Corporate report

Appendix 4: equality analysis guidance and template - for programmes, platforms, projects and policies

Updated 2 April 2024

Practical guidance on completing the template

An initial equality analysis must be completed if:

1. if you are developing/changing policy or activity, or way of working, that is relevant to equality
2. before implementation of the policy/activity or new way of working
3. if a detailed equality analysis is unlikely to be required
4. to show compliance with equality law

Consider the equality impacts on all of the relevant protected characteristic as defined by the Equality Act (2010) and, for Northern Ireland, section 75 of the Northern Ireland Act (1998). You need to show that all the groups have been considered.

For policies impacting on Northern Ireland, you must identify whether there are major, minor or no impacts on equality of opportunity; and good relations between people of different religious belief, political opinion or racial group.

Where a policy clearly has major implications for equality (for example the potential equality and/ or good relations impacts are likely to be adverse; the policy is significant in terms of strategic importance; the policy is significant in terms of expenditure) or is likely to affect a large number of customers or staff in a disproportionate way, then a more detailed equality analysis should be undertaken before the policy is implemented. A specific programme that had major impacts was the closure of enquiry centres in 2013 to 2014.

The mitigation for the creation of the Needs Enhanced Support service in 2014, which is able to provide dedicated phone and face-to-face support for those customers that need extra help.

An example of minor impacts, or no impacts, might be around system or software updates that enable us to improve service delivery.

Equality

You must show that you have assessed impact against each of the protected characteristics in turn, and so even where there is not an adverse impact, ensure you record ‘None’ against the protected characteristic.

Show:

1. whether there are any differential or adverse impacts upon people according to their protected characteristic
2. whether there is evidence of direct or indirect discrimination
3. whether the policy, project etc could lead to harassment or victimisation

For policies which also impact on Northern Ireland:

Promoting equality

What opportunities are there to promote equality between people of different protected characteristics?

What opportunities are there to promote good relations between people of different protected characteristics?

Equality Impact Assessment – for programmes, platforms, projects and policies

The purpose of equality analysis is to identify those policies that are likely to have an impact on equality of opportunity and, or good relations. This will be part of the policy development process, before the policy is implemented.

HMRC equality analysis

You will need to complete this template:

1. if you are developing/changing policy or activity, or way of working that is relevant to equality
2. before implementation of the policy/activity or new way of working
3. if a detailed equality analysis is unlikely to be required
4. to show compliance with equality law

For policies impacting Northern Ireland, the following questions should be considered:

• what is the likely impact on equality of opportunity for those affected by this policy, for each of the section 75 equality categories? (minor/major/none)
• are there opportunities to better promote equality of opportunity for people within the section 75 equality categories?
• to what extent is the policy likely to impact on good relations between people of a different religious belief, political opinion or racial group? (minor/major/none)
• are there opportunities to better promote good relations between people of a different religious belief, political opinion or racial group?

Step 1: identifying the aims of the policy or activity

1. Title of policy/activity
2. Planned implementation date
3. Who has responsibility for managing the policy/activity?

4. Full description of the aims of the policy/activity: - who is affected? (Staff, customers or both) - who benefits? - what are you trying to achieve?

5. How many people or locations are likely to be affected?
6. Who (in HMRC) implements this policy/activity? (For example, managers, Human Resources)
7. Does this policy/activity interact with any other policies, activities or business areas? If so, list them and explain how.

Step 2: gather evidence

1. Who are the internal and external stakeholders of this proposed action? (Include stakeholders that will help you to identify and manage any equality issues)
2. How will you work with the stakeholders in implementing this function?
3. What data have you collected and analysed? Note that sufficient data needs to be analysed before decisions can be made.
4. If little or no statistical data exists, what other methods have you used to gather information on potential or actual equality outcomes? For example, which stakeholders have you informally consulted?

Step 3: assess the impact

Using the data gathered in Step 2, for each equality group assess whether:

• there are any equality impacts
• there is evidence of direct or indirect discrimination
• the policy or its implementation could lead to harassment or victimisation
• there are opportunities to promote equality

Where adverse impacts are identified, you must provide details of the mitigation you have put in place to remove or reduce them.

State what evidence you have used to identify these impacts, including evidence to support no differential impact where applicable. If you do not have sufficient data to make an informed assessment, you will need to go back to Step 2 and gather more.

Equality group	Impact on customers (minor/major/none)	Impacts on staff (minor/major/none)	Proposed mitigation	Opportunities to promote equality
Racial group
Disabled/not disabled
Gender
Gender reassignment
Sexual orientation
Age
Religion or belief (including philosophical belief)
Persons with or without dependants (where there is an impact on people in Northern Ireland)
Pregnancy and maternity
Marriage and Civil Partnership
Political opinion (for NI only)
People who use different languages (including. Welsh language and British Sign Language)

For policies/activities that include an impact on people in Northern Ireland, (a) to what extent is the policy likely to impact on good relations, and (b) what opportunities are there to promote good relations?

	Impact: (minor/major/none) and give details	Opportunities to promote good relations
between people of a different religion or belief (including philosophical belief)
between people of a different political opinion
between people of a different racial group

Step 4: consider the alternatives

If adverse impacts have been identified, look at your policy and activity again to see if there are alternative ways of achieving the same aim which have a less adverse effect on equality. This may also mean reviewing your proposed mitigation.

Step 5: formal consultation – this is only relevant to detailed equality analysis

Step 6: decision making

Once you have decided whether to change or adopt the policy/activity:

1. what changes did you make as a result of doing this equality analysis?
2. any other comments on this proposed activity or any key learning for other similar policies/activities?
3. please indicate if a detailed equality analysis is recommended: Yes/No If ‘Yes’ then:

a. date detailed equality analysis will be completed:

b. consider the priority of the detailed equality analysis: High/Medium/Low (delete as apropriate and explain which equality groups are most at risk).

Note that equality analysis work should be prioritised according to the risk of the impacts identified and the risk of the proposal to the department based on our legal obligations and business objectives.

If you answered ‘No’, please give clear justification for this decision.

Step 7: make monitoring arrangements

You must monitor the implementation of your proposal and the mitigation that you have put in place to ensure that it is effective. If it’s not, you will need to put in place alternative solutions. Note that the equality analysis process is not complete until monitoring has finished.

1. How do you plan to monitor this activity?
2. Date you will review your monitoring activity?
3. Who will be responsible for carrying out the monitoring and analysing the results?

Step 8: publish your results

A copy of this completed template may be requested by interested parties at any time under Freedom of Information.

Consider publication on your local intranet site.

Sign off

Before signing off this equality analysis, it should be quality checked to ensure it meets minimum legal compliance.

Completed by:

Job title/role:

Business unit and office:

Assessor signature:

By, or on behalf of, directors:

Date:

Post implementation monitoring review

Comment on:

• what you have done to monitor this activity
• outcomes from monitoring – for example, was the proposed mitigation sufficient/successful? If not, what else did you do?
• what further action is needed
• how you have addressed the issues identified during monitoring
• the next review date, if required

Reviewed by:

Date: