Single Equalities Scheme for Northern Ireland

Section 75 of the Northern Ireland Act 1998 requires the Electoral Commission to comply with two statutory duties:

Section 75 (1) of the Northern Ireland Act (1998) requires us, in carrying out our functions relating to Northern Ireland, to have due regard to the need to promote equality of opportunity: 

• between people of different religious belief, political opinion, racial group, age, marital status or sexual orientation
• between men and women generally
• between people with a disability and people without, and
• between people with dependants and people without

Section 75 (2) requires us in addition to have regard to the desirability of promoting good relations between people of different religious belief, political opinion or racial group.

“Functions” includes our “powers and duties” including our employment and procurement functions.
 

• Schedule 9.4 (1) of the 1998 Act requires us as a designated public authority to set out in an Equality Scheme how it proposes to fulfil the duties imposed by Section 75. This Scheme accordingly sets out how we propose to do so and our plan for implementation.
• We are committed to the discharge of our Section 75 obligations in all parts of our organisation, and we will commit the necessary available resources in terms of people, time and money to ensure that the Section 75 statutory duties are complied with and that our Equality Scheme can be implemented effectively.

We have set out in Chapter 1 of our Equality, Diversity and Inclusion Strategy the purpose and objectives of the Electoral Commission across the UK.

• We are committed to the fulfilment of our Section 75 obligations in all parts of our work.
• By delegated authority, overall responsibility for the Commission’s Single Equality Scheme rests with our Chief Executive. Operational responsibility for the day to day implementation of this scheme in respect of Northern Ireland rests with the Head of the Electoral Commission in Northern Ireland. The development, maintenance, implementation and review of our Single Equality Scheme in line with our statutory duties and good practice issued by the ECNI is the responsibility of the Commission’s Equality, Diversity and Inclusion Lead. They report to the Head of Strategic Planning and Performance as part of the Directorate of Finance and Corporate Services.
• If you have any questions or comments please contact:

Cahir Hughes
Head of the Electoral Commission in Northern Ireland
4 Cromac Place
The Gasworks
Belfast 
BT7 2JB
0333 103 1928
[email protected]

• Objectives and targets relating to our statutory duties and our objectives for equality, diversity and inclusion are integrated into our strategic and operational business plans.
• These are also reflected in employees’ job descriptions, objectives and regular performance reviews.
• We will prepare an annual review of the progress we have made on implementing the arrangements set out in this scheme and how we meet our Section 75 statutory duties. We will send this annual report of our progress to the Equality Commission for Northern Ireland by 31 August each year and will be mindful of any guidance on annual reporting issued by the Equality Commission. We will publish progress reports on our website after each annual review, and will include an update on progress in our Annual Report.
• Our Annual Report is available on our website www.electoralcommission.org.uk or by contacting:

Cahir Hughes
Head of the Electoral Commission in Northern Ireland
4 Cromac Place
The Gasworks
Belfast 
BT7 2JB
0333 103 1928
[email protected]

• We will liaise closely with the ECNI to ensure that progress on the implementation of this equality scheme is maintained.
• Our EDI Strategy and this Scheme have been approved by the Electoral Commission Board.

• We have developed an Action Plan for the Commission which forms part of this Strategy. Appendix 4 of this Scheme sets out a Timetable for Action in Northern Ireland.
• Our Plan and Timetable have been developed and prioritised on the basis of an audit of inequalities set out in Chapter 1 of the Strategy. This has gathered and analysed information across Section 75 categories to identify the inequalities that exist for our service users and those affected by our policies. It sets out how we propose to deliver against our three equality objectives based on our analysis of the inequalities that may exist for our service users, those affected by our policies and those who work for the Commission.
• We have set out proposed actions which are specific, measurable, linked to achievable outcomes, realistic and timebound, We have identified performance indicators, timescales and responsibilities.
• The Action Plan and Timetable are aligned with our corporate planning and annual business planning cycles, and actions are reflected in our Operational Plans.
• We have consulted stakeholders on the Strategy, Action Plan and Timetable and will keep under review with them.
• We will monitor progress on the delivery of these action measures annually and update the Action Plan and Timetable as necessary.
• We will inform the ECNI of any changes or amendments to our Action Plan and Timetable and will also include this information in our Section 75 annual progress report to the Commission. Our Section 75 annual progress report will incorporate information on progress we have made in implementing our action plans/action measures.
• The Action Plan and Timetable can be obtained from our website www.electoralcommission.org.uk or by contacting:

Cahir Hughes
Head of the Electoral Commission in Northern Ireland
4 Cromac Place
The Gasworks
Belfast
BT7 2JB
0333 103 1928
[email protected]

The Scheme is available on request in alternative formats.

• Screening enables us to identify those policies that are likely to have an impact on equality of opportunity and/or good relations.
• Screening is completed at the earliest opportunity in the policy development and review process. Policies we propose to adopt will be subject to screening prior to implementation; where there are a series of stages we may screen more than once.
• The lead officer responsible for putting together the policy and taking the decisions will take the lead role in screening that policy. Screening will also involve other relevant team members, for example, our senior EDI lead, those who implement the policy and staff members from other relevant work areas. Where appropriate we will include key stakeholders in the screening process.
• The screening process for all policies includes the following:
  • The likely impact on those in the Section 75 equality categories
  • Opportunities to better promote equality of opportunity for those within the Section 75 categories
  • The extent to which the policy is likely to impact on good relations between people of a different religious belief, political opinion or racial group;
  • Opportunities to better promote good relations between people of a different religious belief, political opinion or racial group
• To help us answer these questions we gather relevant information and data, both qualitative and quantitative. In taking this into account we consider the different needs, experiences and priorities of the Section 75 equality categories. The screening decision is informed by this evidence.
•  Our screening will lead to three potential outcomes:
  • The policy is screened in and needs a full EqIA
  • The policy is screened out but needs mitigation or an alternative policy
  • The policy is screened out and does not need an EqIA
• If our screening concludes that the likely impact is minor, we may decide to carry out a full EqIA anyway; and we will consider potential mitigations and alternative policies. Where we do so we will explain this in the screening assessment. The decision will be discussed with our EDI Senior Lead and signed off at Director level.
• If the effect is major we will as a rule proceed to a full EqIA. This will be discussed with our EDI Senior Lead and signed off at Director level.
• If the screening concludes that there is no impact, we will give reasons as to why we are screening the policy out. The assessment will be discussed with our EDI Senior Lead and signed off at Director level.
• As soon as possible following the completion of the screening process, the screening template, signed off and approved by the senior manager responsible for the policy, will be made available on our website www.electoralcommission.org.uk and on request from: 

Cahir Hughes
Head of the Electoral Commission in Northern Ireland
4 Cromac Place
The Gasworks
Belfast 
BT7 2JB
0333 103 1928
[email protected]

We will publish a quarterly list of screenings we have carried out on our website and alert our consultees. Screenings will be made available on request.

• If a consultee raises a concern about the screening based on supporting evidence, including the ECNI, we will review the screening decision.
• Our screening reports are published quarterly (see below for details)

• An EqIA is a thorough and systematic analysis of a policy. Its primary function is to determine the extent of any impact on the Section 75 categories and to determine if the impact is an adverse one. It is also an opportunity to demonstrate the likely positive outcomes of a policy and to seek ways to promote more effectively equality of opportunity and good relations.
• If screening identifies the need for an EqIA, we will carry this out in line with the principles laid down by the ECNI and set out in our own guidance. It will be carried out as part of the policy development process before the policy is adopted and implemented.
•  EqIAs will be subject to consultation as set out in chapter 3 above. We will allow sufficient time for effective consultation and observe the timescales set out in the ECNI’s Guide to the Statutory Duties.

As set out above, we make publicly available on our website the likely impact of our policies on the promotion of equality of opportunity and good relations.

Screening reports are published quarterly. Screening reports detail:

• All policies screened by the Electoral Commission over the three month period
• A statement of the aim(s) of the policy/policies to which the assessment relates
• Consideration given to measures which might mitigate any adverse impact
• Consideration given to alternative policies which might better achieve the promotion of equality of opportunity; 
• Screening decisions, i.e:
  • whether the policy has been ‘screened in’ for equality impact assessment.
  • whether the policy has been ‘screened out’ with mitigation or an alternative policy proposed to be adopted.
  • whether the policy has been ‘screened out’ without mitigation or an alternative policy proposed to be adopted.
• Where applicable, a timetable for conducting equality impact assessments 
• A link to the completed screening template(s) on our website

We will publish a quarterly list of all screenings carried out and alert consultees. Where exceptionally a policy applies only in Northern Ireland we will do this only in Northern Ireland. Conversely where a policy exceptionally does not apply in Northern Ireland we will not follow this procedure.

All screening reports will follow our template. For details on the availability of our screening templates please check our screening process.

We will publish our EqIAs on our website following our EqIA template and setting out the results of the assessment. Equality impact assessments include: 

• A statement of the aim of the policy assessed
• Information and data collected
• Details of the assessment of impact(s)
• Consideration given to measures which might mitigate any adverse impact
• Consideration given to alternative policies which might better achieve the promotion of equality of opportunity
• Consultation responses
• The decision taken
• Future monitoring plans

All information we publish meets WCAG guidelines and can be made available in alternative formats.

The results of our assessments (screening reports and completed templates, the results of equality impact assessments) are available on our website http://www.electoralcommission.org.uk/about-us/equality-anddiversity and by contacting:

Cindy Williams
The Electoral Commission
3, Bunhill Row
London EC1Y 8YZ
[email protected]

In addition to the above, screening reports (electronic link or hard copy on request if more suitable for recipients) which include all policies screened over a 3 month period are also sent directly to all NI consultees on a quarterly basis. As set out above we will not do this if, exceptionally, the measures do not apply in NI.

We will inform the general public through communications such as press releases where this is necessary and/or appropriate.

Monitoring can help us to deliver better public services and continuous improvements. Monitoring equality information involves the processing of sensitive personal data (data relating to the racial or ethnic origin of individuals, sexual orientation, political opinion, religious belief, etc). To ensure that we monitor information confidentially and effectively we will follow guidance from the Office of the Information Commissioner and the ECNI.

We will monitor any adverse impact on the promotion of equality of opportunity of policies we have adopted. We are also committed to monitoring more broadly to identify opportunities to better promote equality of opportunity and good relations in line with ECNI guidance.

The systems we have established to monitor the impact of policies and identify opportunities to better promote equality of opportunity and good relations are:

• collection, collation and analysis of existing relevant primary and secondary quantitative and qualitative data across all nine equality categories on an on-going basis
• a review of information and data collected within one year of approval of this equality scheme, to identify the extent of current monitoring and take action to address any gaps in order to have the necessary information on which to base decisions
• collection of new data if necessary

We will revise a policy if over a two year period of monitoring, evaluation shows a greater adverse impact than predicted, or if opportunities arise which would allow for greater equality of opportunity to be promoted and ensure better outcomes for relevant equality groups.

We review our equality impact assessment monitoring information on an annual basis. Other monitoring information is reviewed in line with the performance cycle set out in our published Corporate Plan.

We will publish the results of our monitoring of adverse impacts of policies we have adopted in a timely manner and welcome feedback to further inform our policy development. However, we are committed to monitoring more broadly and the results of our policy monitoring are published as set out below.

EqIA monitoring information is published as part of our Section 75 annual progress report.

We will be proactive in announcing the outcomes of our monitoring (which will be in six monthly updates on our website) by contacting consultees in Northern Ireland when these are published.

All information published is accessible and can be made available in alternative formats on request.

Our training arrangements including objectives and monitoring and evaluation arrangements are set out in our EDI Strategy. They are designed to ensure that:

• All staff are aware of the provisions of Section 75 of the 1998 Act, our Equality Scheme commitments and the particular issues likely to affect people across the range of Section 75 categories, to ensure that our staff fully understand their role in implementing the scheme 
• Staff engaged in policy assessment through screening and EqIAs are provided with the necessary skills and knowledge
• Staff engaged in dealing with complaints on compliance, consultation and monitoring implementation of the Equality Scheme are provided with the necessary skills and knowledge

We have put in place the following arrangements to ensure staff and Board members are aware of and understand our obligations on equality, diversity and inclusion:

• A summary and access to all key material are easily available on a link from our homepage
• The full equality scheme is available to all staff through this link
• Staff were briefed in a session led by the Chief Executive on the draft strategy, and there will be further briefing sessions post approval
• Material on our statutory obligations and our EDI commitments is included in our induction training
• Focused training is provided where needed for those working on the implementation of commitments in the Strategy and Scheme
• Training is provided as appropriate on the issues experienced by those with protected characteristics and identified in Section 75
• Our Senior EDI lead ensures that awareness is updated as appropriate on issues relating to equality, diversity and inclusion
• The Board is to be supported by an independent adviser on equalities

This programme has been developed in consultation with staff groups such as our Equality, Diversity and Inclusion group, our Race at Work Charter Task Force, our Staff Engagement Group and our Dignity, Respect and Empowerment Group. It reflects our learnings from external stakeholders in the course of business.

We evaluate as we would for any learning and development the extent to which participants have built their skills and knowledge; and we monitor numbers trained. The extent to which training arrangements have been met will be reported on as part of the Section 75 annual progress report, which will be sent to the Equality Commission for Northern Ireland.

To ensure equality of opportunity in accessing information, we provide information in alternative formats such as Braille, EasyRead and audio format (such as CD, MP3 or DAISY) and in minority languages to meet the needs of those for whom English is not their first language on request where reasonably practicable, and will ensure a reasonable alternative is provided if we cannot meet a request. We will respond to such requests within a month where possible in line with our response to all requests. We will liaise with representatives of young people, disability and minority ethnic organisations and take account of existing/developing good practice and work in partnership with them to develop the best ways of reaching such groups.

We will advertise in a range of media as appropriate.

Our website is WCAG compliant.

Democracy is for us all, and we are committed to ensuring that all our services are fully accessible to everyone with protected characteristics or within Section 75. We adhere to the relevant provisions of current anti-discrimination legislation.

We have set out in our EDI Strategy our arrangements for ensuring that all of our services are fully accessible to customers and stakeholders. We make access recommendations and work with others to remove barriers as part of our work to ensure that everyone who is eligible is able to participate in the democratic process. We identify groups who are less likely to have access to democracy and undertake a range of initiatives to target them such as campaigns and partnership working.

We monitor access to our information and services annually in all our work to ensure we promote equality of opportunity and good relations.

We ensure that these aspects are covered in our regular programme of research and monitoring such as:

• access audits, 
• website audits, 
• monitoring requests for information in alternative formats, 
• monitoring complaints, 
• seeking feedback, 
• including relevant questions about access to information and services in service user surveys, 
• engagement with stakeholders etc. 

Appendix 1: organisation chart

Learn about our Executive Team and Senior Leadership team.

Appendix 2: groups relevant to Section 75 categories

This list is illustrative, not exhaustive.

Religious belief:

Buddhist; Catholic; Hindu; Jewish; Muslims; people of no religious belief; Protestants; Sikh; other faiths. For the purposes of Section 75 the term “religious belief” is the same definition as that used in the Fair Employment and Treatment (Northern Ireland) Order, 1998. Therefore “religious belief” also includes any perceived religious belief or lack of belief and, in employment situations only, also covers any “similar philosophical belief”

Political opinion: 

Nationalist generally; Unionists generally; members/supporters of other political parties. For the purposes of Section 75 the term “political opinion” is the same definition as that used in the Fair Employment and Treatment (Northern Ireland) Order 1998. Therefore “political opinion” also includes any perceived political opinion or lack of opinion

Racial group:

Black people; Chinese people; Indians; Pakistanis;; people of mixed ethnic background; Polish; Roma; Travellers; White people; people of other racial groups

Men and women generally:

Men (including boys); Trans-gendered people; Transsexual people; women (including girls)

Marital status:

Civil partners with people in civil partnerships; divorced people; married people; separated people; single people; widowed people

Age:

Children and young people; older people

Persons with a disability:

Persons with disabilities as defined by the Disability Discrimination Act 1995

Persons with dependants: 

Persons with personal responsibility for the care of a child; for the care of a person with a disability; for the care of a dependent older person

Sexual orientation:

Bisexual people; heterosexual people; gay or lesbian people

Appendix 3: List of consultees in Northern Ireland

A list of consultees in Northern Ireland can be found as part of the wider list of consultees annexed to the EDI Strategy.

Appendix 4: Timetable for measures proposed

Appendix 5: Glossary

Definition of the characteristics of people protected from discrimination in the UK 

Age: Under Chapter 1 of the Equalities Act 2010 this refers to persons defined by age group, whether a particular age or a range of ages. Section 75 of the Northern Ireland Act guidance1 proposes that for most purposes, the main categories are: those under 18; people aged between 18 and 65; and people over 65. However, the definition of age groups will relate to the policy under consideration.

Disability: Under Chapter 1 of the Equalities Act 2010 a person has a disability if s/he has a physical or mental impairment which has a substantial and long-term adverse effect on that person's ability to carry out normal day-to-day activities.

Gender reassignment: Under Chapter 1 of the Equalities Act  this refers to people who are proposing to undergo, are undergoing or have undergone a process or part of a process for the purpose of reassigning their sex by changing physiological or other attributes of sex. A reference to a transsexual person is a person who has the protected characteristic of gender reassignment. 

Marriage and Civil Partnership: Under the Equality Act 2010 civil partners must be treated the same as married couples on a wide range of legal matters. ‘Status’ can refer to whether a person is single, divorced or separated, married or in a civil partnership. Section 75 of the Northern Ireland Act guidance refers to married people; unmarried people; divorced or separate people; and widowed people.

Pregnancy and maternity: Pregnancy is the condition of being pregnant. Maternity refers to the period after the birth, and is linked to maternity leave in the employment context. In the non-work context, protection against maternity discrimination is for 26 weeks after birth, and includes treating a woman unfavourably because she is breastfeeding.

Race: Race is defined in the Equality Act 2010 as including colour, nationality and ethnic or national origins.
Religion: Religion has the meaning usually given to it but belief includes religious and philosophical beliefs including lack of belief (e.g. Atheism).

Sex is defined in the Equality Act 2010 as referring to men and women.

Sexual Orientation is defined in the Equality Act 2010 as referring to whether a person's sexual attraction is towards their own sex, the opposite sex or to both sexes.

People with dependants: Section 75 of the Northern Ireland Act 1998 guidance defines this group as: people with a primary responsibility for: a child; a person with a disability; a dependent elderly person.

Political opinion: Section 75 of the Northern Ireland Act 1998 guidance defines political opinion as: Unionists generally; Nationalists generally; members/supporters of any political party; other.

Language: In compliance with the Welsh Language Act 1993 and the Welsh Language Measure 2011, this consideration refers to a group of people defined by the language they speak. In Wales we have a duty to provide services in Welsh and English as set out in the Welsh Language Standards.

Appendix 6: Action Plan

This forms Chapter 8 of the EDI Strategy.