Race Equality and Equality Impact Assessments by Lifelong Learning UK

RACE EQUALITY GUIDANCE FOR FURTHER EDUCATION COLLEGES

Race Equality and Equality Impact Assessments

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 undertaking race equality and equality impact assessments: • Try to incorporate equality impact assessments as part of the college’s review process. • Equality impact assessments should be staggered – prioritise policies according to their relevance to race equality and other equality strands. • Equality impact assessments should not be conducted by just one person – this is a collective activity that should ideally be coordinated by the college’s equality and diversity group. • Consult both internally and externally where appropriate – offset disillusionment with previous consultation exercises by providing feedback to those who have contributed information, showing how they have helped to bring about positive change. • Make sure that decisions have been reached as a result of a clear rationale. Be sure to communicate good work and share practice both internally and externally.

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.

This booklet is divided into the following sections: Section One: • What are equality impact assessments? Background • Why are they relevant to further education colleges? • How can equality impact assessments be used to improve performance in relation to race equality? • Relevant race equality considerations when conducting an equality impact assessment. • How to conduct impact assessments. Section Two: • Organise for impact assessment determining an Plan appropriate assessment timeline. • Relevant questions to consider. • Establishing a realistic timetable. Section Three: • Screening. Implement • Collection of data and information. • Analysis of data and information. • Dealing with impact. Section Four: • Reporting key findings. Progress • Actioning recommendations. • Publishing and communications.

Section One: Background

What are equality impact assessments? Equality impact assessments are a way of evaluating the effectiveness of organisational performance in relation to equalities. They aim to identify the impact, or likely impact, of a policy, service or function upon diverse groups of people and can also help explore ways to promote equality. The legal requirement to undertake impact assessments to measure adverse impact on the grounds of race (specifically in relation to staff and students of different racial groups) was introduced with the Race Relations (Amendment) Act of 2000. The scope of impact assessments has since widened with the introduction of new legislation and statutory duties, which currently cover disability and gender. These will be widened to include age, sexual orientation and religion or belief with the introduction of the Equality Bill in 2010. For an impact assessment to be effective, staff should have a good understanding of the issues affecting diverse groups of people, together with a general knowledge of discrimination and an ability to identify instances of direct and indirect discrimination along with the measures to address them. Equality and diversity training will be required for staff involved with equality impact assessments.

Why are equality impact assessments relevant to further education colleges? Equality impact assessments are not only a legal requirement, but they also support self assessment and the Framework for Excellence1 as a quality review mechanism and allows for an enhanced and mainstreamed approach. Assessing organisational performance in this way is critical, particularly as prospective staff and service users will expect organisations to demonstrate a commitment to tackling inequality.

Carrying out equality impact assessments will help colleges to develop: • increased participation rates of staff and learners, resulting in increased transparency in policy and service development • policies that are informed by qualitative and quantitative information and data derived from diverse groups • more effective and accessible programmes for both staff and learners • improved decision making processes • a proactive approach to the promotion of equality • a process to identify and tackle any institutional discrimination • ways to avoid harmful policies that have a negative effect on staff, learners and the community • a natural link between race equality, community cohesion and social inclusion. The above factors are particularly important given the changing environment for further education providers, in which the world-class skills agenda and self-regulation is a long term aim. The impact assessment process acts as a means for continued improvement and evidence based policy making, which in turn will contribute to achieving world-class skills in an increasingly competitive sector. A college of any size can, and should, use equality impact assessments as a way of measuring the impact of their policies, services or functions on staff and service users. It is increasingly the case that colleges are using a general equality impact assessment process to cover all equality strands, for example race, disability and gender. This can be an effective way of combining the current legal requirements and is a recommended approach. If a college chooses to adopt a general equalities impact assessment process, it is important to use the impact assessment process as a detailed

Department for Business, Innovation and Skills and Department for Children, Schools and Families, The Framework for Excellence [online]. Available from: http://ffe.lsc.gov.uk/.

analysis to understand more fully the issues within race equality and other equality strands, rather than producing a generic and anodyne assessment. The remainder of this booklet will refer to equality impact assessments with a particular focus on relevant race equality issues.

How can equality impact assessments be used to improve performance in relation to race equality? Equality impact assessments provide an opportunity to review any policies, services and functions for issues related to equalities and performance. Good practice would be to prioritise impact assessments for those policies, services and functions that are highly relevant to race equality and other equality strands to be assessed first. Those policies, services and functions with medium or lower relevance to equality should be assessed afterwards. Ideally, the whole process should take place within a threeyearly cycle. The equality impact assessment is complementary to both the self assessment process and the Framework for Excellence. In both of these processes performance is measured across all service provision, tackling poor performance, raising standards and skills, increasing efficiency and being closer to learners and employers. The thread of equality and diversity runs through all these areas of performance. Recent research has outlined the particular issues experienced by black and minority ethnic staff. This includes findings of the Learning and Skills Improvement Service’s report on succession planning within further education and the Annual Workforce Diversity Profile published by Lifelong Learning UK. In order for colleges to tackle the issues raised by these pieces of research, it is important that both qualitative and quantitative data and information is used to inform the impact assessment process, which in turn can facilitate positive change at the local level. The combination of data and information provided through an impact assessment process will allow for an objective

review of progress. Questions in relation to race matters should be asked of the policy, service or function in order to identify areas for improvement. This may include: • considering the accessibility of services and communications • measuring equality of opportunity in recruitment and selection • looking at whether the workforce is diverse enough to provide breadth of knowledge, experience or skill and is representative of the communities and learners it serves • considering whether poor performance is linked to low morale, unchallenged prejudice or discrimination on the grounds of race. Whilst the Disability Equality and Gender Equality Duties make explicit reference to consultation and engagement requirements, it is recommended that colleges include appropriate consultation mechanisms for race equality within the equalities impact assessment process. This approach will allow colleges to undertake an effective assessment approach and help their preparations towards the forthcoming Equality Bill, where a combined approach will be required. The Commission for Black Staff in Further Education made the following recommendation in relation to embedding race equality in the human resource function: Assessing the effectiveness of employmentrelated policies and procedures is a key function of human resource departments. Close analysis of data and embedding key questions into the policy review process is a way of mainstreaming race equality and reduces the scope for discriminatory employment practices. Source: Commission for Black Staff in Further Education, Good Practice Guidance, Book One

An alternative approach to equality impact assessments There are strong parallels between the impact assessment process and the changes an organisation will make to their services to accommodate the needs of their clients or service users. For example, opening late on certain days and offering products in different formats, languages and types. Equality impact assessments can help providers to identify improvements like this in many ways, for example by enhancing its external reputation, improving morale amongst staff and learners and strengthening links with employers and the local community. As mentioned above, a form of impact assessment already exists within further education through the self assessment report process. Self assessment stresses the need for insightful and challenging self-evaluation as part of the assessment process. Dr Christine Rose has considered this further, and recommended that equality impact assessments are used in conjunction with the self assessment process to meet colleges’ goals and development needs. Source: Quality and Equality: a match made in heaven? Dr Christine Rose http://readingroom.lsc.gov.uk/lsc/EastofEngland /From_quality_to_equality.pdf

TIP: Bear in mind that impact assessments are a means of meeting the Race Equality Duty and therefore should be outcome focused. Ask the following questions for this purpose: • What are the issues, and how is the college going to address them? • How will the college know when aims have been achieved?

Relevant race equality considerations when conducting an equality impact assessment It is important to note findings from relevant research, such as Lifelong Learning UK’s Annual Workforce Diversity Profile (which analyses Staff Individualised Record data in relation to ethnicity, disability, gender and age) identified a slow rate of increase in the representation of black and minority ethnic staff at different grades. The Learning and Skills Improvement Service’s report on succession planning and race equality in the further education sector considered qualitative information and data within its research. Based on survey responses, focus group sessions and one-to-one interviews with black and minority ethnic groups, the research produced the following findings: • Many black and minority ethnic staff:

A similarly robust process of review can be used for corporate and workforce issues. For example, consideration of workforce issues can be enhanced by the use of The National Centre for Languages (CILT) National Occupational Standards on Intercultural Working2, which clearly outline the need to consider intercultural working in areas from planning workforce requirements to implementing workforce procedures. As part of this, impact assessment provides a vital tool to meet the standard through better understanding of the areas where the college is succeeding and those that require further work.

• feel ignored, believe that they are seen as a threat by others, have low morale and wish to leave the sector • believe they are trapped beneath resistant glass ceilings and fail to win promotion on merit • believe that promotion is achieved through informal networking from which they are excluded • do not have confidence in using formal complaints procedures to resolve instances of racial discrimination in college.

The National Centre for Languages (CILT), 2008. National Occupational Standards on Intercultural Working [online]. Available from: http://cms.cilt.org.uk/Cilt/home/standards_and_qualifications/uk_occupational_standards/intercultural_skills.aspx.

• Approximately only one quarter of black and minority ethnic respondents rated their appraisal as effective3. Both these pieces of research indicate a need for further action at national, regional and local levels. It is particularly important that issues such as staff representation, general morale in the workplace and satisfaction with career progression are analysed further within the college equality impact assessment process as a means of meeting the Race Equality Duty.

How to organise impact assessments Remember that equality impact assessments are essentially a reviewing process to make sure that all elements of the college offer are fit for purpose. The following diagram outlines the main stages for the impact assessment process, using the ‘PIP’ mnemonic as outlined in the Race Equality Duty guidance – plan, implement and progress. The following stages of the impact assessment process provide a basic framework, which should be contextualised within the provider setting.

PLAN

Mapping and screening

Reporting, action and review promotion

Gathering data

> Consultation and engagement

Mitigation, change or promotion

IMPLEMENT

PROGRESS

Preliminary organisation

Analysis

Both current and proposed policies should be included as part of the impact assessment process. With regard to the latter, it is important that assessment is built into the policy formation process. Each of these stages is explored in the following sections.

Learning and Skills Improvement Service, 2009. Succession planning and race equality in the further education sector.

Section Two:

Planning equality impact assessments This section will look at: • including the equality and diversity group in determining an appropriate assessment timeline • relevant questions to consider • establishing a realistic timetable.

Effective planning is an important part of the impact assessment process and can help to ensure that assessments are conducted in a constructive way. The college’s equality and diversity group will need to plan the process and consider the following:

• a quality assurance process that acts as a ‘critical friend’ to maintain a consistent output of high quality assessments at the screening and full assessment stages (this can also be used to inform future training needs)

• what are the relevant functions, policies, practices, provisions and criterion within the college

• how the results of assessments are publicised internally and externally, e.g. progress reports

• how data is gathered, e.g. management information systems

• action planning and resource implications

• who will carry out the assessments and what are their training needs • how information will be screened

• aligning actions within core business planning work plans • how changes are reviewed and progress is monitored.

• effective consultation mechanisms for staff, learners and the local community • how information is analysed and assessed • what happens as a result of analysis, e.g. recommendations to senior management and next steps

On a wider level, the group should also consider the factors below. Mainstreaming – How the impact assessment process can be mainstreamed within existing review practices, allowing the college to provide a tailored review process. Senior–level championing – Visible leadership and commitment is a vital part of the impact assessment process and can help to ensure that the process is understood and taken forward by the provider organisation as a whole. Embed the equalities impact assessment process in relation to proposed policies – Making sure that those responsible for developing policies within the college incorporate equalities considerations in a systematic way, helping to ensure that it is able to meet legal requirements.

Training or briefings for impact assessments can go a long way towards facilitating understanding of the process and can help build capacity within the organisation. 8

The type of training required – Training or briefings for impact assessments can go a long way towards facilitating understanding of the process and can help build capacity within the organisation. Think about the type of training and briefings that may be appropriate to particular staff members. For example, will they be required to carry out impact assessments or provide information? The Commission for Black Staff in Further Education have produced their Good Practice Guide on Training (Book Three), which provides a comprehensive outline of appropriate interventions. Developing a ‘consultation finder’ – This is a system that will allow staff to access the outcomes of past consultations and find out about any future consultations. This will create a consolidated approach to consultations, reducing the likelihood of consultation fatigue. Consideration of these areas will allow the equality and diversity group to develop a broad timetable for the main stages of the impact assessment process.

EXAMPLE: The Open University devised a comprehensive and realistic timetable for its race equality impact assessment process that took place between 2006/7. The timetable, covering both unit and central level activity at the university, can be found at: http://www.open.ac.uk/equality-diversity/

Section Three:

Implementing equality impact assessments This section will look at: • • • •

mapping and screening gathering data consultation and engagement analysing data and information.

Screening allows colleges to prioritise the policies that are of high relevance to race equality and equalities generally, which can then be focused on as a more immediate priority in the reviewing process.

Mapping Mapping precedes the screening process and can help colleges look at how policies fit into the general framework. It is recommended that colleges undertake an indicative mapping exercise (conducted through the equality and diversity group) to outline their functions, within which policies, services and practices can be located. Once the mapping exercise is completed, it is possible to move onto the screening stage.

Unwritten practices, criterion and provisions These areas are more difficult to assess than written or codified policies, but progress in identifying them can be made in the following ways: • Good and reflective training interventions can help identify the college standard on race equality, and show what will and won’t be tolerated. This can help weed out discriminatory practice. • Engage with staff groups and trade unions to see if there are any practices etc at the college that people are uncomfortable with. • Complaints – it may be possible to look at the number of complaints that include a race dimension to them. This will help highlight any particular practices etc that may discriminate.

Screening This process should be undertaken by those who have best knowledge of the policy, and therefore should be driven by heads of departments and policy makers. The following questions should be considered: • What are the objectives of this policy? • Who created the policy? • Who is the policy aimed at? • How is progress towards outcomes measured? • Could people of diverse racial groups have different needs in relation to the policy or service? • Does the policy help promote good race relations? • Does this contradict the college’s race equality policy/single equality scheme or objectives? Reports on the screening process should also outline the type of relevant and reputable information used to answer the above questions. Screening policies allow the provider to prioritise areas into high, medium and low relevance categories, and then establish timelines for action dependent on their priority level. If a policy, service or function is seen as highly relevant to race equality, it should be prioritised for a full impact assessment, followed by those that have medium or low relevance. If the initial screening has identified a potential impact, either positive or negative, then a full equality impact assessment should be carried out.

The equality and diversity group should check any completed screenings to make sure that the right information has been considered and that the completed screenings are published.

Data can be either:

The screening process therefore acts as a filter for providers to identify and focus on the most important issues for each equality area.

b. Qualitative – data that reveals people’s perceptions, such as their views of a service, analysis of complaints and/or outcomes of focus groups discussions.

The Equality Challenge Unit has published examples of the screening process in its guidance for higher education4.

TIP: Remember that policies may differ in their

a. Quantitative – such as population figures, the number of users, census data, indices of multiple deprivation data, workforce data, etc.

Looking at monitoring data within the impact assessment process will also allow colleges to consider the following:

‘equality relevance’ to different equality strands.

• How effective have past targets/positive action been? Allowing colleges to better understand what works at the local level.

EXAMPLE: West Nottinghamshire College is

• What are the larger contextual issues for the provider? Issues around location or history can impact on colleges, for example past conflicts between different groups in the local area.

developing an equality impact assessment process that covers race, gender and disability. They have produced college-specific guidance, identified the functions and policies that are of relevance to each respective equality strand and conducted an initial screening of policies and procedures in relation to human resources, corporate and learner issues. www.wnc.ac.uk

Carrying out a full impact assessment Gathering data

• How are internal or external provisions being used? Monitoring data can identify how services are being used and more importantly who is not using them. An important way of considering these questions in more detail is through effective consultation and engagement with staff. This is looked at in the next section.

There is a natural link between monitoring activities and impact assessment exercises, in that the data gathered from monitoring can be analysed in an impact assessment. This link makes it possible for the impact assessment to identify causal factors behind gaps in representation and/or disparity of treatment.

Conducting Equality Impact Assessments in Higher Education, 2007, Equality Challenge Unit, http://www.ecu.ac.uk/publications/files/conducting-equality-impact-assessments.pdf/view

Consultation and engagement Consultation and engagement is the central stage of any equalities impact assessment process. It goes beyond simply informing people of what will happen, but instead actively involves them in shaping a way forward. It also allows colleges to gain a clearer insight to what is happening with staff and learners ‘on the ground’. In relation to staff development, consultation can play a vital role in helping with career progression and up/reskilling. Echoing the recommendations of the Commission for Black Staff in Further Education, the Learning and Skills Improvement Service’s Equality and Diversity Competencies5 recommends that providers impact assess human resources policies, procedures, plans and strategies in consultation with learners and staff from diverse backgrounds.

EXAMPLE: Worcestershire County Council has developed a consultation toolkit that can be adapted and used by colleges. When deciding on the most appropriate consultation method, think about the following: • Will this method elicit a high level of response from black and minority ethnic staff and the wider community? • Are there sufficient resources to undertake this consultation method? • How will the college use the consultation findings in the impact assessment process? • How will the college provide feedback to those who participated in this consultation process? • Will this be a regular form of consultation or a one-off? • How will feedback be provided to senior management and the governing body (or equivalent)? When deciding on the most appropriate consultation method, colleges should consult with the recognised trade unions and wider community, ideally through the equality and diversity group. http://www.worcestershire.gov.uk/home/wcc-contoolkit-stage5-a

There are a range of possible approaches to consultation and engagement, and the success of different methods often depends on the local context and how well people understand the college’s standard on race equality and current activities. Colleges can build trust in the impact assessment process by selecting consultation exercises that provide a comfortable environment for staff, learners and/or the wider community. This may include facilitated focus groups or liaising with informal networks through trade unions and team meetings. Colleges can also consider other innovative approaches to help elicit feedback.

CASE STUDY: Subject: The Black Staff Group Organisation: West Thames College Link: http://www.lluk.org/raceequality.htm

TIPS: • Make sure that there are adequate resources available for consultation exercises. • Be clear as to why consultation exercises are taking place and make it meaningful, as consultation fatigue is common among many equality groups. • It is important to remember that equality groups are not homogenous – colleges may therefore need to consult more than one group in each equality group. • Use innovative ways to raise awareness and attract participation, for example the use of payslips, intranet, staff notices, newsletters and use of a senior-level champion can all help. • Make sure consultations take place at times that are appropriate for people to attend. For example, it may be better to run staff events outside of working hours, or with clear assurance that staff will not be penalised if they attend a session during working hours. • Ensure adherence to the provisions of the Data Protection Act – people need to know that their responses will be anonymous. • Both internal and external consultations are a good way of promoting community cohesion, by facilitating discussion and improved understanding between people from diverse backgrounds.

Learning and Skills Improvement Service, 2008. Equality and Diversity Competencies [online]. Available from: http://www.centreforexcellence.org.uk/UsersDoc/EqualityDiversityCompetencies_May08.pdf

Analysis or assessing impact Quantitative data will provide a certain level of evidence for an impact assessment, which can be refined by gathering qualitative data through consultation exercises. Once consultation has taken place, the equality and diversity group will be in a

Key message one

position to assess whether the information gathered is complete. To aid their decision, the equality and diversity group can develop a framework to identify the key issues that were consulted upon, and then the main findings from those consulted with. The following template can be used for this purpose:

Key message two

Key message three

Key message four

Key message five

Issue People consulted Date Area one Area two Area three

Areas one, two and three can include the main findings that have emerged from monitoring data, whilst the key messages can include the feedback gained from consultation.

Once quantitative and qualitative data has been gathered a full impact assessment can be conducted. In particular, the following areas should be considered:

This type of analysis will allow colleges to extract the key messages from consultation exercises, and give a clearer idea of the impact of a policy.

• who the policy is aimed at and the rationale for this

• the aims and objectives of the policy • the information that has been considered (both internal and external sources) • consultation and engagement methods • identification of any gaps in data or information • impact of the policy, be it positive, neutral or negative, including unlawful discrimination and the ways in which it helps meet the three strands of the Race Equality Duty.

The Commission for Black Staff in Further Education recommends that both positive and negative impact is looked at and that the quality of information and data used features as part of the overall assessment process. The Equality and Human Rights Commission identifies the following areas that should be considered when analysing any differences for staff, learners and the community6: a. Is the institution helping all staff and students to achieve as much as they can, and get as much as they can from what is provided for them? b. How does the institution explain the differences between groups of students in terms of teaching and learning, drop-out rates, student progression and achievement, assessment, access to learning resources, support and guidance, and curricular and other opportunities? c. Are these explanations justified? Can they be justified on non-racial grounds (for example, English language difficulties)?

g. Do the policy’s aims lead to action to deal with any unjustifiable differences that are identified? h. Is the action appropriate and effective? Are there any unexpected results? If so, how are they being handled? i. What changes does the institution need to make to policies, relevant policy aims, and related targets and strategies? The Commission for Black Staff in Further Education recommends that both positive and negative impact is looked at and that the quality of information and data used features as part of the overall assessment process7. To this end, it provided the following key questions to help in this area: • Could this policy or procedure affect some racial groups differently?

d. How does the institution explain the differences between groups of staff in terms of grade and position, type of contract, career development, training, and other opportunities?

• What does available statistical data tell us?

e. Are these explanations justified? Can they be justified on non-racial grounds (for example, a change in institution-wide policy on permanent recruitment)?

• Have we taken account of all relevant and available information, for example:

f. What is the institution doing to: (i) raise achievement levels and tackle race inequalities when recruiting staff, and in students’ performance and progress; (ii) promote race equality and harmony, both inside the institution and in the wider community; and (iii)prevent, or deal with, racism?

• Does the policy or procedure promote good race relations?

• staff surveys or sampling activities • feedback from staff consultations and focus groups • reports from responsible managers and their teams • the views of the Equality Forum and other key committees. • Does the policy or procedure need to be revised in light of this assessment?

Commission for Racial Equality (now Equality and Human Rights Commission), 2002. Statutory Code of Practice for Race Equality. Paragraph 6.32. 7 Commission for Black Staff in Further Education, 2002. Good Practice Guide, Book Two. 6

Section Four:

Progressing equality impact assessments This section will look at: • • • •

dealing with positive, neutral or negative impact reporting and action-planning taking recommendations forward publishing results.

Dealing with positive, neutral and negative impact

In choosing the most appropriate action the following questions may be useful8:

Following assessment, it is important to explore the potential outcomes and next steps as a result of the exercise.

• Are there any alternative measures or mitigation that could be taken to achieve the desired aim without the identified adverse impact?

Negative impact

• What are the consequences for staff and learners if the college does not take the action that best meets the requirements of the Duty? What are the implications for the college?

The person conducting the assessment should consider the following action if a negative impact is found: 1. Changes to the policy or the way in which it is implemented. 2. Adopting a different policy that aims for the same objectives as the original policy, but avoids the negative impact. 3. In a few cases negative impact can be justified if it relates to a legitimate positive action or health and safety issue. This is a very narrow option and the college will need to show that the policy is important on grounds independently of the discrimination, and that it has tried to find non-discriminatory alternatives to the policy without success.

• Is it justified to proceed with an indirectly discriminatory policy? Can the college argue credibly that the policy aims and objectives were essential and justifiable to the organisation and that the means it employed in achieving them were appropriate and necessary? These questions will help the person conducting the impact assessment in choosing the appropriate action to take in the case of negative impact.

Positive impact If positive impact is found then consideration should be given to how this impact can be widely promoted and used in other equality strands. The policy in question should be reviewed again as part of the college’s review cycle.

Adapted from: http://www.scotland.gov.uk/Publications/2005/02/20687/52424

Once the senior management team or governing body has approved any recommendations, the equality and diversity group should oversee subsequent activity to ensure that changes are implemented.

Neutral impact

Taking recommended actions forward

In the event of a neutral impact, consideration should be given to ways in which more positive impact can be encouraged. The policy in question should then be reviewed again as part of the college’s review cycle.

Once the senior management team or governing body has approved any recommendations, the equality and diversity group should oversee subsequent activity to ensure that changes are implemented.

Reporting and action-planning

As well as providing feedback to those who participated in the impact assessment process, it would also be useful for the college to invite feedback from the same people so that improvements can be made to future assessment exercises.

All impact assessment exercises should be reported back to the equality and diversity group, who in turn can look at the information assessed, make recommendations and report to the senior management team and governing body (or equivalent). Whilst general reports can follow the college’s usual reporting procedures, reports on impact assessment should include the following information:

The equality and diversity group should also consider when the next timetable of review takes place and put measures in place to improve future assessment processes.

• policies reviewed • summary of assessment process (e.g. information used) • result • recommendations.

Publishing results The Equality and Human Rights Commission recommends that the following information is included when publishing information on completed impact assessments9: • a description and explanation of the policy, putting it in its wider policy and legislative context • a brief explanation of how the policy was assessed for its effects on different racial groups, with clear references to the information and research used as a benchmark • a brief description of the consultation methods used, and a summary of the overall findings

• an explanation of whether and how the adopted policy differs from the original one • a statement of the plans for monitoring the policy when it is put into effect. The Association of Colleges and Trade Unions’ model agreement on race equality recommends that colleges include relevant information on race equality work within their annual reports10.

EXAMPLE: The Open University has published a progress report on its race equality impact assessments for both internal and external audiences: http://www.open.ac.uk/equalitydiversity/

• the conclusions reached through the assessment and consultation as to the likely effects of the policy on meeting each part of the Race Equality Duty

Adapted from: http://83.137.212.42/sitearchive/cre/duty/reia/how_stage2.html#publish 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. 9

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