Walsall Council's experience of cumulative Equality Impact Assessment

An example of how a council significantly improved its equality impact assessment processes.

Community action

Walsall is situated at the heart of the Black Country. A conurbation of former villages and district suburbs, Walsall’s ethnic and faith diversity started to change in the 1950s and 1960s with South Asian and Caribbean workers settling here. Today, the borough has a population of 281,293 and is proud of its multi faith heritage including Muslim, Sikh and Hindu faiths active in the town.

Like other parts of the Black Country, Walsall population has experienced poor health outcomes from the industrial era and health inequalities agenda continues to be a priority with 1 in 10 adults affected by limited long-term illness. The socio-economic indicators suggest a geographical divide with poverty and educational levels well below national average particularly in the North and South. Young people perceive lack of opportunities and this leads to disproportionate representation of older people in the make-up of the town.

According to the last census 1 in 4 residents have other than White British ethnic heritage and this is expected to increase with the Brexit settlement scheme. Certain national indicators, for example those collected by DfE and MHCLG, show structural segregation and therefore a significant investment was made into Walsall for All programme funded by MHCLG with emphasis on social mixing and improving equalities. The programme is delivered through voluntary sector and recently featured as best practice in the Social Cohesion Investment Report 2020.

Better understanding of how budgetary decisions impact on different people with protected characteristics

Equality impact assessments (EqIAs) are required for all Walsall Council decisions identified in the forward plan prepared by Democratic services. There are two types of decisions, depending what group of people they potentially impact on:

a/ the decisions that change/create a new policy, procedure or service affecting customers/residents require an EqIA for policy, procedure and service.

 b) the decisions that bring about internal organisation changes and impact on staff require an EqIA for organisational change.

In the Corporate Budget Plan 2016/17 to 2019/20 and Treasury Management and Investment Strategy 2017/18 savings worth of £17,136,724 were identified across many areas of business all to be implemented in a parallel manner and sequentially. This has raised concern about ability of the existing EqIA process affecting the residents to recognise multiple impacts as some can potentially be affected by withdrawal or changes of not just one but many decisions at the same time.

Previous equality impact assessments had already showed us that there are certain gaps in the way proposals are consulted on. For example Gypsies, Travellers and Roma and LGBT community were rarely referred to in the consultation and engagement part of the assessment. Similarly, the grid analysing the effects of the proposals on each protected characteristic lacked in-depth data that would enable us to do appropriate risk analysis.

We therefore decided to provide better guidance for each of the 9 protected characteristics and developed an ABCD risk analysis system, with A being equivalent to ‘no change required’ to D meaning ‘stop and rethink the proposal’.

Another change occurred with the way consultation and engagement linked to each proposal were gathered. With the help of Consultation Institute, we trained Consultation Champions in carrying out better consultations following the Gunning Principles across different protected characteristics, recognising the value of understanding equality impact. This meant that when it came to conducting the analysis, more in-depth data were available relating to different groups of people affected.

And finally, from 2017, it became a requirement of the formal budget decision process to carry out a cumulative impact assessment analysis before the budget was approved by elected members.

Value of understanding cumulative impact

A cumulative impact report provides additional insight from examining all the EqIAs from a given time period, focusing on those groups of people (with protected characteristics) that may be affected multiple times, by different policies and service changes. This is particularly important in annual budget cycles when organisations seek to find efficiencies and savings. So for example, impact of all the proposals on women would be viewed together (libraries, children centres, pregnancy services, domestic violence), rather than only through lenses of an individual proposal, for example, on domestic violence.

In the Corporate Budget Plan 2016/17 to 2019/20 and Treasury Management and Investment Strategy 2017/18 out of the 80 key decisions, 33 required in-depth Equality Impact Assessments for Policies, Procedure and Services. The highest risk proposals were then further audited by the Consultation Champions and Equality Advisors and a cumulative report was prepared, shared with proposal owners and elected members responsible for decisions.

Space for challenge and discussion

One of the most important changes from the new cumulative impact process was the way information was gathered and presented to decision-makers, creating additional space for discussion and challenge.

Consultation Champions and Equality advisors ensured that engagement with residents with protected characteristics took place early on and that emerging analysis was shared, identifying thus the areas of vulnerability, e.g. multiple loss of provision in a geographical area, taking into account demographic profile of that area or specific group (e.g. people with disabilities or Gypsies, Travellers and Roma).

Stop and rethink – longer term view

The discussions generated a longer-term view of a problem area and sometimes resulted in a ‘stop and rethink’ outcome. This was viewed as an opportunity to carry out more consultation, review the strategy or work closer with partners to resolve potential issues jointly.

Some of the budgetary proposals affecting children and under 5 year olds certainly belonged to this category. For example, children with special educational needs were affected by the proposed changes of the ‘home to school transport’ and ‘short breaks’. As a result of in-depth consultations with the parents, carers and schools, it was decided not to go ahead with these proposals in the first year and review provision for these children more strategically. This has led to a number of new strategies being developed, including the Walsall Right for Children Inclusion Strategy, Walsall SEN Strategy and Walsall Accessibility Strategy.

Other proposals that were also likely to impact on children and under 5 year olds included changes to children centres, libraries’ redesign, public health weight management and reductions in voluntary sector. As a result of the cumulative impact analysis, public health prioritised weight management services for children and closer working was established between schools, libraries and voluntary sector.

Similarly, a number of smaller proposals would have impacted negatively on older people access to outdoor activities, on younger people receiving counselling, vulnerable people receiving welfare advice as well as those participating in community cohesion activity. It was decided that these proposals would not go ahead and instead new funding would be sought to mitigate potential gaps. This has materialised in the Council partnering with voluntary sector and obtaining funding from MHCLG’s Integration Area and Controlling Migration programmes.

New projects were created from these new funding streams focusing of cohesion and tackling inequalities. For example, we invested in research and better understanding of the needs of Gypsy, Travellers and Roma. Based on this piece of work, we have now set up a new community partnership whose role will be to also provide temporary accommodation for Gypsy and Traveller families.

Better mitigation plans

Several budget proposals identified by Adult Social Care would have impacted on Youth and Young Adults (including those with disabilities) and therefore more mitigation had to be included into EqIA action plans as a result of the cumulative report. The actions included changes to the Housing and Care 21 contracts as well as criteria for the Hardship fund.

Additionally, multiple proposals identified by Adult Social Care and Neighbourhood services would have impacted negatively on older and/or disabled residents. As a result of the cumulative impact, certain eligibility criteria, for example for large bin collections, mobile library service, Hardship Fund and other support services were amended to mitigate the impact and provide alternative support.

The cumulative impact showed that reduction of public health funding would impact significantly on all protected groups. Changes in drug and alcohol, stop smoking, weight management, and domestic violence services presented multiple risks often falling on similar demographics and geographical areas. It was decided that reductions in these services required more in-depth mitigation plans to reduce adverse impact on all the protected characteristics. This has been referenced in the Health Inequalities Action Plan and Joint Strategic Needs Assessment. Some new sources of funding had been identified with partner organisation to continue prioritising the most vulnerable groups

Next steps and future improvements
  • Many findings from the cumulative impact report fed into the 2019/20 Proud Programme – a transformational modernisation of the council which allows for more holistic approach to improving customer experience, employee satisfaction, and service efficiency and effectiveness
  • Cabinet reporting process was also changed as a result. Having observed the impact of Covid-19 on health inequalities we recognise more focus will be required in this area in future. We included the ‘health and wellbeing implications section’ as well as the ‘reducing inequality’ section into our Cabinet reporting already and guidance is currently being prepared to take into account the Health Equity Assessment Tool (HEAT). 
  • Managers responsible for identifying efficiencies have a better understanding of other areas of business and partner agencies, nudging them to seek solutions together.
  • Some EqIA action plans are monitored centrally based on risk, and there is a greater opportunity to exchange good practice between different sectors. 
  • Some EqIAs already resulted in seeking new funding for example MHCLG funded the Integrated Communities Programme and Walsall for All Board are currently seeking to extend the programme for another 3 years.