Race Equality Policies by Lifelong Learning UK

RACE EQUALITY GUIDANCE FOR FURTHER EDUCATION COLLEGES

Race Equality Policies

Introduction to the resource Purpose This is one in a series of booklets which provide guidance for further education colleges in managing their approach to race equality. This guidance will help providers to meet the requirements of current race equality legislation and offer advice on how to ensure that race equality features appropriately within the new single equality context. Providers can also use this guidance to ensure that race equality issues are addressed as part of their

The guidance in these booklets has a primary focus on race equality and workforce issues. However, the guidance may also be useful when considering approaches to equality matters in general and may be applied to learner issues.

Timeframe

Summary

At the time of writing, colleges are subject to the Race Relations Act 1976 (as amended) and as such this is the main legislative focus of the booklets.

Points to remember when developing race equality policies:

The guidance also takes a transitional approach so that providers can use it to prepare for the likely changes towards single equality legislation, which is likely to be implemented in 2010-2011.

Who are the booklets for? These documents contain useful information for governing bodies and corporations, senior management, provider staff, trade union members and officers, marketing and communications professionals, human resources professionals and equality and diversity practitioners.

This series of booklets include: The Race Equality Duty: what it means for further education colleges Race Equality Policies Race Equality and Equality Impact Assessments Publishing Race Equality Information

general approach to single equality. More specific guidance for third sector, work based learning and adult and community learning providers will be produced at a later date.

• A college’s race equality policy and action plan should represent its ‘standard’ on race equality, having been tailored to suit its particular context. • The forthcoming changes in equalities legislation means that colleges will be required to produce single equality schemes, rather than separate equalities documents. Colleges can start this process by using this guidance to ensure that essential information is included for race equality when producing single equality schemes. • The college’s equality and diversity group (see Race Equality Duty booklet) needs to play a key part in creating both the plan and policy/single equality scheme. • Communications are a good way of ensuring understanding of what race equality and other equality issues mean for colleges, their staff, learners and the community. • The race equality policy/single equality schemes and plan need to be living documents – make sure that its actions are taken forward. • Regular reviews are important to make sure that milestones under the policy/scheme and plan have been met. This booklet is divided into the following sections: Section One: • What is a race equality policy? Background • What about single equality schemes? • What is an action plan? Section Two: • Understanding the law. Plan • Knowing where you are and where you need to be. Section Three: • Ensure the policy and action plan are comprehensive. Implement • Identify clear roles and responsibilities. Section Four: • Implementation of the policy and plan are key. Progress • Review progress on a regular basis.

Section One:

Background to race equality policies What is a race equality policy? A race equality policy is a document that outlines an organisation’s commitment to meeting the statutory requirements of the Race Equality Duty. The policy should be a fundamental part of any provider’s strategic and operational plans. The Commission for Black Staff in Further Education define that an effective race equality policy should: • act as an engine for development and implementation setting out the practical measures being taken to achieve race equality • have clear targets and projected outcomes

The Equality and Human Rights Commission’s Statutory Code of Practice for Race Equality states that a race equality policy and action plan should represent the college’s responsibilities and commitments. It also states that the policy should: a. be part of the institution’s yearly plan b. give details of how the institution will put the policy into practice, monitor it, and assess how effective it is c. provide a framework for building race equality into other relevant policies, and into all relevant areas of the institution’s activities

• be regularly reviewed.

d. clearly define roles and responsibilities so that people know what is expected of them

Source: Commission for Black Staff in Further Education, Good Practice Guide One1

e. explain clearly what the institution will do if the policy is not followed

A race equality policy should therefore represent the following:

f. set out the institution’s arrangements for publishing, each year, its race equality policy and the results of the monitoring and assessments it carries out to meet the Duty.

1. The college’s standard on race equality – this means that it should clearly outline what race equality means for the college, its staff, learners and the community it serves.

Source: Commission for Racial Equality (2002) Statutory Code of Practice on Race Equality. Paragraph 6.26.

2. A ‘living’ document – this means that the policy should be outcome-focused, identifying particular activities that will help the college achieve positive change. It should also be reviewed on a regular basis to check actual progress against aims. These two elements should be at the heart of any race equality policy and will be explored further in this booklet.

Commission for Black Staff in Further Education, 2002. Good Practice Guide, Book Two.

What about single equality schemes? Colleges are currently legally required to produce disability equality and gender equality schemes as well as race equality policies. The forthcoming changes in legislation will mean that colleges are required to produce a single equality scheme, rather than separate policies or schemes for each equality area. Colleges can prepare for these changes by using this guidance to produce a single equality scheme.

What is an action plan? Attached to the policy or single equality scheme should be an action plan to explain how the policy or scheme will be implemented, identifying what will be done, how it will be done, who will lead on the activity and relevant timescales. Together these documents provide an organisational framework in which providers can pursue more than just anti-racism strategies, but help ensure a progressive environment of inclusivity for people of different racial backgrounds. A race equality policy can be tailored to the unique circumstances of a college, from the initial statement of values and vision to the ways it will implement activities in relation to race equality.

The policy, scheme and action plan should be drafted in consultation with the collegeâ&#x20AC;&#x2122;s equality and diversity group, who will provide valuable input on the equality matters relevant to staff and learners, as well as overarching corporate issues for the college. The group can also help to ensure that the policy and plan will be understood and actioned appropriately. When it comes to drafting the policy, scheme or action plan, the group should also be able to provide opportunities for wider consultation across the college community, so that feedback can be included as appropriate.

Section Two:

Planning race equality policies This section will look at: • the importance of senior-level commitment • the essential foundation work that should be completed to produce an effective race equality policy, or to incorporate race equality issues within a single equality scheme.

The importance of senior-level commitment A crucial factor in the success of any effort to promote race equality is having a visible commitment from senior leaders and managers. This demonstration of leadership will also help to guard the college against legal challenge on the grounds of racial discrimination, where liability will rest with the college’s governing body or equivalent. Governing bodies and senior management therefore need to show their commitment to the race equality policy both within the college and externally. This will demonstrate that race equality is core to the organisation’s culture and practices.

When developing the policy and action plan the equality and diversity group should consider the following questions: 1. Where are we now in relation to meeting the statutory requirements of the Duty? 2. Where do we want to be by the next review of the policy, scheme and action plan? 3. Have we considered the potential links between the Race Equality Duty and other equalities areas?

Essential foundation work Understanding the law The race equality policy and action plan enable a college or provider to show their response and compliance with the Race Equality Duty. The documents outline how the college will seek to eliminate unlawful racial discrimination, promote equality of opportunity and good relations between people of different racial groups. To support providers in this work, specific duties have been outlined that can guide providers towards achieving their aims and meeting the requirements of the Duty. The policy and action plan should therefore reflect the way in which the legislation is structured (see The Race Equality Duty booklet for more information).

The race equality policy and action plan enable a college or provider to show their response and compliance with the Race Equality Duty. 5

1. Where are we now: assessing progress to date The first question highlights the need to assess what progress has been made in race equality matters to date, with the aim of identifying any lessons that have been learned from past experiences. This should include a critical assessment of the extent to which any equality goals or targets have been achieved and whether past targets were overly ambitious. The first race equality policy and action plan should be thought of as a starting point which will be built on and improved in the future. Learning from past achievements as well as failures should not be seen as self-criticism, but as a necessary part of the race equality process.

2. Where do we want to be: areas needing action This question looks to the future for race equality within the organisation, specifically at establishing the aims and mission, building on any work to date and setting college priorities. All areas of the policy, scheme and action plan should consider how race equality can be brought into alignment with the mainstream policies of the organisation. The race equality policy, single equality scheme and action plan should be positioned within the collegeâ&#x20AC;&#x2122;s overall strategic plan and be developed through standard planning and decision-making processes.

TIP: A race equality impact assessment could be introduced in mainstream assessment procedures. When monitoring race equality it might be sensible to consider existing monitoring systems, such as management information systems.

3. Have we considered the links between the Race Equality Duty and other equalities areas? It is important that colleges consider the connections between different equality areas and the concept of multiple discrimination (i.e. issues affecting people or groups in relation to more than one equality area). In relation to race equality, this means considering how a personâ&#x20AC;&#x2122;s gender identity, disability, religion or belief, sexual orientation and age can affect them in the workplace. An example of this could be a form of discrimination in the recruitment process, where applications from African-Caribbean men are considered differently to those from AfricanCaribbean women or white men. The move towards single equality legislation will potentially make it easier to tackle this kind of multiple discrimination, by allowing for a more sophisticated level of analysis.

Section Three:

Implementing race equality policies This section focuses on developing the content of the race equality policy and looks at the following areas: • • • • • • • •

race equality policies, ethos and strategy accessibility single equality schemes content responsibilities how the specific duties should be used other relevant areas drafting the action plan.

Race equality policies, ethos and strategy

Accessibility

A policy provides the opportunity for colleges to show that they have taken a considered approach to race equality within their organisation. However, the policy, scheme or action plan will only be effective if it is regarded as a living document and is aligned with the college’s overall vision and mission.

Accessibility of the policy and plan is another important consideration for two reasons.

Policies and plans allow providers to address what race equality means in their unique environment. Establishing the vision and values of the organisation at the beginning of the policy is an effective way of doing this, and it can help set the tone of the policy or scheme and action plan. The policy must also reflect the college’s strategic objectives to ensure that equality becomes a part of mainstream business planning and aligns with the strategic direction of the organisation. Any agreed race equality objectives should be geared towards achieving specific outcomes that will add visible value.

1. The tone of the document: This should be clear and accessible so that the provider’s position and plans are easily understood, giving the policy more force as a mechanism of positive change. 2. The different readers of the document: The policy and plan should also be made clear and accessible to all audiences. This may be achieved by producing different versions for different audiences, for example, producing a shortened version with a summary of the main points. This would enable those seeking to simply understand the vision for race equality within the organisation to do so easily, while others can scrutinise the detail of the full document to understand specific policies and processes. (Further information on this topic is provided in the booklet, Publishing Race Equality Information.)

EXAMPLE: Barnfield College has produced a concise race equality policy and action plan which links its work to a local context. A commitment to equality of opportunity and the elimination of unlawful discrimination is also embedded within the college charter. http://www.barnfield.ac.uk/files/Race-EqualityPolicy-and-Action-Plan-0507.pdf

An effective single equality approach can also enable providers to consider the connections and overlaps between equality areas, such as gender and race, in relation to their local environment.

Single Equality Schemes There is currently no legal requirement for providers to produce a comprehensive single equality scheme. However, it is likely that colleges will be required to produce and maintain single equality schemes in the future due to forthcoming changes to equalities legislation. Some organisations have already decided to produce single equality schemes in preparation for this legislation. This should not impact on meeting the statutory requirements of the Race Equality Duty, providing that the race equality elements of the scheme can be clearly identified. An effective single equality approach can also enable providers to consider the connections and overlaps between equality areas, such as gender and race, in relation to their local environment.

EXAMPLE: Ponteland Community Middle School has produced a Single Equality and Diversity Policy, which brings all six equality strands together in one document and also refers to work that will be done in relation to areas such as community cohesion. The policy includes an accessibility plan that will help ensure everyone has access to and understands the policy. http://www.culturaldiversity.org.uk/docs/134.doc

EXAMPLE: West Nottinghamshire College, which has recently been awarded star status as part of the Best Companies accreditation scheme, has published an Equality and Diversity Scheme for 2007-2010. Approved by both recognised trade unions and the corporation board, the scheme clearly identifies the ways in which the national, local and college context shapes its approach to equality and diversity. It also outlines how effective equality and diversity approaches can help the college in meeting its vision as an employer of choice and how the college infrastructure can help facilitate effective implementation. The scheme includes specific sections in relation to the six mainstream equality areas (i.e. disability, race, gender, age, religion or belief and sexuality) and outlines particular actions for each of those areas. The scheme is also supplemented with an action plan, an outline of college functions and their relevance to race, gender and disability, and information on the equality impact assessment process. http://www.westnotts.ac.uk/

CASE STUDY: Subject: Developing a Single Equality Scheme Organisation: Highbury College Link: http://www.lluk.org/raceequality.htm

Content of a policy If a college decides to produce a single equality scheme it must also ensure that relevant race equality issues are included in the document. The Equality and Human Rights Commission recommends that the race equality policy: “should reflect the character and circumstances of the institution, and deal with the main areas that are relevant to promoting equality of opportunity and good race relations, and tackling racial discrimination. These areas may include: a. the institution’s values b. curriculum, teaching and learning (including language and cultural needs) c. assessment d. racial harassment and bullying e. the institution’s management and governing body

Race equality policies and single equality schemes should be action and outcome-focused, showing not only the relevant areas that the provider intends to consider, but also the action that will be taken to make sure work in these areas is progressed. Addressing these areas in an outcome-focused way will enable colleges to produce policies that can be effectively linked to other college priorities and used for action-planning. Any cross-references should be included in other college policies that are relevant to promoting race equality.

TIP: This guidance emphasises the need to focus on outcomes and recommends that the following areas are considered when planning a policy: • What are the issues, and how is the college going to address them? • How will the college know when aims have been achieved?

f. admissions, access and participation

Institutional values and college context

g. student support and guidance

It is useful to identify the vision, mission and values of the provider, the context (demographic and historical) and the link with race equality. There are many ways to combine institutional values with the requirements of the Duty in strategic and operational plans. This could include promoting a dynamic learning environment, contributing to regional economic regeneration and community cohesion or developing an inclusive working environment.

h. behaviour and discipline i. partnerships and community links j. staff recruitment, training and career development.”2 Included in these areas is the requirement that the policy should set out: • arrangements for building race equality into the college’s processes for policy planning and development (i.e. mainstreaming) • arrangements for putting the policy into practice, including a timetable for regular reviews of the policy (i.e. implementation) • arrangements for monitoring and assessing progress towards meeting any race equality targets and the Duty (i.e. review).

EXAMPLE: Recent research by the Learning and Skills Improvement Service into race equality and succession planning found that providers with a strong inclusive ethos were more likely to retain and motivate black and minority ethnic staff. http://www.centreforexcellence.org.uk/?Page=no menuReadNews&id=424

Commission for Racial Equality, (now the Equality and Human Rights Commission) 2002. Statutory Code of Practice on Race Equality. paragraph 6.27

The policy should also summarise the background of the college in terms of its history, functions, locality and the main issues faced in relation to the Race Equality Duty.

TIP: Establishing the link between race equality and institutional values helps to identify the college’s ‘standard’ on race equality. It can assist in identifying the challenges and opportunities ahead and support a rationale for future action. The Association of Colleges and trade unions’ joint agreement on race equality highlights that the policy provides an opportunity to demonstrate explicit commitment to race equality in the working environment. If this is done properly, it can enhance the reputation of a college to both staff and learners. http://www.ucu.org.uk/media/docs/l/3/fejointag_ra ceq_08.doc Questions to consider in this section: • What are the links between the Race Equality Duty and your mission and objectives? • Do staff, learners, the community and contractors know about your standard on race equality as expressed through your policy? • How will these issues be expressed in a single equality scheme?

Identification of the Race Equality Duty Outlining the legal responsibilities the college has under the Duty can help the reader to understand why new race equality policies and action plans are being implemented. Diagrams (such as the one provided in the Race Equality Duty guidance) can help outline the requirements in a clear way. Training is also a good way to ensure that staff understand how the legal requirements relate to them in terms of their responsibilities and rights as a member of the college community. (Refer to Commission for Black Staff in Further Education – Good Practice Guidance Book Three3). Targeted communications can be used to make the policy or scheme available to diverse audiences within the college community and is a good way of creating awareness and understanding for the college’s ‘standard’ on race equality (see the booklet Publishing Race Equality Information for more details).

version of its race equality policy for staff and learners during inductions and admissions. The shortened version included relevant information on race equality, such as the rights and responsibilities for staff and learners, what the college would be doing to promote race equality, and contact details for further information.

Responsibilities The policy or scheme should define the roles and responsibilities of individuals and departments within the college. Alongside this must be a clear statement of what will happen if these responsibilities are not met and if the policy is not followed. In this way, the policy can help the college to progress and make a visible contribution to achieving positive change. The Association of Colleges and Trade Unions’ model agreement on race equality gives a useful breakdown of the kinds of responsibilities that exist within colleges, which can be adapted to suit the specific college community. This agreement covers governor, manager and employee responsibilities and provides a useful guide to setting targeted requirements4. Defining the role and responsibilities of leaders is particularly important and is linked to the need for every employee and learner to understand their own rights and responsibilities under the legislation. Relationships and responsibilities with external contractors should also be defined. Contractors are not subject to the same Duty as the colleges themselves, but colleges are responsible for any activities carried out by contractors working on their behalf. It is therefore important that colleges take race equality matters into consideration when establishing agreements with contractors, and build this into the standard procurement process.

Using the specific duties As mentioned, the specific duties can be used to help providers in meeting the statutory requirements of the Duty and the policy or scheme should identify how these specific duties will be met.

Conducting Equality Impact Assessments in Higher Education, 2007, Equality Challenge Unit, http://www.ecu.ac.uk/publications/files/conducting-equality-impact-assessments.pdf/view 4 Association of Colleges, 2008 Joint Agreement on Race Equality [online]. Available from: http://www.ucu.org.uk/media/docs/l/3/fejointag_raceq_08.doc 3

EXAMPLE: A college produced a shortened

Monitoring The Equality and Human Rights Commission identifies the following points to include in any monitoring activity5. 1. Ethnic monitoring – consider how to: • collect ethnic data to monitor the admission and progress of students and the recruitment and professional development of staff • use the data to inform planning and decision making and to set targets • use the ethnic data provided by external sector organisations. 2. Planning and mainstreaming race equality – consider how to: • build race equality targets within wider strategic plans • consider equality intersections. 3. Other general areas of monitoring to consider: • is the correct data being collected • can monitoring be improved to capture specific ethnic groups (such as gypsies and travellers, eastern European nationals) and how can this inform strategy and planning • how can monitoring in other areas, such as religion or belief, be used to identify and address the needs of different religious groups who also fall under race equality legislation, i.e. Sikhs, Jews, Roma. 4. Two important monitoring elements that the policy or scheme should include are: • data collection – the methods for monitoring both staff recruitment and progression, and learner admissions and progression • data analysis and next steps – how and for what this information will be used.

Clear process and timelines should be identified for the above, including the specific equality areas and categories that will be monitored.

Impact assessment Impact assessments are an important way of bringing race equality into the mainstream policies and practice of the organisation. Assessments can also contribute to monitoring activity in that quantitative data can be used to identify gaps in representation and/or inequality of treatment. This can be used as a basis for further analysis in the impact assessment process. The Equality and Human Rights Commission has identified the following key areas that should be included in the policy6. 1. Planning and mainstreaming race equality – consider how to: • build questions on the implications for race equality into the processes for developing and planning policy • use assessments and consultations to decide whether any action is needed. 2. Assessing and reviewing policies – consider how to: • review, monitor and assess all policies or strategies to see how effective they are in tackling unlawful racial discrimination, promoting equal opportunities and good race relations • consult with staff, students and other interested parties • build race equality questions into your self assessment and evaluation frameworks • use the results of reviews and assessments to inform all your planning and decision making.

Commission for Racial Equality (now the Equality and Human Rights Commission) 2002. The duty to promote race equality: a guide for further and higher education institutions [online]. Available to access from: http://83.137.212.42/sitearchive/cre/downloads/duty_fehe.pdf 6 Ibid 5

The model agreement on race equality by the Association of Colleges and Trade Unions’ has a clear outline of requirements in this area: “The impact assessment process must be clearly articulated, preferably providing links to relevant guidance on how to follow the process. This guidance should include an outline of the high, medium and low priorities for assessment following screening exercises, how different areas will be assessed (including methods to consult and engage with staff) and the action that will be taken in the case of positive, neutral or negative impact. This approach should also be reflected in the race equality action plan, with timescales and responsibilities clearly set out. Further information is provided in the impact assessment guidance.”7

TIP: In order for the impact assessment to be effective, it is imperative that consultation takes place with black and minority ethnic learners and staff, as they are the people most likely to be affected by policies. Since the race equality policy is evidence of a provider’s compliance with the Duty, these consultation arrangements must be articulated in the policy. This should include the consultation methods that are used and the groups who are consulted with, which will demonstrate the level of inclusivity. Details about any consultation that has taken place previously will assist in developing an action plan for future consultation activity, including the methodology and timing and how people will be made aware of the assessment process. Further information on consultation mechanisms can be found in the booklet, Race Equality and Equality Impact Assessments.

Publishing and promoting The Equality and Human Rights Commission has identified the following areas that should be included in the policy8: When publishing and promoting the policy, you should include: • how and where the policy will be available • who will get a copy of the policy • whether the policy will be translated or made available in alternative formats (for example, audio, larger print, Braille etc) • promoting the policy as evidence of good practice in audits, inspections, and reviews of your performance. When publishing the results of monitoring and assessments, you should include: • how you will publish the results of your assessments and monitoring • how you will make the information available to different groups in your institution • how you will make sure that any information you publish cannot be used to identify individuals. The model agreement on race equality produced by The Association of Colleges and Trade Unions’ provides further comprehensive guidance for publishing and communicating the policy and action plan both internally and externally using a variety of communication channels9.

http://www.ucu.org.uk/media/docs/l/3/fejointag_raceq_08.doc Commission for Racial Equality (now the Equality and Human Rights Commission), 2002 The duty to promote race equality: a guide for further and higher education institutions [online]. Available from: http://83.137.212.42/sitearchive/cre/downloads/duty_fehe.pdf 9 Association of Colleges, 2008. Joint Agreement on Race Equality [online]. Available from: http://www.ucu.org.uk/media/docs/l/3/fejointag_raceq_08.doc 7 8

In summary, a good policy or scheme should clearly articulate the rationale behind impact assessment. This will include the criteria used to prioritise its functions as well as the criteria used to actually assess the impact. The rationale behind impact assessment should include links to the context, challenges, aims and objectives of the provider.

Publishing the policy or scheme is both a necessity and an opportunity for colleges, as it enables them to promote their commitment to race equality and to publicly celebrate their achievements.

• A definitions section or glossary will help to ensure that people are aware of discriminatory acts under the law and will aid clarity and understanding of the policy.

The legal requirements for publishing the policy or scheme are straightforward. They must be available as a published document in the public domain, and should include details of the arrangements for publishing the results of both impact assessments and monitoring. These results must be published annually and the plans must include the timetable, methods and target audiences for publication, together with a reference to any previous publication of results. Above all, race equality policies and action plans are public documents and it is essential that they are easy to find and freely available at no cost to the reader.

• Breaches of the policy. As the policy represents the college’s ‘standard’ on race equality, it should also clearly identify what will happen when that standard is breached at any level. This may include the college’s standard complaints procedures and also allow for confidential whistle-blowing. Mechanisms with trade unions and students’ unions need to reflect an efficient, sensitive and effective way of considering referrals.

Beyond these statutory requirements the published policy provides an opportunity for colleges to promote its policies both internally and externally. This could include making the policy available on the provider website, including the results of monitoring and assessment in annual reports or newsletters and sending detailed results directly to those involved in the consultations. Most importantly, making a public announcement about the publication of the policy, scheme and action plan makes a clear statement about the provider’s commitment to race equality.

Other relevant areas The policy or scheme should also include information on the following areas: • Relevant training interventions, both in relation to specific training on race equality and also other equality strands. This should cover developmental training, such as continuing professional development, and should be included in the college’s training plan. Training interventions can then be monitored and assessed for effectiveness. • Review mechanisms for the policy, i.e. how often the policy and plan will be reviewed (and by whom), how the college plans to consult internally and externally and how it will use the feedback.

The Stephen Lawrence Inquiry Report defined a racist incident as “any incident which is perceived to be racist by the victim or by any other person”10. The rationale behind this definition is to ensure that a complaints system can take full account of any racist dimension to an incident. Similar provisions should be included in relation to harassment or bullying within the college environment.

EXAMPLE: Bristol University has outlined a clear institutional position on racist incidents, harassment and bullying, including relevant procedures to be followed under the University’s student and staff disciplinary procedures. This approach is also supported by the University’s Dignity at Work and Study Policy. http://www.bris.ac.uk/staff/handbook/legal/racee quality.html

EXAMPLE: UNISON has launched a crosssector campaign called ‘Challenging Racism at Work’, which consists of a package of training and guidance resources to help its members on race equality issues: http://www.unison.org.uk/challengingracism/

10 Lord Macpherson of Cluny, 1999. The Stephen Lawrence Inquiry, Report into and Inquiry [online]. Available from: http://www.archive.official-documents.co.uk/document/cm42/4262/4262.htm

• Procurement. It is important that the policy or scheme includes a commitment to buying goods and services from contractors that comply with race equality legislation. This is because the college will remain liable for any activities carried out by a contractor on its behalf. Depending on the size of the contract, this can include ensuring that the company signs up to the college’s race equality policy or has one of its own, that it is able to show that it has taken steps to train its staff or looking at its track record on commitment to race equality issues. Equality Bill update: At the time of writing it is proposed that public authorities (including colleges) include equality considerations during key parts of public procurement processes, for example to consider incorporating equalityrelated contract conditions where they relate to the performance of the contract and are proportionate.

EXAMPLE: Nottingham University has produced a useful procurement checklist which is available to access online from: http://www.nottingham.ac.uk/procurement/policy_ files/equality.php • Community links. Working with external constituencies and local community groups is an essential part of meeting the Duty, namely through promoting good relations between people of different racial groups. This can also help colleges in better reflecting the communities they serve.

• Links with the local community. The policy should outline how the college works and will work with local people and organisations to help promote race equality.

EXAMPLE: A member of senior management at the Grimsby Institute of Further and Higher Education is an active member of the Communities Together for Racial Justice forum, made up of public sector bodies and members of minority groups from the North East Lincolnshire area. Its aim is to promote equality of opportunity and good relations between people of different racial groups within the community, both generally and by the advancement of public education in the causes and effects of discrimination. By having a close relationship with this group, the Institute has co-ordinated and been involved in the following activities: • Providing transport for local community members from a variety of faith and culture groups to travel to Bradford to attend the Pillars of Light exhibition. This allowed the group to explore different aspects of Islamic cultures and heritage. • As part of celebration events the Institute contributed to a successful street market and performance of dance and music with local youth groups from a variety of cultures. This will be repeated during autumn of this year. • The Institute’s diversity co-ordinator was involved in compiling a diversity booklet for the organisation based on the backgrounds of local minority ethnic groups.

• Arrangements for reviewing the policy. The policy is a document that can only be in effect for a limited period of time, due to the changing context that colleges operate within and the work that the college has undertaken on race equality. The policy therefore needs to be updated on a three-yearly basis to reflect these changes.

delivery of actions. This defines that objectives should be specific, measurable, achievable, realistic and timed. This will help make the plan realistic and achievable, which in turn will help the overarching vision for the race equality policy be achievable.

Date of the policy

• the action that will be taken to achieve it

The policy and action plan will need to be approved by the governing body or corporation, then signed and dated (usually by the principal or chief executive) once the documents have been approved.

• who will take the lead and supporting roles in carrying out that action

Action plan The action plan will accompany the policy or scheme and show the college’s status in relation to race equality issues. The plan can use the above headings as a framework to identify where the college wants to be, how it will achieve these targets, who will lead on the action and when it will be completed. This process will also outline the objectives of the organisation, from which specific aims can be extracted and addressed in the action plan. This will help to ensure that the action plan not only reflects institutional priorities with regard to race equality, but also that previous experience is considered and built upon.

For each race equality target that the college seeks to achieve, the following should be specified:

• the required resources and where they will come from • a timescale for completion • how success will be measured – the associated performance indicator. By adopting this approach, it is possible to group related targets under the following broader headings: • area • objective • activity • who • when • desired outcome and performance indicator.

Establishing the ‘how’

Consultation

It is imperative that the action plan is a practical and constructive document that contributes to tangible outcomes.

Colleges should consider the best way for staff, learners and the community to provide feedback on the policy or scheme as it is being developed, either through the representatives of the equality and diversity group or other committees such as a college’s joint negotiating committee with the trade unions, community forums and the students’ union.

The plan should include specific tasks which are clearly defined to ensure that they can be monitored successfully. Tasks need to be accompanied by measures of success that can actually be measured, for example developing outcome targets such as increasing levels of representation of black staff at senior levels of the college. Actions should all have realistic but defined timescales for completion. This will make it possible for the next review of the policy and plan to provide a clear measure of progress and make recommendations for any adjustments accordingly. In order to be a usable document, the action plan should clearly define the roles and responsibilities of those responsible for implementing the existing and new actions. The plan should identify specific projects and the suggested resources and funding routes to deliver them. It is useful to use the ‘SMART’ mnemonic when setting targets for the

It is imperative that the action plan is a practical and constructive document that contributes to tangible outcomes. 15

Section Four:

Progression of race equality policies This section will look at: • who should review the policy, scheme and action plan • how the policy/scheme and action plan should be reviewed • how to effect any changes. As previously mentioned, the policy, scheme and plan should be living documents against which progress can be reviewed on a regular basis. If drafted correctly, both documents can provide a useful benchmark against which colleges can monitor progress on a regular level. The ideal locus for reviewing the policy, scheme and plan should be the equality and diversity group. It is a good idea for senior management to request information from those individuals working on the policy, scheme or plan on behalf of the group prior to any meeting. This will enable the group to check what progress has been made or conversely look at the reasons why progress has not been made if this is the case.

TIP: Be realistic about progress. If the college has not managed to action as much as anticipated then outline the reasons behind this, how it will improve the situation and recommend changes to the policy, scheme and action plan.

Any changes to the policy, scheme and plan should be approved by the college’s governing body and senior management. The equality and diversity group should also think about how the college can communicate significant changes and achievements. Establishing an annual review process so that progress can be charted and changes made is vital to the success of the documents. This can also be built in to the college’s standard monitoring and target setting mechanisms.

RW10/09/3570200910.038

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