Making Equality Impact Assessments more than just a tick box exercise
Change in culture and mindset required to put issues of equality at the heart of decision-making
Our report found that many public bodies are not using Equality Impact Assessments to their full potential, especially in terms of promoting equality and cohesion.
Equality Impact Assessment (EIA) is an important part of the approach to tackling discrimination and promoting equality in Wales. EIAs help public services meet their legal responsibilities under the Public Sector Equality Duty to avoid discrimination in the decisions they make and to promote equality of opportunity and cohesion. Done well, EIAs are more than a means to show compliance and avoid legal challenges. They support the growth of a mind-set and culture that put issues of equality at the heart of policy development and decision-making.
We found examples of good practice in some areas of the process but our report sets out some key areas for improvement. There is a need for Welsh Government to be clear about which type of policies and practices must be assessed, as well as the arrangements for assessing the impact of collaborative policies and practices.
We also found that EIAs are sometimes carried out very late in the process of developing a policy. Many EIAs recognised that a policy or practice may impact on a group generally but did not show how it would impact people’s lives in practice. None of the EIAs we looked at considered how different protected characteristics intersect. EIAs rarely consider how multiple different decisions combine to impact on specific groups. Also, public services need to better engage and involve people with protected characteristics and monitor the actual impact on people once a policy or change is rolled out.
Discrimination and inequality continue to impact on the quality of life and life chances of people in Wales. Black Lives Matter, MeToo and other social movements have brought issues of discrimination and inequality to the forefront of public policy and debate.
Our work shows that within individual public bodies there are good examples of aspects of the process of conducting an Equality Impact Assessment. However, what we have seen and heard tells us that public bodies in Wales tend to use their EIAs defensively. Too often, they seem like a tick box exercise to show that the body has thought about equality issues in case of challenge, rather than focussing on opportunities to promote equality and cohesion.
My recommendations call on the Welsh Government to work with partners to improve and update the overall approach to EIAs; and call on public bodies to respond to review their own approaches, I also expect those involved in scrutiny to use this report to challenge their organisation’s overall approach to EIAs and the quality of individual EIAs used to inform decisions.