Appendix 2 - Revised Equalities Impact Assessment (EQIA)
Perth and Kinross Council · 22 January 2025
Back to Housing and Social Wellbeing Committee — 22 January 2025 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
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1 Appendix 2 Equalities Impact Assessment Perth and Kinross Council – Access to Housing (Via Common Housing Register or Homelessness Application) Equalities Impact Assessment Updated – April 2024 Title of policy Access to Housing (Via Common Housing Register or Homelessness Application) Date of initial screening Date of Review 16 October 2018 18 April 2024 Organisation wide/service specific Service specific New/existing policy Development of existing policy Lead officer Service Manager Housing Name of officer (s) involved in review Service Manager Housing Team Leader Access Housing Options Co-ordinator Equalities Team Leader Who will be involved in delivering the policy? Housing Options Officers Support Officers Private Sector Officers Housing Officers Partner agencies – Caledonia Housing Association, Hillcrest Housing Association, Fairfield Housing Association and Kingdom Housing Association How they have been involved in EQIA? Team meetings Delayed Office Opening Sessions Equality and Diversity Training Common Allocations Policy Review Group
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2 Appendix 2 Equalities Impact Assessment EQIA – Access to Housing (Via Common Housing Register or Homelessness Application) Definitions Common Housing Register – this is a single point of access, application pathway to social-rented housing provided by Perth and Kinross Council, Caledonia Housing Association, Hillcrest Housing Association and Kingdom Housing Association. Common Allocations Policy – this is a common, shared policy which underpins the Common Housing Register and is fully adopted by all member landlords. Homelessness Application – as a local authority, Perth and Kinross Council has a statutory duty to investigate if it suspects someone may be homeless. The process involves a homelessness presentation and an assessment of the circumstances to establish if someone is homeless. Perth and Kinross Council’s response to homelessness is called ‘Home First’ and is outlined in our Rapid Rehousing Transition Plan. Aims and Objectives The aim of the Common Allocations Policy (CAP) is to meet housing need fairly and help secure accommodation for households in the greatest housing need. For people who are homeless or threatened with homelessness, Home First aims to prevent homelessness occurring and to ensure that where homelessness cannot be prevented, homeless households move directly into settled accommodation, avoiding the stigma, cost and uncertainty of temporary accommodation and homelessness. The CAP and Home First response to homelessness operate in tandem and share a number of key principles and objectives. The development and delivery of these Access to Housing Pathways is consistent with the Human Rights PANEL principles; • Participation – these polices have been developed in partnership and service-users and other stakeholder have been consulted and involved in policy development and review. Service-users have ongoing opportunities to provide feedback on the services they receive and we use this information to continuously improve. • Accountability – we are accountable for the decisions we make and have a range of measures in place to ensure accuracy, fairness and consistency in our approach. • Non-discrimination and Equality – we have adopted a key principle of respecting diversity and promoting equality in everything we do. • Empowerment – people using our Access to Housing Pathways are given housing options advice and assistance and are empowered to make informed decisions. • Legality – we are committed to operating in line with legislation and statutory guidance that is relevant to the Access to Housing pathways.
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3 Appendix 2 Equalities Impact Assessment The Common Allocations Policy is based on 6 key principles – we will; 1. Apply our policy consistently: this means that we apply our policy to every applicant and property we allocate, wherever that property is, whoever the applicant is, and whoever allocates it or processes the application. 2. Be clear about what we do and when we will do things. We will be clear about how we do things and explain why we do things wherever we can. 3. Be open and honest with you and talk clearly and directly about your housing options. We will be clear about what we can and cannot do to help you. 4. Follow what the law and guidance says we must do and what the law allows us to do. Wherever we can, we will follow what guidance recommends we should do. 5. Respect diversity and promoting equality in everything we do. No one will be treated unfairly because of race, colour, ethnic or national origin, language, religion, belief, age, gender, sexual orientation, marital status, family circumstances, employment status, physical ability, mental health or neurodiversity. 6. Use all the information we receive about you and everyone you apply with in line with the law and hold that information securely Common Allocations Policy Objectives 1. Responding quickly to people in acute and urgent housing need and giving the right priority to people who are in most need of housing. This includes specific groups identified in legislation to which we must give reasonable preference. These groups are; • People who are homeless or threatened with homelessness (including those at risk of harassment or abuse) • People who are living in unsatisfactory housing conditions with unmet housing needs • Social housing tenants who are under-occupying their homes Practice elements: We provide advice, assistance and support based on our service standards and in line with legislation. Equality aspects: We provide the service in various locations with an emergency response available 24 hours a day and 365 days of the year. We use language line, provide translated documents, offer same sex officers, disability friendly services and we learn and improve from complaints and appeals. Our staff are well trained and we have a range of monitoring and quality assurance processes in place. Equality aspects: No immediate impact
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4 Appendix 2 Equalities Impact Assessment 2. Providing suitable (affordable and sustainable) housing solutions to households with an assessed housing need Practice elements: We ensure appropriate offers of housing are made taking account of needs/preferences (ground floor, house type, and location) – in line with information from lead services and agencies. Our Housing Occupational Therapist provides advice on property suitability for people with physical disabilities and where adaptations are required. When needed, we provide housing support to help people sustain their tenancies and where appropriate, this includes referrals to ensure tenant’s income is maximized. To ensure we make the best possible allocation, we may seek advice and assistance from partner agencies including Social Work, Police Scotland, Health services including the Medical Advisory Service. Equality aspects: No immediate impact 3. Delivering services that meet legal and statutory responsibilities and corporate outcomes of Best Value Practice elements: Policies and procedures Staff training – supervision, DOO sessions Equalities Operational Group Keeping up to date with legislation and new guidance Monitoring and quality assurance (customer feedback, complaints and appeals) Performance Framework and monitoring Scottish Housing Regulator (SHR) – Charter Return Statistical Returns to the Scottish Government Tenant scrutiny feedback and inspections Case Law Equality aspects: No immediate impact 4. Creating a service culture which upholds the rights of applicants to the Common Housing Register in meeting their needs Practice elements: As above and consult/engage with homeless people (Homeless Voice) Customer and Stakeholder Surveys Peer Audits – Tayside, Fife & Central Housing Options Hub Equality aspects: No immediate impact Home First Objectives 5. Resolving homelessness more quickly and/or preventing homelessness from occurring Practice elements: We make advice, assistance and support available in a range of accessible formats in the places where people need to access them. We deliver services in line with our service standard and in line with legislation.
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5 Appendix 2 Equalities Impact Assessment Equality aspects: We provide the above in various locations on a 24/7 basis, we use language line or other interpretations services, provide translated documents, same sex officers, disability friendly services, learning from complaints and appeals. Our staff are well trained, and our managers undertake monitoring and quality assurance of the services we provide. 6. Reducing the time that homeless households spend in TA Practice elements: At the point this EQIA was reviewed, the average length of stay in temporary accommodation was around 68 days. This is closely linked with the average overall duration of homelessness which was around 80 days at the point of review. Every case is monitored and reviewed on an individual basis. Equality aspects: Individual needs would be met (or assessed on a case by case basis) for those with protected characteristics No immediate impact – variances in length of stay would be caused by households’ needs rather than on equality grounds eg. A household that requires a large property or an area with limited turnover. 7. a) Achieving greater parity between mainstream and TA costs for households Practice elements: The rent charges for temporary accommodation is the same as the rent charged for mainstream accommodation. There are no service charges for temporary accommodation other than for utility costs such as heating and lighting. Equality aspects: No immediate impact as Temporary Accommodation rent is the same as for mainstream properties. All accommodation meets our ‘lettable standard’ and there are higher standards in place for temporary accommodation. b) Identifying ways to reduce rehousing costs for homeless households Practice elements: Providing advice, assistance, and support – financial assessment and budget planning Provision of furniture packs, budgeting, signposting to relevant projects and initiatives (Re-use schemes, Community Care Grants etc) Support plan/liaise with landlord Equality aspects: No immediate impact 8. Providing suitable (affordable and sustainable) housing solutions to homeless households and those facing homelessness Practice elements: Ensure appropriate offers are made taking account of needs/preferences (ground floor, house type and location) – in line with Code of Guidance and homeless legislation Provision of Housing Support if required. Seek advice and assistance from relevant partner agencies such as; Social Work, Police Scotland, Heath Services, Scottish Welfare Fund
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6 Appendix 2 Equalities Impact Assessment Equality aspects: No immediate impact 9. Delivering services that meet legal and statutory responsibilities and corporate outcomes of Best Value Practice elements: Policy and procedures Staff training – supervision, DOO sessions Equalities operation group Keeping up to date with legislation and new guidance Monitoring and quality assurance (customer feedback, complaints, and appeals) Performance Framework and monitoring Equality aspects: No immediate impact 10. Creating a service culture which upholds the rights of homeless people in meeting their needs Practice elements: As above and consult/engage with homeless people (Homeless Voice) Surveys Peer Audits Equality aspects: No immediate impact
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7 Appendix 2 Equalities Impact Assessment EQIA – understanding protected characteristics and the impacts of the Common Allocations Policy What characteristics do households have that will use the Access to Housing pathways? How is this evidenced? Are there any ways in which the Access to Housing Pathways will specifically support households with these characteristics? Age (young or old) • Performance Management Framework • Quality Assurance audits • Training Plans • Returns to Scottish Government and SHR • Support Plans Younger people – greater focus on transitional support and tenancy skills to enhance tenancy sustainment Older people – prioritisation of hospital delayed discharge cases. Provision of aids & adaptations where required. Disability As above Assessment, medical support needs, links to OT/aids and adaptations/extensions. Independent Living Pathway and specialist Panel have been established. This is a partnership with key services and agencies – Housing, Social Work, Health, Commissioning etc. Independent Living Panel creates understanding of current and future demand and informs the new build programme (wet rooms, barrier free) and use of assistive technology Gender reassignment As above Quick move to permanent accommodation may be beneficial, avoiding the need to spend time in temporary accommodation and hostel accommodation. Any placement or offer of housing would be on a person-centred approach that fully considers the needs and wants of the individual Pregnancy and maternity As above Offer accommodation before baby born, also offer 2 bed to single and couple to support future circumstances. Close partnership working with Family Nurse Partnership and Health & Social Care.
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8 Appendix 2 Equalities Impact Assessment Race As above Any placement or offer of housing would be on a person centred approach that fully considers the needs and wants of the individual. Would also seek support and assistance from Safer Communities Team. We will carry out Environmental Risk Assessments where appropriate to minimise the risk of racially motivated crimes. We recognise that significant events such as the Coronavirus pandemic and Brexit may have a disproportionate impact on non-UK citizens, and we have worked in partnership with partners and 3rd sector organisations to minimise the impact where possible. Perth & Kinross Council has made a commitment to support people seeking sanctuary. This includes people who are supported by formal Resettlement Schemes and those seeking asylum and receiving a positive decision on their claim. We work in partnership with a broad range of partners to ensure that people seeking sanctuary have access to sustainable accommodation and community integration support. Religion or belief As above Would consider location of place of worship and any link in with Safer Communities Team in terms of neighbourhood issues re crimes and issues – Environmental Risk Assessment. Sex As above Closure of commissioned 3rd sector provision which catered for male/female and had some shared rooms. Service standards, same sex officers Sexual orientation As above Staff training/awareness, participation in equalities operational group Support assessments
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9 Appendix 2 Equalities Impact Assessment What impacts might the Access to Housing Pathways have on advancing equality of opportunity? Positive impact Negative impact No impact Age (young or old) Young – Support Plans, Housing education programme, Youth Boost and Future Builders programmes commissioned from and/or delivered in partnership with The Rock Trust Old – delayed discharge, assessment processes Disability Accessible properties or those with pre-existing adaptations targeted to applicants with disabilities. Independent Living Pathway provides access to mainstream and supported accommodation for people with physical and learning disabilities. Gender reassignment Quick move to permanent accommodation may be beneficial, avoiding the need to spend time in temporary accommodation. Pregnancy and maternity Offer accommodation before baby born, also offer 2 bed to single and couple to support future circumstances Race Our Common Allocations Policy has been developed in line with Equalities legislation and is designed to be non- discriminatory. Religion or belief No impact identified Sex No impact identified Sexual orientation No impact identified
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10 Appendix 2 Equalities Impact Assessment What impacts might the Access to Housing Pathways have on eliminating unlawful discrimination? Positive impact Negative impact No impact Age (young or old) Our Common Allocations Policy has been developed in line with Equalities legislation and is designed to be non- discriminatory. Home First consistently applies these principles. Disability As above Gender reassignment As above Pregnancy and maternity As above Race As above Religion or belief As above Sex As above Sexual orientation As above
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11 Appendix 2 Equalities Impact Assessment What impacts might the Access to Housing Pathways have in fostering good relations between people who share a protected characteristic and those who do not? Positive impact Negative impact No impact Age (young or old) Social media Homeless Voice Twitter/Facebook Older persons’ forum Disability Newsletter Office layout Staff training Gender reassignment Staff training Pregnancy and maternity No impact identified Race Translation and interpretation services Religion or belief No impact identified Sex Same sex officer Service standards Sexual orientation Equalities group
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12 Appendix 2 Equalities Impact Assessment EQIA – monitoring Methods for monitoring policy Performance Management Framework, Business Management Implementation Plan, National Statistical Data ARC return & returns to Scottish Government Feedback from stakeholders, customers and applicants Complaints and appeals Forums and feedback/surveys and questionnaires Who will be involved in monitoring the policy? Housing Options and Support Team including Senior Officer, Co-ordinator and Team Leader The Scottish Government The Scottish Housing Regulator Housing Management Team Customers and stakeholders Partner Organisations Ways in which data will be used to develop the policy. Data will be used to inform staff training and further policy development. When will policy be reviewed? Every 3 years Or sooner if there are significant policy or legislative changes
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13 Appendix 2 Equalities Impact Assessment EQIA – embedding EO action matrix Common Allocations Policy and associated activities. Method of analysis Lead officer Timescale Measure of success Common Allocation Policy • Performance management • Quality assurance audits • Feedback from partners and stakeholders • Customer feedback including complaints • SHR return Martin Smith Monthly - ongoing People in housing need are provided with appropriate and sustainable housing solutions and individual needs are considered. Housing is allocated in a fair and consistent way and in line with the Common Allocation Policy Homelessness Procedures • As above • SHR return • SG statistical return • Hub benchmarking Martin Smith Monthly - ongoing There is a sustained decrease in the levels of homelessness and the duration of homelessness Housing Options Procedures • As above • SHR return • SG statistical return • Hub benchmarking Martin Smith Monthly - ongoing There is an increase of people with housing needs being provided with appropriate and sustainable solutions which prevents their homelessness System processes • Performance management • Quality assurance audits • Feedback from partners and stakeholders • Customer feedback including complaints Martin Smith Monthly - ongoing Service standards • Performance management • Quality assurance audits • Feedback from partners and stakeholders • Customer feedback including complaints Martin Smith Monthly - ongoing Document/information materials that clearly indicate to people how to access the service, who it supports and what it provides. How particular vulnerabilities are safeguarded