which will summarise any main outcomes and indicate where further information can be obtained. There will also be permanent notices at the Customer Service Centre and Area Offices indicating where information about outcomes can be obtained and a similar entry on the AVDC web site. The Council’s housing tenants will receive information in the Tenants’ Newsletter. Where appropriate, press releases will be issued.
8.3 The Council’s staff will be informed about outcomes in the spring edition of District Line. There will be an introductory article in the District Line this summer to let staff know about the Race Equality Scheme, and how outcomes are to be published. New entrants to the Council will receive information as part of their induction training.
8.4 Once specific aims, targets and indicators have been established at service level they will be used to measure outcomes and will form an important part of the published material.
8.5 The outcomes of employment monitoring will continue to be reported separately every year to Cabinet as part of the Council’s strategy for promoting equality of opportunity in employment.
9. WHAT ARRANGEMENTS THE COUNCIL WILL MAKE FOR
ENSURING THAT PEOPLE HAVE ACCESS TO THE INFORMATION AND SERVICES IT PROVIDES
9.1 Through its Marketing and Information Division the Council already takes a number of measures to publicise its services as widely as possible and to make them generally accessible.
9.2 The Division commissions market research surveys which normally specify that a sample of ethnic minority people should be interviewed, together with
guidelines on how people should be approached, including the use of interpreters where necessary.
9.4 Most of the leaflets promoting Council services carry a strapline in Asian languages referring the customer to a translation service.
9.5 The Council has a presence at an annual fair designed to assist Asian people in understanding what public benefits may be available to them
9.6 The Council has strong links with Aylesbury’s Multi-Cultural Centre, and liaises closely with the local race equality council (AVREC) both formally and
informally.
9.7 For customer comments, compliments and complaints there is a Council-wide scheme which is designed to monitor ethnic origin and other equalities. In addition the Customer Service Centre invites everyone to complete short customer satisfaction forms.
10. TIMETABLE OF KEY EVENTS
10.1 Spring/Summer 2002
Race Equality Scheme is reported to Cabinet (21 May) and to Council (12 June)
Race Equality Scheme is publicised in an edition of District Link (for the public) and in District Line (for AVDC staff)
Action points arising from the Scheme are incorporated in Service Plans by Heads of Service
A Cabinet Member is appointed to assume overall responsibility for race equality (and other equalities)
A support group or steering group is formed of officers to assist the Cabinet Member.
The AVDC/AVREC Liaison Forum considers its role in relation to the Scheme
The outcomes of existing employment monitoring are reported to Cabinet.
10.2 Spring 2003
The Race Equality Scheme is reviewed in consultation with Heads of Service
PRIORITISATION OF FUNCTIONS AND POLICIES THAT ARE RELEVANT TO THE COUNCIL’S GENERAL DUTY TO PROMOTE RACE EQUALITY
YEAR 1: 2002/2003
RELEVANT FUNCTION OR POLICY ACTION TO BE TAKEN
Housing Needs and Strategy
Strategy development Participation in: Housing Investment Programme Strategy;
Homelessness Strategy;
Enabling Strategy
Homelessness (dealing with applications; providing temporary accommodation)
Ongoing monitoring of applicants by ethnic origin
Housing and Budget Advice (to any resident seeking help)
Ongoing support to residents, liaising with AVREC on individual cases, and supporting AVREC on Asian Women’s Advice Fair, and advice surgeries on Aylesbury estates
Lettings (including waiting list, allocation of tenancies, and nominations to housing associations)
Ongoing monitoring of applicants by ethnic origin
Best Value Include in review of landlord services the need to consult ethnic minority groups and to make provision for their needs
Housing Tenancy Services
Collection of Rent Arrears Ongoing attention to communication needs. Tenant satisfaction surveys to be reviewed with the object of improving effectiveness. Will cover maintenance as well as rent collection
Tenant Participation Monitoring of attendance at tenants’ meetings by ethnic origin with a view to improving levels of attendance of the Asian community
Dealing with anti-social behaviour Improved methods for reporting and recording racial incidents
Environmental Health
Applications for grant will continue to be monitored by ethnic origin
Licensing of taxis Ongoing consultation with representatives of the taxi drivers with a view to improving service delivery, e.g. cameras in taxis
Food Safety/Health and Safety in commercial premises
Survey of residents’ understanding of
correspondence to be carried out with special regard to residents with English as a second language
Public Health Improvement Healthy Living Centre due to be opened this year at Walton Court, targeted at improving well-being of ethnic minority groups in the area
Leisure
Arts development Applications are to be monitored
Facility Management (including gymnasiums and swimming pools)
User surveys are to be carried out
Holiday Activity Programme User surveys are to be carried out
Leisure Marketing Promotional material is to be reviewed
Play Development and Sports Development User surveys are to be carried out
Revenues and Benefits Division
Relations with customers In-depth review of correspondence with customers in the interests of greater simplicity and clarity
Planning
Planning applications Review the way in which data on ethnic origin is collected and monitored, and how it is used
Design Services
Housing Tenant Liaison In conjunction with Housing Tenancy Services, to consider ways of involving tenants more closely in issues arising from building improvement/maintenance work
Marketing & Information
External communications Continue to raise awareness internally and
and interpreting services; and to monitor the take up of these facilities
Market research Analyse by ethnicity the responses to the next set of exit interviews at AVDC’s Customer Service Centre
Chief Executive’s Support Services
Awarding grants Review publicity material to get to “hard to reach groups”
Economic Development: Business support Review AVDC support for agency providing business support to ensure that the nature and accessibility of the service meets the needs of all community groups
Community Safety: Youth Research to be undertaken with Bucks CC to identify youth needs, including those of ethnic minority groups.
Community Safety: Drug and Alcohol Abuse Support to agency which is currently working to improve access by ethnic minority groups to drug services
Personnel
Job applicants Ongoing monitoring and reporting
Profile of existing staff Ongoing monitoring and reporting
Applicants for promotion To be monitored from 1 April 2002
Staff receiving training To be monitored from 1 April 2002
Staff raising grievances To be monitored from 1 April 2002
Staff subject to disciplinary action To be monitored from 1 April 2002
Staff leaving AVDC employment To be monitored from 1 April 2002
Property and Operational Services
Year 2: 2003/2004
RELEVANT FUNCTION OR POLICY ACTION TO BE TAKEN
Housing tenancy services
Day-to-Day Repairs and Planned Maintenance Introduce monitoring by ethnic origin of customer satisfaction returns
Business Support: Direct Debit/ Standing
Order/Right to Buy Introduce monitoring of applications by ethnic origin
Leisure
Cemeteries Records of Muslim interments to be monitored
Civic Centre User survey to be carried out
Countryside Management User survey to be carried out
Tourism User survey to be carried out
Design Services
Housing Tenant Liaison Investigate viability of partnership pilot contract
Planning
Development Control, Forward Plans and Strategic Implementation
Review effectiveness of communication with stakeholders, including “hard to reach groups”, and their engagement in the planning process Review scheduled for Year 2/Year 3
Housing Needs & Strategy
Strategy Development Housing needs and preferences of ethnic minority groups to be subject to a specific review with the object of developing a strategy
Chief Executive’s Support
Awarding grants Review SLA performance indicators to include information on ethnicity
YEAR 3: 2004/2005
RELEVANT FUNCTION OR POLICY ACTION TO BE TAKEN
Leisure
Allotments Applications to be monitored
Arboriculture Applications to be monitored
Parks and Open Spaces User survey to be carried out
Play Areas User survey to be carried out
Environmental Health
Sustainable development Review again for impact
Public Health Review again for impact
Entertainment Licensing Review again for impact
Pest Control Review again for impact
Design Services
Building Control Review again for impact
Shopmobility Review again for impact
Dealing with dangerous structures Review again for impact
Customer Services
Face-to-face visitors and enquiries Review again for impact Cash office payments Review again for impact Telephone switchboard Review again for impact Concessionary travel scheme Review again for impact
Revenues & Benefits Division
Tax collection, billing and recovery Review again for impact
Vale Contract Services
Refuse collection, including re-cycling and trade waste
Review again for impact
Housing maintenance Review again for impact
Inspections of taxis Review again for impact
Property & Operational Services
Refuse collection Review again for impact
Planning
Town Centre Management Review again for impact
Marketing and Information
Communications generally
Consultation, including “hard to reach” strategy
Review again for impact Review again for impact
Administration Division
Electoral registration Review again for impact
Elections Review again for impact
Financial Services
Investigation of fraud Review again for impact
Legal Division
Provision of legal advice to client departments and Members
Review again for impact
Preparing legal documents Review again for impact
Prosecution policy Review again for impact
Carrying out statutory monitoring officer function Review again for impact
Information Technology Division
Support to internal IT users Review again for impact
